Summary of Key Provisions in Final Rule for Stage 2 HITECH Meaningful Use
Author: Jane Metzger, Jared Rhoads
The final rules for Stage 2 of the Medicare and Medicaid Electronic Health Record Incentive (EHR) Programs were released by the Centers for Medicare and Medicaid Services and the Office of the National Coordinator, respectively, on August 23, 2012. These specify the meaningful use criteria that eligible professionals, eligible hospitals and critical access hospitals must meet in order to continue to participate in the program, the certification requirements for EHR technology that qualifies for use in the program, and the data and transmission standards to be incorporated into the Certified Electronic Health Record Technology providers are to use in achieving meaningful use. This paper provides a summary of the key provisions.
The Global Institute for Emerging Healthcare Practices is the applied research arm of CSC’s Healthcare Group.
Current as of November 28, 2012
- The final rules for Stage 2 requirements for meaningful use and electronic health record (EHR) standards and certification were released by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC), respectively, on August 23, 2012.
- Much of the content in the final rule is in line with how Stage 2 was described in the Notice of Proposed Rule Making (NPRM) released in February 2012.
- Despite much comment from the industry on the complexity and number of requirements for meaningful use, the list for both eligible professionals (EPs), eligible hospitals (EHs) and critical access hospitals (CAHs) remains about the same, though many are carried over from Stage 1, but with a much higher threshold of minimum level of use.
- The final rule gives participating providers more time to meet Stage 2 requirements through a combination of allowing providers still working to achieve Stage 1 the ability to use 2011-certified technology through 2013, giving 2011-attesting provider organizations another year to achieve Stage 2 (2014 instead of 2013), and defining the EHR reporting period for both meaningful use and clinical quality measure (CQM) reporting for Stage 2 in 2014 as three months, rather than one year.
- Overall participating providers have more options in terms of which measurement approach to use for some meaningful use criteria and when to transition to electronic reporting of CQMs, and, for those organizations still working to achieve Stage 1 meaningful use, even whether to employ 2011- or 2014-certified EHR technology. For providers, this will require more (sometimes inter-related) decisions to sort out the right path; vendors of Certified EHR Technology (CEHRT) will have to be able to support every path.