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Changes for Eligible Hospitals and Critical Access Hospitals within Stage 1

Changes for Eligible Hospitals and Critical Access Hospitals within Stage 1
The Notice of Proposed Rulemaking (NPRM) for Meaningful Use Stage 2 proposes changes that would affect those organizations attesting to Stage 1 in FY2013 and beyond. Changes are both subtle and broad, varying from wording changes to changing denominators and, occasionally, striking objectives entirely. The following is a high-level summary of the proposed Meaningful Use Stage 1 changes:
Core Objective 1: Use computerized provider order entry (CPOE) for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines
  • Rule would create a new denominator: “number of medication orders created in the eligible hospital’s emergency department.”
  • In FY2013 the organization can choose to report the current denominator, patients admitted to inpatient or emergency department with at least one medication in their medication list, or can report with the new denominator. FY2014 and beyond requires the new denominator for all reporters.
Core Objective 7: Record and chart changes in the following vital signs: (A) Height, (B) Weight, (C) Blood pressure, (D) Calculate and display body mass index (BMI), (E) Plot and display growth charts for children 2-20 years, including BMI
  • Rule would change measure by increasing the age limit for blood pressure to patients aged 3 and older and requiring height/length and weight documentation for patients of all ages.
  • In FY2013 the organization can choose to report using these new measures or the current measures. FY2014 and beyond requires the new measure for all reporters.
Core Objective 9: Report hospital clinical quality measures to CMS.
  • Rule would remove this objective in FY2013 and beyond.
  • The NPRM revises the definition of a “meaningful EHR user” to incorporate the requirement of submitting clinical quality measures, making this measure redundant.
Core Objective 11: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies, discharge summary, procedures) upon request.
  • Rule would remove this objective in FY2014 and beyond.
  • The Certification Criteria for Electronic Health Record Technology, 2014 Edition, would require EHRs that are no longer certified to this objective.
  •  Objective would be replaced with new objective: Provide patients the ability to view online, download, and transmit information about a hospital admission.
Core Objective 12: Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request.
  •  Rule would remove this objective in FY2014 and beyond.
  •  The Certification Criteria for Electronic Health Record Technology, 2014 Edition, would require EHRs that are no longer certified to this objective.
  •  Objective would be replaced with new objective: Provide patients the ability to view online, download, and transmit information about a hospital admission.
Core Objective 13: Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
  •  Rule would remove this objective in FY2013 and beyond.
  •  Objective would be met through the new objective: The eligible hospital or CAH who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide summary care record for each transition of care or referral.
Menu Objective 8: Capability to submit electronic data to immunization registries or immunization information systems and actual submission according to applicable law and practice.
  •  The text “except where prohibited” would be added in FY2013 and beyond.
  •  This change is designed to encourage all eligible hospitals and CAHs to submit electronic immunization data, even when not required by State/local law. Therefore, if they are authorized to do so, they should do so even if it is not required by either law or practice.
Menu Objective 9: Capability to submit electronic data on reportable (as required by State or local law) lab results to public health agencies and actual submission according to applicable law and practice.
  •  The text “except where prohibited” would be added in FY2013 and beyond.
  •  This change is designed to encourage all eligible hospitals and CAHs to submit electronic immunization data, even when not required by State/local law. Therefore, if they are authorized to do so, they should do so even if it is not required by either law or practice.
Menu Objective 10: Capability to submit electronic syndromic surveillance data to public health agencies and actual submission according to applicable law and practice.
  •  The text “except where prohibited” would be added in FY2013 and beyond.
  •  This change is designed to encourage all eligible hospitals and CAHs to submit electronic immunization data, even when not required by State/local law. Therefore, if they are authorized to do so, they should do so even if it is not required by either law or practice.
Clinical Quality Measures (CQMs): The changes to CQM reporting apply to both Stage 1 and Stage 2 reporters. The NPRM would increase the reporting from 15 CQMs to 24 CQMs, with at least one measure from each of the following 6 domains: (A) Patient and Family Engagement; (B) Patient Safety; (C) Care Coordination; (D) Population and Public Health; (E) Efficient Use of Healthcare Resources; (F) Clinical Process/Effectiveness.
Recall that differences between the NPRM for Meaningful Use Stage 1 and the Final Rule were sometimes significant. Similar public comment will guide CMS’s modification of the Stage 2 NPRM when creating the final rule. Bearing that in mind, the Centers for Medicare & Medicaid Services (CMS) writes the rules and, as such, is the most significant bellwether of what to expect in the Final Rule.
Talk with your organization’s Meaningful Use team and your software vendors to get a sense of how significant the proposed changes would be. If you’re still in the process of getting ready for Stage 1 attestation, consider implementing those changes in the NPRM that are broader than the current measures (e.g., documentation of height/length and weight for all patients). Remember to ensure that you can report on the numerator and denominator of both measures, especially if you plan to attest in FY2012.
More on MU Stage 2 from Beacon Partners
Beacon Partners welcomes these proposals as a major step forward and is excited to begin working with the provider community to help make these concepts a reality.

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