Meaningful Use Stage 2, he said, will expand on Stage 1 by making the current "menu" set part of future core requirements. Trenkle, director of the CMS Office of e-Health Standards and Services, said the organization also wanted to get certain administrative requirements -- which were included in the NPRM but dropped from the final regulation- along higher CPOE levels, into Stage 2.
"We would also like to look at higher thresholds for other measures," he said. "That is our intent, and it will be framed by feedback and recommendations that come from the Policy Committee."
The administrative measures were dropped from Stage 1 after CMS learned many providers were using older practice management systems which vendors had no intention of certifying. If CMS had coupled these systems with EMRs in the regulation, the entire package would have been disqualified for not meeting the legislatively decreed certification requirement.
Regarding Stage 3, CMS has not put much definition around it because the organization desires more feedback. Also, Trenkle says, it is during the Stage 3 years when the Medicare and Medicaid programs strongly diverge. Medicaid, for example, has no penalties and payments can be made into 2021, while Medicare payments stop in 2016 and penalties are instituted in 2015. "So those are big changes that require us to think about how we will handle the rulemaking," he said.
Further "signaling" can be found in CMS's description of what it "will" or "should" do. However, interested parties should not get too wrapped up in such hints.
"All of those are signals that we plan to move in a particular direction, but if we go into rulemaking and get strong comments against them, or we see the infrastructure is not advancing, those indications are not binding because they are not contained in regulation language," said Trenkle. "However, it does signal our strong intent to move in that direction. Obviously in two years things can change."
As he took questions from Policy Committee members about the final regulations, some wondering why a certain area had not been address more comprehensively, Trenkle emphasized both the complexity of devising the program, and the fact that Meaningful Use is not the only means government has to effect changes in healthcare.
Specifically, Trenkle noted that not only did the Meaningful Use programs managed by Medicare (federal) and Medicaid (states) have to jive, but both had to work within the overall context of HITECH (certification and Meaningful Use) and other government mandates (HIPAA 5010 and ICD-10).
In terms of other program effecting change, he cited the Accountable Care Act and PQRI programs. "There are a number of areas where we have influence to ensure the quality of care is improving," said Trenkle. "One of the important things here is not to get too caught up with what's in Meaningful Use without recognizing it's one of many quality-improvement programs out there. They all need to be look at as integrated and coordinated."
In terms of managing expectations, he also cautioned expecting too much too fast from Meaningful Use. As an example, Trenkle noted the occasional disconnect between perception and reality around e-prescribing. In that sphere, often infrastructure and network limitations stand in the way of full deployment, despite the best of intentions.
As for managing Stage 1 of the Meaningful Use program, Trenkle said there is currently "major operational activity" at CMS. "We have a governance board with an operations board that is looking very closely over our systems and other things that need to be met over the next months so the program goes up in time." That operational activity includes creating program linkages between the federal government and states.
Added Trenkle, "Although the regulation work is finished, we have other work that we are spending our days and nights on."
Anthony Guerra is the founder and editor of