This year marked the first of Stage 2 Meaningful Use (MU) for eligible providers, eligible hospitals and critical access hospitals (CAH) that already completed the required years of attestation to Stage 1 — three years if beginning Stage 1 in 2011, two years for those who began after. The objectives for Stage 2 are similar to Stage 1: all providers must meet a set of “core” objectives while also reporting on a number of available “menu” objectives, in order to attain MU certification and receive payments under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. For Stage 2 MU, eligible professionals must meet 17 core objectives and three menu objectives; eligible hospitals and CAHs will need to meet 16 core objectives and three menu objectives.
The arena of MU continues to be confusing for some healthcare providers and especially radiologists, with some coming late into the game and others unable to catch up to the requirements outlined for 2014. Earlier this year, the Centers for Medicare and Medicaid Services (CMS) announced it was scaling back on the deadlines for Stage 2 and putting off Stage 3 until 2017. The proposed rule would also allow participants in the EHR Incentive Programs to continue using certified electronic health record technology (CEHRT) from 2011 in the current reporting period, the 2014 calendar year. But beginning in 2015, eligible providers and hospitals would have to report MU objectives using 2014 editions of CEHRT.1
CMS cited that reasons for Stage 2 implementation delays included the increasing backlog of certification cases as well as the slower than anticipated adoption of CEHRT solutions. “Increasing the adoption of EHRs is key to improving the nation’s healthcare system, and the steps we are taking will give new options to those who, through no fault of their own, have been unable to get the new 2014 edition technology, including those at high risk such as smaller providers and rural hospitals,” said Karen DeSalvo, M.D., MPH, MSc, national coordinator for health information technology, United States Department of Health and Human Services, back in May.
Understanding Measures and Objectives
At the center of the Meaningful Use initiative is the set of clinical quality measures (CQM) that help track the quality of healthcare services provided by those in the program. The measuring tools track aspects of care such as health outcomes, use efficiencies, patient engagements and adherence to clinical guidelines.
Stage 1 of MU aims to capture a variety of information across healthcare: patient information, clinical conditions, health records and more. In Stage 2, providers are expected to focus more on demonstrating meaningful use of those records collected in Stage 1; while CQMs are similar to that of the first stage, there is more of an emphasis on patient engagement and information exchange between providers. Eventually, Stage 3 (now slated to start in 2017 due to the adjusted timeline proposed in May) will see the use of CEHRT bringing about improved outcomes and addressing national health priorities. For 2014, eligible professionals must report on nine out of 64 total CQMs, while eligible hospitals and CAHs must report on 16 out of 29.
Not all objectives will apply to all providers participating in MU, and radiology practices and imaging centers may need to look at their own situations to determine the best course of action for pursuing Stage 1 and Stage 2, and ultimately receiving incentive payments in the program. In order to avoid penalties, organizations can apply, or may already be eligible, for hardship exceptions. For example, physicians whose Medicare Provider Enrollment, Chain and Ownership System (PECOS) medical specialty codes are diagnostic radiology, interventional radiology and nuclear medicine can opt for specialty-based significant hardship exceptions. Note that those who opt for hardship exceptions cannot do so for more than five years and will eventually be penalized, barring future legislative intervention. The deadline to obtain a significant hardship exception from incentive program penalties for the 2015 calendar year was July 1.2
Since the creation of the Medicare and Medicaid EHR Incentive Programs, numerous healthcare providers have adopted EHR technology in order to begin demonstrating meaningful use. The CMS reported at the end of last year that “85 percent of eligible hospitals and more than six in 10 eligible professionals had received a Medicare or Medicaid EHR incentive payment.” It is estimated that nine out of 10 eligible hospitals and eight out of 10 eligible professionals had at least taken initial steps to register for the programs as of October 2013.3 The number of those in the process of attesting to Stage 2 MU has been slowly increasing, with both eligible hospitals and eligible professionals recently reporting that more participants are attesting to Stage 2 in the program from the prior month.4
The notice of proposed rulemaking for Stage 3 is expected for release in fall 2014. Those eligible to Stage 3 objectives are expected to begin the final stage in the program in 2017. At the time of writing, the Office of the National Coordinator for Health Information Technology (ONC) was also working on introducing a 2015 edition of certification criteria as an alternative to the 2014 set. While expected to improve upon the latter, the former would not require those already using 2014 edition EHRs to immediately upgrade to 2015.
Radiologists and other physicians looking to reap the benefits for the EHR Incentive Programs may be reconsidering or postponing decisions because of costs or unsuitable deadlines. Moving forward, expect more eligible providers to adopt EHR technologies to demonstrate Meaningful Use — which in the end will create a more connected healthcare community that greatly benefits both physicians and patients.
1. www.cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2014-Press-releases-items/2014-05-20.html, accessed June 17, 2014.
2. http://radiologyandhealthit.com/2014/05/28/reminder-meaningful-use-penalty-avoidance-deadline-approaching/, accessed June 17, 2014.
3. www.cms.gov/eHealth/ListServ_Stage3Implementation.html, accessed June 17, 2014.
4. www.ihealthbeat.org/articles/2014/6/11/eligible-provider-hospital-attestation-to-stage-2-increasing-slowly, accessed June 17, 2014.