In an earlier post, I had analyzed side by side the final Stage 1 criteria for achieving meaningful use to the interim Stage 2 criteria that will be phased in starting in 2014. Following that analysis, HHS released the final Stage 2 criteria. As a result, the comparison has changed a bit from my post earlier this year. The following two tables analyze the final Stage 1 Core and Menu Criteria in comparison to the same for the final Stage 2 criteria.
A few highlights on what changed between the interim and final Stage 2 criteria. First, a few of the final Stage 2 criteria ended up reducing the compliance metrics from what was proposed in the initial Stage 2 criteria. See 495.6(j)(1), (j)(9) and (j)(11).
However, a few of the Stage 2 criteria metrics were changed to include additional requirements for compliance which might present a curve ball for those of you planning on obtaining compliance with these. For example, in the final Stage 2 regulation, the criterion on patient access to health information has an added metric that 5% of patients actually download information available electronically from the provider. You may want to contact your information systems vendor to determine if the portal you are implementing can provide you with this kind of information as it may not be collected and stored in a way that a report could be generated to evaluate compliance.
In addition, a new Menu criterion was added in the final Stage 2 regulations, found at 495.6(k)(6). Here, a practice could elect to enter patient chart information as structured data; the metric requires that 30% of patients that are seen during the reporting period have data entered in this manner. As a practical matter, many EHR systems today will store documented patient information as structured data where the patient visit is documented electronically as a part of the patient visit. This might be an easy Menu criterion to comply with (as you need to pick three of the six total criteria in the final Stage 2 regulations).
Table 1 – Core Criteria Under Stage 1 and Stage 2 Meaningful Use Comparison
Eligible Providers must meet all of the Core Criteria to Qualify for the Incentives. Stage 1 had 15; Stage 2 has 17. Stage 1 meaningful use Core Criteria are found in section 495.6(d) for eligible providers. Stage 2 meaningful use Core Criteria are found in section 495.6(j) for eligible providers.
| Core Criteria for EPSubsections (d), (j) | Stage 1 Metric | Stage 2 Metric |
| § 495.6(j)(1) – provider use of CPOE for medication, lab, and radiology orders | [§ 495.6(d)(1)] 30% of orders | 60% of medication orders;30% of lab and rad orders |
| § 495.6(d)(2) – drug-drug and drug-allergy checking | Enabled during period | moved to 495.6(j)(9), same metric |
| § 495.6(d)(3) – maintain up to date problem list | 80% of patients | subsumed into transition of care requirement. |
| § 495.6(j)(2) electronic prescriptions | [§ 495.6(d)(4)] 40% of Rx | 50% of Rx |
| § 495.6(d)(5) – active medication list | 80% of patients | subsumed into transition of care requirement. |
| § 495.6(d)(6) – active allergy list | 80% of patients | subsumed into transition of care requirement. |
| § 495.6 (j)(3) demographics | [§ 495.6(d)(7)]50% of patients with encounters | 80% of patients with encounters |
| § 495.6 (j)(4) vital signs | [§ 495.6(d)(8)]50% of patients with encounters | 80% of patients with encounters |
| § 495.6 (j)(5) smoking status | [§ 495.6(d)(9)]50% of patients with encounters | 80% of patients with encounters |
| § 495.6(d)(10) – reporting clinical measures to CMS or State | Successful testing | not a separate criterion; CQM submission required |
| § 495.6 (j)(6) decision support | [§ 495.6(d)(11)] Implement 1 decision support intervention | Implement 5 decision support interventions |
| § 495.6 (j)(7) lab results as structured data | [§ 495.6(e)(2)] Was Menu in Stage 1; 40% of all lab results | 55% of all lab results |
| § 495.6 (j)(8) patient lists by specific condition for QI | [§ 495.6(e)(3)] Was Menu in Stage 1; at least 1 list | At least 1 list |
| § 495.6 (j)(9) patient reminders | [§ 495.6(e)(4)] Was Menu in Stage 1; 20% of patients sent during period | 10% of patients seen in last 2 years receive a reminder |
| § 495.6 (j)(10) patient electronic access of health information | [§ 495.6(e)(5)] Was Menu in Stage 1; 10% of patients receive timely access | 50% of patients receive timely access & 5% actually download information |
| § 495.6 (j)(11) clinical summaries at patient visit | [§ 495.6(d)(13)] 50% receive summary from office visit | 50% receive summary from office visit |
| § 495.6 (j)(12) patient education resources | [§ 495.6(e)(6)] Was Menu in Stage 1; 10% of patients receive ed. resources | 10% of all office visits |
| § 495.6 (j)(13) medication reconciliation for transition of care | [§ 495.6(e)(7)] Was Menu in Stage 1; 50% of transitions have recon | 50% of transitions of care have medication recon |
| § 495.6 (j)(14) patients transitioned to another provider’s care have care summary prepared by provider | [§ 495.6(e)(8)] Was Menu in Stage 1; 50% of transitions have recon | 50% of transitions of care have patient summary; 10% of transitions must involve exchange of data |
| § 495.6 (j)(15) capability to submit electronic data to immunization registry | [§ 495.6(e)(9)] Was Menu in Stage 1; perform 1 test to registry | Ongoing submission of data to registry during CY |
| § 495.6 (j)(16) security risk assessments under HIPAA security regulations | [§ 495.6(d)(15)] Conduct security assessment | Conduct security assessment |
| § 495.6 (j)(17) use electronic messaging to communicate with patients | N/A | 5% of patients seen during period received secure message from provider |
| [§ 495.6(d)(14)] – capability to exchange key clinical information among care providers and patients | One test of exchange | N/A |
| [§ 495.6(d)(12)] 50% of patients receive timely access | 50% in 3 days on patient request | N/A |
Table 2 – Menu Criteria Under Stage 1 and Stage 2 Meaningful Use Comparison
In Stage 1, EP had to meet 5 out of 10 Menu Criteria to qualify. In Stage 2, EP must meet 3 out of the 6 Menu Criteria to qualify. Stage 1 meaningful use Menu Criteria are found in section 495.6(e) for eligible providers. Stage 2 meaningful use Menu Criteria are found in section 495.6(k) for eligible providers.
| Menu Criteria for EPSubjections (e), (k) | Stage 1 Metric | Stage 2 Metric |
| § 495.6(k) (1) – access to imaging results in EHR | N/A | 10% of imaging results in EHR |
| § 495.6(k) (2) patient family health history in structured data | N/A | 20% of all patients seen |
| § 495.6(k) (3) capability to submit syndromic surveillance data to public health agency | [§ 495.6(e)(10)] Was Menu in Stage 1; perform 1 test to registry | Successful ongoing submission of data for period |
| § 495.6(k) (4) capability to identify and report cancer cases to State cancer registry | N/A | Successful ongoing submission of data for period |
| § 495.6(k) (5) capability to report other specialized registry (other than cancer) to specialized registry | N/A | Successful ongoing submission of data for period |
| § 495.6(k) (6) record electronic notes in patient records | N/A | 30% of patients seen during the reporting period |
| [§ 495.6(e)(1)] – implement drug formulary checking | Enable functionality | Moved to Core / decision support |
| [§ 495.6(e)(2)] – lab results as structured data | 40% of lab results are structured data | Moved to Core |
| [§ 495.6(e)(3)] – generate lists by specific conditions | 1 reporting list | Moved to Core |
| [§ 495.6(e)(4)] – send reminders to patients for follow-up care | 20% of patients | Moved to Core |
| [§ 495.6(e)(5)] – Provide patients with timely access to health information | 10% of patients have electronic access | Moved to Core |
| [§ 495.6(e)(6)] – Use EHR for patient education | 10% of patients | Moved to Core |
| [§ 495.6(e)(7)] – Incoming transition of care to EP medication reconciliation | 50% of patients have medication recon | Moved to Core |
| [§ 495.6(e)(8)] – Outgoing transition of care from EP care record summary | 50% of patients have care summary | Moved to Core |
| [§ 495.6(e)(9)] – immunization registry | 1 certified test | Moved to Core |
Faith At Law LLC 