Unlike Stage 1, in which EPs must fulfill only 15 core objectives, Stage 2 requires providers to fulfill 17 core objectives, many of which are Stage 1 objectives with higher margins.
For example, EPs are required to record smoking status for more than 80 percent of all unique patients ages 13 and older in Stage 2, up from 50 percent in Stage 1.
Providers must also meet three of six "menu set" objectives, a list that includes items like "record patient family health history," as well as "identify and report cancer cases to a state cancer registry."
If the core and menu set objectives aren't enough of a meal to chew on, in the Stage 2 final rule CMS introduced new clinical quality measures (CQMs) demonstrating its goal for providers to align more closely with preexisting national quality programs, such as the Medicare Shared Savings Program. In 2014, EPs must submit nine CQMs from at least three of the National Quality Strategy domains out of a potential list of 64 CQMs across six domains published in the Stage 2 final rule. Prior to 2014, EPs are required to report on three core CQMs (or three alternate CQMs) from a table of 44, plus three additional CQMs, from a set of 38.
While some objectives, such as those related to collecting demographics, will be easy to do, experts agree that practices will need to pay particular attention to the following:
• Data-transmission requirements. There's a requirement that "the EP who transitions or refers their patient to another setting of care or provider of care provides a summary of care record" either electronically to a recipient using a certified EHR or via exchange facilitated by an ONC-established governance mechanism or NwHIN Exchange for 10 percent of transmissions and referrals. (For tips, read: How to Meet CMS' Data-Transmission Requirements).
• Patient-engagement requirements. These include a requirement for EPs to "provide patients the ability to view online, download, and transmit their health information within four business days of the information being available to the EP (for more than 50 percent of patients)," as well as a requirement to communicate using secure electronic messaging with more than 5 percent of patients (for tips, read: How to Get Patients Engaged).
To do: Review your attestation history
To figure out where you stand in regard to Stage 2 readiness, Jeff Loughlin, project director with the Massachusetts eHealth Collaborative, which oversees the REC for New Hampshire, suggests printing out a copy of your EHR's dashboard reports to see how far off (or close) you are to meeting certain thresholds. Weaknesses, such as e-prescribing for only 20 percent of patients when the threshold is 40 percent, will be easy to spot right away. Increasing your percentage may mean fixing data-collection processes — and ultimately the work flow — at your practice.
"The biggest things a practice needs to prepare for is to really take a hard look at their work flow, and how they are operating at the practice, and look at who is collecting the data," says Loughlin. "So with e-prescribing, that [process] might need to be re-engineered to start at the front desk, so staff will ask patients, 'What is your pharmacy? Where are you going to regularly?' and make sure that pharmacy is e-prescribing enabled." If it isn't, that could prompt the front-desk staff to suggest an alternative pharmacy that uses e-prescribing, he says.
To do: Talk to your vendor
Your best intentions to meet Stage 2 requirements are useless without cooperation from your EHR vendor: The final rule for the second stage outlines requirements that EHRs all conform to certain technology standards. In other words, if your EHR is not certified for Stage 2, you will not be able to attest.