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Initial reactions to final meaningful-use Stage 2 rules By Robin Raiford, IT Strategy Council, The Advisory Board Company


The uncertainty of meaningful-use (MU) Stage

2 is finally over. Now the work begins. Nearly six months after the release of the proposed rules, CMS and the Office of the National Coordinator released the final MU Stage 2 rules on Aug. 23. The CMS Electronic Health Record (EHR) Incentive Pro- gram and the ONC 2014 Edition final rules reinforce the government’s unswerving commitment to ensuring widespread adoption of Certified EHR Technology (CEHRT), and the rules ease some of the measures of success.

The final rules address several of the concerns the industry expressed in comments on the proposed rules. In particular, they significantly reduce a number of thresholds and provide additional time for hospitals to make mandated upgrades.

But despite more generous measures and deadlines, the technical burden remains largely unchanged. Overall, the final rules give hospitals and vendors the

clarity, direction and confidence they need to continue, and even accelerate, the development of their MU capabilities. They are written to be a helpful step on the industry’s road to success, as opposed to a weapon for punishing its failure.

Our IT Strategy Council is working on a more thor- ough analysis of the rules. In the meantime, I wanted to share a few quick observations about what they mean for providers

A big sigh: Relief on upgrades

CMS is taking some of the heat off getting a new upgrade late next year. While 2014 Edition CEHRT will be required to achieve MU in 2014, the rules allow pro- viders that are beyond the first year of demonstrating meaningful use, for 2014 only, up to an additional nine months to upgrade to 2014 Edition CEHRT. Despite the extra time, hospitals will want to upgrade well in advance of the 2014 deadline (July 1, 2014) to avoid

the last-minute rush for resources. This will allow organizations to test and implement new functionality, adopt new workflows, meet new thresholds and complete the three- month quarter reporting period before Sept. 30, 2014.

Thresholds reduced for several measures The CMS final rule includes some significant reduc- tions in thresholds for compliance. For example, the summary-of-care document at transition dropped to 50 percent from 65 percent (which will be welcomed by the 93 percent of hospitals that have deferred this measure). The eligible hospital e-prescribing threshold in the menu set was reduced to 10 percent from 50 per- cent, and the image results threshold is now 10 percent, down from 40 percent. Also of note, the threshold for patients utilizing view, download and transmit function- ality fell to 5 percent from 10 percent. Taken together, the lower thresholds strike a note of encouragement for organizations attesting for Stage 2. But while many of the thresholds are down, the level of effort to implement the functionality and adopt new workflows remains the same.

Retention of demanding new capabilities The rules hold firm on demanding process and tech- nology requirements for patient engagement and interop- erability beginning in 2014. Another major challenge for hospitals will be providing the ability for at least half of patients to view, download and transmit the visit records within 36 hours of discharge. That means if a patient leaves the ED at 10 p.m. Friday on a holiday weekend, hospital documents related to that visit need to be avail- able online by 10 a.m. on Sunday of the holiday weekend. A fact sheet on CMS’ final rule is available at: tinyurl. com/8gwz68h. Reach Robin Raiford at Learn more at

CMS delays ICD-10 compliance date by one year CLAIMS & CODING

CMS has moved back the compliance date for imple-

menting ICD-10 diagnosis and procedure codes to Oct. 1, 2014, from Oct. 1, 2013. The delay will give organizations

4 October 2012

more time to prepare for the transition to ICD-10 and conduct thorough testing, allowing them to avoid obstacles and save money. You can read the Office of the Federal Register rule change document at:


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