By Michele Judge
With the first round of attestation for the Medicare and Medicaid EHR Incentive Program out of the way, healthcare providers are looking toward the next phase that commences in 2014. As expected, the second stage of MU will greet them with stricter documentation requirements. Rather than being dismayed, eligible professionals (EPs) and hospitals should utilize lessons learned in Stage 1 to prepare for a successful Stage 2 attestation.
To review, providers and hospitals will be required to report on more core objectives than in Stage 1. EPs will now attest to 20 total items, including 17 core objectives and three (of six) menu objectives. But as the industry found out from Stage 1, attestation is not straightforward. Reporting requirements are different for certain patient populations, which is the essence of numerators, denominators, thresholds and exclusions. This aspect proved to be among the most confusing for providers.
To help clarify, objectives requiring a numerator and denominator are divided into two groups:
In the first group, the denominator is based on patients seen or admitted during the 90-day EHR reporting period, regardless of whether their records are maintained using certified EMR technology.
The second group of objectives consists of those that are not relevant to all patients. In this case, the denominator is based on actions related to individuals whose records are maintained using certified EMR technology. More information can be found in guides such as this one provided by CMS.
But it’s not only the complex rules that promise to trip up providers in Stage 2. Meeting the increased documentation requirements for radiology and laboratory orders in particular have many wondering if they will attest successfully. The reason? Up until now, the focus for EMR developers has been on usability and meeting Stage 1 requirements. Radiology and lab order documentation has not previously been a priority.
Providers must use 2013 to become familiar with their EMR’s radiology and lab modules. If they determine that limitations in the software will jeopardize their MU compliance chances, they can suggest that their vendors deliver a more functional solution. Physicians can also consider implementing third-party stand-alone technology or a module that can be embedded within their current EMR. Many products, such as Emdeon’s lab orders and results software, are Web based, greatly easing implementation.
Perhaps the greatest bit of advice for the provider community, however, is not to procrastinate. Many physicians waited until the last three months of the year to collect their data, only to find that they failed to meet core and menu set objectives. Rather than risk missing out on MU’s economic windfall, providers should choose a 90-day period early in the year for attestation, leaving ample time to adjust their data if they do not initially meet the appropriate criteria. Providers should also consider using CMS’ calculator at http://www.cms.gov/apps/ehr/, to test whether or not they would successfully demonstrate Meaningful Use.
With adequate foresight and planning, healthcare providers will greatly increase their chances for MU success. Companies like Emdeon are great resources, providing insights and continuously guiding physicians through the complex maze that is Meaningful Use.
Michele Judge is Senior Director of Clinical Services at Emdeon. She has over 20 years of experience in managing, deploying and developing computerized physician order entry solutions for laboratories, hospitals and pharmacies.
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Meaningful Use Stage 2: It’s Not too Early to Prepare for Attestation
