Published in the April 2012 AAMC Reporter
By Whitney L.J. Howell
In late February, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) released the proposed rules for Stage 2 of meaningful use and corresponding certification requirements. The rules introduce new measurements that doctors and hospitals will be required to meet to receive incentive payments for implementing electronic health records (EHRs).
The Stage 2 meaningful use rule is part of the Health Information Technology for Economic and Clinical Health (HITECH) Act, which was included in the 2009 American Recovery and Reinvestment Act. Under HITECH, hospitals and providers can receive Medicare and Medicaid incentive payments for adopting certified EHRs, using health IT in “meaningful” ways, and reporting clinical quality measures. CMS began making payments under the Stage 1 rule last year. With the law, Medicare hospitals and physicians who do not use health IT “meaningfully” will be penalized beginning in 2015. CMS has proposed criteria to determine which providers would be subject to this penalty. In most cases CMS plans to use a 2013 reporting period to identify proactively which providers are subject to a penalty, said Lori Mihalich-Levin, J.D., AAMC director of hospital and GME payment policies for health care affairs.
Industry leaders are still dissecting the details of the Stage 2 rule, but several key points already have emerged that will affect how providers approach meaningful use.
“CMS is obviously moving toward improved interoperability and information exchange,” Mihalich-Levin said. “However, there are some serious flaws with some of the proposed measures.”
The AAMC plans to submit its concerns to CMS and ONC by the May 7 deadline.
The biggest red flags in the new rule, Mihalich-Levin said, are proposals that require actions by third parties—in this case a patient—for the hospital or physician to meet the requirements. For example, hospitals and physicians must provide patients with online access to their health information. But in order to receive credit for meaningful use, at least 10 percent of patients must log on and actually view their records. An additional measure calls for at least 10 percent of patients to send their physician a secure, online message about their health care.
The problem, she said, is that there are no incentives for patients to comply, and providers cannot control whether patients feel comfortable with electronic communication, or have access to it.
“Hospitals can’t meet that requirement by implementing technology,” said Rod Piechowski, senior director of health information services at the Healthcare Information and Management Systems Society (HIMSS). “They must engage the patients on a different level, get them to take action, and recognize the value of the data. It’s a little bit out of their direct control.”
The proposed rule also increases the reporting requirements for many existing measures. For example, while Stage 1 called for 30 percent of medications to be ordered through computerized provider order entry, Stage 2 bumps the requirement to 60 percent of medications, and includes laboratory and radiology orders.
“This could be something that’s a minor change, but it will still require extra work to make sure we get the right groundwork in place,” said Tom Smith, chief information officer for Chicago’s NorthShore University HealthSystem. “It’s certainly a good idea to move away from writing down prescriptions on paper—ordering 100 percent of medications through e-prescribing would be great.”
Physicians and other clinicians who are eligible for the meaningful use incentives through Medicare also could benefit from the rule’s group reporting proposals. Rather than collecting quality measure data from each physician individually, beginning in 2014, CMS will allow doctors in group practices to report as a single unit.
“When you have a practice of hundreds or thousands of physicians, it’s logical to identify performance on clinical metrics as a group,” said Mary Patton Wheatley, AAMC manager of physician quality and payment policies. “Instead of a faculty practice trying to report measures for a variety of specialists and subspecialists (many of whom do not have relevant measures that can be reported through an EHR), the group reporting option allows the practice to focus on a single set of measures that makes sense for the practice as a whole and improves quality for the patient.”
Under the quality reporting requirement, beginning in 2014, hospitals would be able to choose which measures they report. While the element of choice is appealing, there are concerns about how this will ultimately impact the flow of measures used in other programs, including value-based purchasing.
It’s important to remember that any of these proposed measures could change in the final rule, which is expected this summer, Mihalich-Levin said. Until then, she recommended that institutions familiarize themselves with the various proposals. She added that after receiving feedback on the proposed Stage 1 requirements, CMS addressed many of the AAMC’s concerns in the final Stage 1 regulations. Over the next few months, the AAMC will review the proposed Stage 2 rules and encourage member institutions to provide feedback.
Smith agreed the proposed rule offers several benefits to teaching hospitals, but he cautioned that many of the meaningful use measures will require additional work from hospitals and physicians. Achieving certification or compliance, he said, will take time and resource investments to produce positive results.
According to Piechowski, hospitals that are just getting started on health IT will benefit from what others have learned.
“Hospitals should pay attention to what others have done, stay connected, get involved, and get ahead of the curve,” Piechowski said. “That is the best thing they can do. The people who are just getting in now are in an advantageous situation.”
Despite the challenges, health IT adoption is on the upswing. According to CMS, 35 percent of hospitals were using EHRs in 2011, compared with 16 percent in 2009. In addition, 85 percent of hospitals have said they plan to implement meaningful use and take advantage of the incentive payments by 2015. CMS will likely release proposed rules for Stage 3 of meaningful use in 2014 for implementation in 2016 and beyond.
To read article at original location: https://www.aamc.org/newsroom/reporter/april2012/279214/meaningful-use.html