Proposed Stage 2 MU Criteria May Be Too Difficult for Hospitals, Providers, Groups Say

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Industry Comments on Proposed Stage 2 Meaningful Use Criteria  


Key Take Away:Proposed Stage 2 criteria may be too difficult for hospitals and providers to achieve.

Recommendations:CMS should change the Stage 2 time frame, simplify Stage 2 objectives, and align clinical quality measures to make the criteria feasible.

By Genevieve Douglas  

Elements of proposed “meaningful use” criteria for Stage 2 of the Medicare and Medicaid electronic health record incentive programs could be too difficult for hospitals, the American Hospital Association said in comments submitted May 1 to the Centers for Medicare & Medicaid Services.

According to a letter from the association, the Stage 2 objectives to achieve meaningful use of EHRs could “stand in the way of a successful program to support widespread adoption by all hospitals” of EHR systems.

AHA expressed “major concerns” with parts of the proposed criteria related to:

• implementation of the Medicare penalty phase;

• proposed timing and staging of the next phase of the incentive program;

• specific objectives and measures for Stage 2; and

• reporting of clinical quality measures through EHRs.

Many of the proposals for Stage 2 of the program “put regulatory requirements ahead of actual experience with these technologies,” an approach that would likely be a barrier to adoption, AHA said.

AHA and the College of Healthcare Information Management Executives (CHIME) recommended that CMS establish a 90-day reporting period for Stage 2 that mirrors the reporting period for Stage 1 of the EHR incentive programs.

AHA also recommended that each stage of the meaningful use programs last three years to ensure vendors and providers have adequate time to transition safely and without “undue distortions to the market.”

“We felt the approach taken in Stage 1 gave providers much-needed time to make sure the correct fields were populating and accurate meaningful use reports were being produced--we think a similar approach is needed for Stage 2 and beyond,” Pam McNutt, CHIME member and senior vice president and chief information officer at Dallas-based Methodist health System, said in a release.


“We felt the approach taken in Stage 1 gave providers much-needed time to make sure the correct fields were populating and accurate meaningful use reports were being produced--we think a similar approach is needed for Stage 2 and beyond.”  



-Pam McNutt, CHIME

CMS released the proposed Stage 2 meaningful use criteria Feb. 23, and they were published in the March 7 Federal Register (77 Fed. Reg. 13,698, March 7, 2012)(see previous article). The AHA and CHIME letters were sent as public comments on the proposed rule. The public comment deadline is May 7.

Making Objectives Achievable.

According to AHA, taken as a whole, the proposed requirements for meeting Stage 2 “raise the bar too high” and are not feasible for the majority of hospitals to achieve.

AHA recommended that CMS make Stage 2 objectives more feasible and less burdensome for both hospitals and eligible professionals by:

• preserving the existing approach of a core (mandatory) set of required objectives accompanied by a menu (optional) set with limited choice among objectives;

• introducing all new objectives through the menu set;

• moving menu items to the core at the same performance threshold set in Stage 1; and

• removing measures that make the performance of hospitals and eligible professionals contingent on the actions of others.

For example, proposed criteria that rely on patient-initiated access of their health data are not feasible as proposed, raise significant security issues, and go beyond current technical capacity, according to the comments.

Comments from CHIME urged CMS to expand the menu set options for the proposed Stage 2 criteria, so that eligible professionals and hospitals have flexibility in achieving meaningful use of EHRs.

“The menu set for both EPs and hospitals is quite small in relation to the minimum number that would need to be met, thereby providing relatively few options for EPs and hospitals,” CHIME said.

Clinical Quality Measures.

Overall, CHIME said the accurate reporting of clinical quality measures was one of the “the most daunting challenges faced by providers today.”

While EHR products have the ability to automatically produce CQM reports, the data are often inaccurate and cannot be shared across different providers or care settings, according to the comments.

In comments to the Office of the National Coordinator for Health Information Technology on standards and certification criteria for 2014, CHIME recommended that part of the EHR certification process include certification of all CQMs needed to meet meaningful use in each care setting.

Additionally, CHIME offered to work with ONC to minimize the costs of development and implementation by limiting the total number of CQMs associated with each care setting.

ONC published a companion proposal in the March 7 Federal Register (77 Fed. Reg. 13,832, March 7, 2012) outlining the EHR standards, certification criteria, and implementation specifications needed to participate in the incentive programs starting in 2014 (see previous article).

In its letter to CMS, AHA “strongly urged” the agency to defer adding new hospital clinical quality measures to the meaningful use program until Stage 3, so that Stage 2 could be used to make the process accurate and aligned across multiple federal quality improvement programs.

The AHA comments are available at

The CHIME comments to CMS are available at

The CHIME comments to ONC are available at

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