Meaningful Use Stage 2 Final Rule Released

August 31, 2012

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The Centers for Medicare and Medicaid Services (CMS) released the Stage 2 requirements for its Electronic Health Record (EHR) Incentive Programs last week. Stage 2 of Meaningful Use will begin in 2014. The Final Rule was released after reviewing extensive comments the AAN submitted on the Stage 2 Proposed Rule in May, along with comments from other professional organizations, hospitals and eligible providers, and EHR vendors.

In the first year of participation, eligible professionals must demonstrate meaningful use of their EHR for a 90-day reporting period and for a full calendar year each subsequent year.  However, CMS has finalized that for 2014 only, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a 90-day reporting period. This is to align with existing CMS quality measurement programs such as the Physician Quality Reporting System (PQRS) and to ensure providers who must upgrade their 2014 Certified EHR Technology have adequate time for implementation.  

Click here to access the CMS Stage 2 Overview.

Core and Menu Measures
In Stage 2, physicians are required to meet 17 core measures and an additional 3 measures selected from a menu set of six measures. In comparison to Stage 1, nearly all core and menu measures are included in Stage 2, as well as many Stage 1 measures being combined under Stage 2. Click here to see a comparison of the Stage 1 and Stage 2 objectives.

Clinical Quality Measures
Beginning in 2014, eligible professionals must report on a total of 9 Clinical Quality Measures (CQMs) from at least 3 National Quality Strategy domains, selecting from a list of 64 CQMs across 6 domains. Alternatively, eligible professionals can satisfy the CQM reporting component of Meaningful Use if they satisfactorily report CQMs under the PQRS-EHR Reporting Option. Reporting periods under the PQRS-EHR Reporting Option are subject to the PQRS program of one calendar year. Those who are in their first year of participation will need to submit their CQMs through the attestation process. For more information on the 2014 CQMs, click here.

Medicare EHR Incentive Program Penalty Phase
A penalty of 1.0% will begin being assessed on January 1, 2015 for those who are not successful in the Medicare EHR Incentive Program, and continue to increase in subsequent years.

  • If you were successful in the Medicare EHR Incentive Program in 2011 or 2012, you must successfully meet the requirements for the full 2013 CY to avoid the 2015 penalty
  • If you are successful in the Medicare EHR Incentive Program in 2013, you must successfully meet the requirements for a 90-day reporting period in 2013 to avoid the 2015 penalty
  • If you begin the Medicare EHR Incentive Program in 2014, you must successfully meet the requirements for a 90-day reporting period in 2014 within the first 9 months of the 2014 CY AND attest no later than October 1, 2014, to avoid the 2015 penalty

For more information on the future payment adjustments, click here.

Hardship Exemptions
The following hardship exemptions have been finalized in the Stage 2 Final Rule:

  • Infrastructure: Eligible professionals must demonstrate lack of availability of internet access or barriers to obtaining IT infrastructure (ex. Lack of broadband)
  • New Eligible Professionals: Newly practicing physicians can apply for a 2-year limited exception from penalties (ex. Physicians who begin practicing in CY 2015 would apply for an exemption for 2015 and 2016, but must comply by 2017)
  • Unforeseen Circumstances: Natural disaster or other unforeseeable circumstances
  • By Specialist/Provider Type: An eligible professional who meets all of the following three criteria
    • Lack of face-to-face or telemedicine interaction with patients
    • Lack of follow-up need with patients
    • Lack of control over Certified EHR Technology availability at their practice

For more information on the hardship exemptions, click here.

Physicians who do not meet the eligibility requirements due to performing 90-percent or more of covered professional services in the inpatient or emergency department of the hospital are considered exempt. However, if eligibility status changes the physician may be subject to penalties in the relevant year, so CMS has advised physicians to check their hospital-based status on the Medicare EHR Incentive Programs Registration System page at https://ehrincentives.cms.gov/.

The AAN will continue providing its members with up-to-date information and assistance in preparing for Stage 2 of Meaningful Use.  For more information, visit www.aan.com/go/practice/pay/ehr.