CSC elucidates Stage 2 meaningful use NPRM

The Centers for Medicare & Medicaid Services announced at the 2012 Healthcare Information and Management Systems Society (HIMSS) conference that the notice of proposed rulemaking (NPRM) for Stage 2 of its EHR Incentive Program was filed to the Office of the Federal Register. With the NPRM set to be published on March 7 in the Federal Register with a 60-day comment period, Erica Drazen, ScD, managing director, Global Institute for Emerging Healthcare Practices of CSC, in an interview, made recommendations for eligible providers to consider as they continue their meaningful use journey.

According to Drazen, the proposed rule was more aggressive than expected. Some of the big changes for end-users is that all menu items in Stage 1 will become core objectives in Stage 2 and there will be new measures as well. Hospitals will have 16 core measures and must select two of four menu objectives while eligible providers will have 17 core objectives and be required to select three of five menu objectives. “That’s not a lot of flexibility,” Drazen said. “If you avoided a menu objective for Stage 1, I would get started on it now.”

There were some subtle changes from meaningful use Stage 1 to Stage 2, such as requirements relating to computerized physician order entry (CPOE), Drazen said. In Stage 1 final minimum requirement, 30 percent of patients need a CPOE medication order if they have any medication orders. In the Stage 2 proposed rule, that has been expanded to 60 percent of medication, laboratory and radiology orders using CPOE. This could be a challenge for some eligible providers because it is a much higher bar to adjust to in terms of expanding CPOE to all patients.

Another challenge lies in the changes of electronic copies of discharge instructions and health information. In the Stage 1 minimum final requirement, 50 percent of hospital patients who request discharge instructions would have fulfilled the requirement as well as 50 percent of patients who request electronic copies of health information. Now, in the proposed rule, those rules are replaced by the requirement that 50 percent of patients have access for both measures.

Built on that, 10 percent of patients, in the Stage 2 proposed rule, now must access that information electronically, said Drazen. “Not only do you have to provide access but also encourage patients to use it and access that information,” she said. “It’s your responsibility as a provider to educate people, get them on board and have them using that capability.”

While 10 percent may sound like a low threshold and is a reasonable target to Drazen, she cautioned that it takes time. ”If you don’t start now, you’re unlikely to reach this goal because it takes awhile to educate patients and get information in a format that a provider is comfortable sharing with patients.”

One surprise to Drazen was the lack of the requirement of a physician note for each visit despite it being recommended by the U.S. Department of Health and Human Services’ Health IT Policy Committee. However, according to Drazen, to get the data an eligible provider needs to report on quality measures, they need the information that a physician documents like diagnosis and procedures, potentially making the physician note a “hidden” requirement that will be necessary to fulfill the larger goal.

Drazen noted that another area of challenge, especially for small hospitals, could be the requirement that electronic medication administration is required for 10 percent of all medication orders for hospital patients in the Stage 2 proposed rule. “It doesn’t sound like a challenge as it’s pretty common but in order to check medications electronically, they need a barcode. If medications don’t come with a barcode, then one needs to be added,” said Drazen. “For small hospitals, this could be a challenge to make sure proper medications have proper barcodes if they don’t come that way.”

View the NPRM. View the CMS’ fact sheet.