Wednesday, September 5, 2012

A Meaningful Use Stage 2 FAQ

Today I had the privilege of speaking with CMS colleagues about Meaningful Use Stage 2.

As I've written in previous posts, MU 2 is truly a work of art and the stakeholder response to it has been very positive.

There are a few persistent questions about the MU program that are worth sharing with the community

1. What is the timing of each stage for early adopters - those who wish to attest as early as possible?

2012 - use stage 1 criteria
Eligible Professional (EP) reporting period is  January 1, 2012-December 31, 2012  with attestation in Jan/Feb 2013
Hospital reporting period is October 1,2011-Sept 30, 2012 with attestation in Oct/Nov 2012

2013 - use stage 1 criteria with optional refinements
EP reporting period is January 1, 2013-December 31, 2013  with attestation in Jan/Feb 2014
Hospital reporting period is October 1,2012-Sept 30, 2013 with attestation in Oct/Nov 2013

2014 - use stage 2 criteria (NOTE the 90 day reporting period to enable adoption of new MU Stage 2 certified products)
EP reporting period is January 1, 2014-March 31, 2014 with attestation in April/May 2014
Hospital reporting period is October 1, 2013-December 31, 2013 with attestation in Jan/Feb 2014

I'm guessing that stage 3 will return to the year long reporting period pattern
2015 - use stage 3 criteria
EP reporting period is January 1, 2015-December 31, 2015  with attestation in Jan/Feb 2016
Hospital reporting period October 1,2014-Sept 30, 2015 with attestation in Oct/Nov 2015

The program ends in 2016 and then penalties for non-attestation begin.

I've also been asked by pathologists, , anesthesiologists and especially radiologists about penalties for non-attestation.   These hospital-based specialists may file for the hardship exemption.  See the MU Stage 2 final rule page 446 for more detail

Finally, the stage 2 tip sheets provide valuable educational material for EPs and hospitals.  In the past, I've created educational materials on my blog, but these are so good, you can use materials directly from CMS!


THarkness said...

One minor point of clarification - 2015 will be the second year of attestation to Stage 2 criteria which will revert to the full year long reporting period.

Eligible professionals and hospitals, as the regulations are currently outlined, will have two years at each stage of meaningful use regardless of the year they begin reporting. The only exception is that early adopters who attested in 2011 will have three years of Stage 1 meaningful use. (Please see the chart on the link Dr. Halamka noted for tip sheets for more information.)

CMS representatives have pointed out that the 90 day reporting period in 2014 applies to all eligible professionals and hospitals because, regardless of the stage of meaningful use to which they are attesting, they must be using 2014 Edition certified software. (Hardship exemptions may apply if the vendor has not released their 2014 Edition EHR or the provider is still waiting in the vendor’s queue to implement. EP/EHs will need to be aware of the deadlines by which the hardship exemptions must be filed with CMS.)

Alex I said...

in the stage 1 to stage 2 comparison sheet from CMS it states that the Problem List is being eliminated as a measure and blended into the Summary of Care record. However, when the PDFs came out on Friday Sept 7th it showed the Problem List as still a measure albeit a "Revised" one with ICD-10-CM replaced by Snomed-CT.

Why the disconnect or am I missing some valuable piece of information that connects the dots?

John Halamka said...

From the CMS Final Rule:

"We proposed to combine some of the Stage 1 objectives for Stage 2. For example, the objectives of maintaining an up-to-date problem list, active medication list, and active medication allergy list would not be separate objectives for Stage 2. Instead, we proposed to combine these objectives with the objective of providing a summary of care record for each transition of care or referral by including them as required fields in the summary of care."

Rebecca W said...

Ok - I just spoke to Elizabeth from CMS who said she talked to you, John. :) Here is the situation with ICD-10 and MU Stage2 - it is OPTIONAL up until October 1, 2014. That is the reason for the date dfferences. After 10/1/14, it is REQUIRED. I think this is an important call-out, as ICD-10 is a major undertaking for organization. Thank you to Elizabeth from CMS for talking with me for an hour about this!!

Eric B said...

I cannot find anything that explicitly states when payments will be made for the EPs in Stage II. John, you mention that registration and attestation will occur after each quarterly period for Medicare. Did CMS indicate that payments would be made during 2014 given the provider has met his required dollars?

John Halamka said...

My experience is that CMS pays about 6 weeks after attestation i.e. May 2014