AMGA Public Policy Department Seeks Insights Concerning
Proposed Rule: Medicare and Medicaid Electronic Health Record Incentive Program -- Meaningful Use Stage 2
Federal Register, March 7, 2012 (CMS-0044-P)
Comments due May 7, 2012
Overview
The Centers for Medicare and Medicaid Services (CMS) issued the Stage 2 proposed rule for the Medicare and Medicaid Electronic Health Record Incentive Program on March 7, 2012, available at this link. The proposals focus on increasing the electronic capture of health information in a structured format and the exchange of clinical information between health care providers at care transitions. The core/menu set structure for Stage 2 has been retained from Stage 1, meaning some objectives will be required, and others can be selected in order to provide some flexibility in achieving the requirements of the program. In response to grave concerns from health care providers and software vendors about being prepared for the next stage, CMS has delayed the start of Stage 2 from 2013 to 2014, as recommended by the Office of the National Coordinator’s Health Information Technology Policy Committee.
CMS proposes that eligible professionals (EPs) must meet or qualify for an exclusion to 17 core objectives and 3 of 5 menu objectives. CMS proposes that eligible hospitals and critical access hospitals (CAHs) must meet or qualify for an exclusion to 16 core objectives and 2 of 4 menu objectives. Nearly all of the Stage 1 core and menu objectives would be retained for Stage 2, with an increase in measure thresholds that providers must achieve for each objective that has been retained from Stage 1.
Modifications to Stage 2 Objectives
The changes from Stage 1 to Stage 2 objectives are outlined in Table 3 of the proposed rule. Highlights include:
· Replacing the phrase “provide patients with an electronic copy of their health information” with an “electronic/online access” core objective;
· Compliance thresholds for some objectives have been increased, such as the requirement for more than 50 percent of all unique patients seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency department during the EHR reporting period to have blood pressure (for patients over age 3) and height and weight (for all ages) recorded as structured data; and
· The former “report ambulatory (hospital) clinical quality measures to CMS or the states” objective has been incorporated directly into the definition of a meaningful electronic health record (HER) user and eliminated as an objective.
Table 4 lists Stage 2 meaningful use objectives and associated measures, sorted by core and menu set objectives.
Clinical Quality Measures
CMS is proposing clinical quality measures (CQMs) for Stage 2 that align with other quality reporting programs such as the Physician Quality Reporting System (PQRS), the Medicare Shared Savings Program, and the National Council for Quality Assurance, found in Table 8. CMS has posted additional detailed information on the Stage 2 proposed CQMs, which is available here. The agency is specifically seeking stakeholder input on the CQMs.
Group Reporting Options
For Stage 2, CMS is also proposing group reporting options, beginning in 2014. These options will be available for eligible professionals (EPs) in a single group practice who are beyond the first year of Stage 1. The options would apply to EPs who are participating in the Medicare Shared Savings Program and those who are testing the Pioneer Accountable Care Organization (ACO) model. CMS proposes that EPs who use certified EHR technology to submit ACO measures would qualify. Medicare EPs who satisfactorily report PQRS quality measures in the Group Practice Reporting Option and use certified EHR technology would also be eligible for the group reporting option under this program.
AMGA Topics for Discussion
AMGA is interested in your views concerning the proposed rule and would like to take your thoughts into account when developing comments for submission to CMS. In order to better understand your perspective on the proposed rule, we plan to hold a conference call on Friday, April 20 at 2 p.m. EST. CMS welcomes comments on all provisions found in the proposed rule, however, the agency is soliciting specific public feedback on the following issues, which we plan to use as a basis for our discussion:
1) Mechanisms for electronic CQM reporting, including aggregate-level electronic group reporting options, and through existing quality reporting systems;
2) The proposed changes to Stage 1, summarized in Table 3;
3) Whether the problem list should be extended to include “when applicable, functional and cognitive limitations” or whether a separate list should be included for these limitations;
4) A wide-ranging list of 125 potential measures for EPs and 49 potential measures for eligible hospitals and critical access hospitals (and will finalize only a subset);
5) The “core” measures listed in Table 6; and
6) The number and appropriateness of measures for hospitals and CAHs, found in Table 9.
We welcome discussion on any other issues of interest or concern.
Please dial-in on Friday, April 20, 2 pm, EST at: 1-888-295-9066, passcode #4817.