The feds seem to have learned from the problems they created with stage 1 criteria. Now they're doing their due diligence.
Although the requirements for Meaningful Use (MU) stage 2 will in some respects pose more of a challenge for healthcare providers than stage 1 regs, I suspect the process will go more smoothly, especially for those who've already completed stage 1 compliance.
That's because the feds are taking more time and care ironing out the details that will be included in MU stage 2, which is expected to be finalized next spring.
Another reason it will probably be easier for many is because earlybird healthcare providers who achieved MU stage 1 compliance in 2011 will get the reward of extra time to work on their stage 2 compliance. Originally, healthcare providers achieving stage 1 compliance in 2011 had until fiscal 2013 to attest to stage 2 compliance.
But in July, the Office of National Coordinator (ONC) for Health IT said it would defer the deadline for stage 2 compliance until 2014 for hospitals and providers who attest to stage 1 compliance for the first time in 2011. For those healthcare providers waiting till 2012 to attest to stage 1 compliance, the deadline is also 2014 for stage 2 compliance--but that still makes their window smaller.
Regardless of whether you're an earlybird or not, stage 2 will likely be smoother than stage 1 because the criteria will be better thought out. "Quality measures in stage 1 were heinous," said John Halamka, CIO at Beth Israel Deaconess Medical Center (BIDMC) and co-chair of the Health IT Standards Committee that advises ONC. Many of the measures that healthcare providers were expected to take for stage 1 compliance "didn't necessarily make sense" for many of them, he said during a session at the Healthcare IT Solutions Exchange (HITSE) conference in Dedham, Mass, this week.
For instance, many hospitals--including BIDMC--that have already attested to stage 1 found that none of their patients had requested electronic copies of their discharge instructions at the time of discharge. However, providing such electronic copies to 50% of patients who request the discharge instructions is among the core measures for stage 1 compliance. Halamka suspects this measure might have come too soon. Moving ahead, more patients will be aware that this information is available to them, he said.
Timing will also be different for stage 2. Because of deadlines set in the HITECH Act, healthcare providers only had a few months notice of the requirements before the timer was set for compliance in 2011, the first year for which healthcare providers could attest and receive their incentive money from the Centers of Medicare and Medicaid Services (CMS).
But not so this time around. "Stage 1 was put together quickly, stage 2 is not being rushed," Halamka said. In fact, before the final requirements for stage 2 are finalized, the feds will have some healthcare providers "pilot" the various criteria, testing whether the proposed quality measures make sense for healthcare providers, according to Halamka. "There will be cleaner measures in stage 2."
While stage 2 details are still being hammered out, it's expected that data exchange requirements will be among the mandates amped up. And some healthcare providers are already prepping.
For instance, Beaufort Memorial Hospital, a 197-bed acute care hospital in Beaufort, S.C., has saved $75,000 so far since March 2011 by implementing Summit Express Connect, an interface engine technology from vendor Summit Healthcare Services. The savings have come in part by reducing the number of interfaces that Beaufort needed to develop or deploy to have data exchanged between its various applications and the EHRs and other electronic ordering systems used by doctors in the community, according to Beaufort CIO Ed Ricks.
Summit Express Connect is helping Beaufort report immunizations to public health agencies and exchange data bidirectionally with physician offices. It will also be key in Beaufort's participation in a state health information exchange, said Ricks during a session at HITSE.
Beaufort attested to stage 1 MU in October and Ricks is confident that the Summit technology, along with the other work the hospital has been doing, will put Beaufort in a good position for achieving stage 2 compliance. "Once you can abstract the required data, we feel we can exchange it," he said.
"There's pushback on some of the new criteria," she said. "There are no standards yet" for some aspects of stage 2, such as a proposal for providing patients electronic access to their longitudinal medical records, she said. "What's a longitudinal record--is it from the day you were born, and what goes into a longitudinal care plan?" she asked. Those are among the specifics not yet defined, she said.
But Halamka points out a lack of specificity in some criteria may actually be a good thing, giving healthcare providers more opportunities to innovate and implement technologies that work best for their organizations.
For instance, without specificity on medication safety, some healthcare providers might opt to use barcode or RFID technologies when checking that the right patient is receiving the right drug and dose at the right time, while others might want to deploy digital cameras "with facial recognition of patients," he said.
"There are all kinds of ways you can do this," said Halamka.