Many of the Stage 2 requirements of the EHR Incentive Programs build off Stage 1. But past experience doesn’t necessarily mean physicians will have an easier time.
CMS recently released the final rule for Stage 2 of the Medicare/Medicaid EHR Incentive Programs. But while many of the requirements build off the Stage 1 requirements, past experience doesn’t necessarily mean physicians will have an easier time participating in Stage 2 when it begins in 2014.
“It would be risky [for physicians] to think of Stage 2 as an ‘incremental step’ above Stage 1,” Laura Kreofsky, principal of healthcare technology consulting firm Impact Advisors, LLC, told Physicians Practice. “The changes are significant and complex and will require a great deal of technology change, robust reporting capabilities, and work flow and policy evaluation and modification. Providers and organizations should anticipate a comparable, if not greater, level of effort - to achieve Stage 2 as was used to achieve Stage 1.”
Many of the Stage 2 requirements reflect Stage 1 requirements, just with higher percentage thresholds required. In addition, many of the Stage 1 menu set measures become core measures in Stage 2.
But there are also new challenging requirements, such as those related to patient engagement.
For instance, more than 5 percent of unique patients seen by the physician during the reporting period must use the electronic messaging function of the EHR to send a secure message; and more than 10 percent of all unique patients who have an office visit within 24 months prior to the start of the reporting period must be sent a reminder.
“Even things like sending reminders out to patients are not particularly mainstream yet,” said Kreofsky.
In addition, many of the objectives have two or three separate components built within them, she said, citing the objective related to providing patients with online access to health information.
The first piece of this requirement is that 50 percent of all unique patients must have access to their health information within four business days of it being available to the physician. The second piece is that more than 5 percent of all unique patients seen by the physician must view, download, or transmit their information to a third party.
“The level of effort for [physicians] to prepare for Stage 2 is twice, if not three times what it took to get ready for Stage 1, and a lot of this has to come down to the multivariate and multi-attribute measures and requirements,” said Kreofsky.
Still, other experts said the experience physicians gained as part of Stage 1 participation should not be discounted when gauging the difficulty of Stage 2.
“For those physicians who have already embraced Stage 1, this will be a natural progression of their EMR/EHR experience,” pediatric physical medicine and rehabilitation specialist Chuck Dietzen, chief medical officer at iSalus Healthcare, told Physicians Practice via e-mail. “I think the greater challenge was to ‘get started’ towards Stage 1 … in other words, selecting a vendor, ensuring their hardware and network configuration was intact, training and implementation, data input, or importation.”
Still he acknowledged, some physicians may struggle more than others. “...If they had a bad experience with their software implementation towards Stage 1 - this will undoubtedly ... be more fuel to the fire,” he said.
What also might make matters worse is that some of the “homegrown” or small vendor EHRs will have a difficult time complying with the Stage 2 certification standards, said Kreofsky.
These vendors “may be challenged to fully understand the tech requirements … in the context of increasingly complex workflows,” she said. In addition, they may have difficulty building them in a manner that meets ONC certification requirements and in a way that they remain user-friendly to physicians and staff members.
“That may just drive a host of system replacement - [physicians] may just come to a point that they can’t achieve what they want to achieve for Stage 2 on a homegrown system,” she said.
For those physicians, who need to start Stage 2 on a new EHR, “It certainly wouldn’t be starting from a ‘ground zero,’ but they’d have to hit the ground running - and that’s just frustrating,” said Kreofsky.
What do you think will be the most challenging aspect of Stage 2?