1. Meaningful Use Stage 2 Proposed Rule
AAMC comment letter:
AAMC Contacts:
Ivy Baer:
Lori Mihalich-Levin:
Jennifer Faerberg:
Mary Wheatley:
Scott Wetzel:

2. Stage 2 Decision Tree: Medicare
INCENTIVE! (CMS)!
YES
Have you attested to EP quality measures (CMS)?
YES NO
Have you attested to core & menu measures of meaningful use (CMS)?
YES NO
Are you using certified EHR technology (ONC)?
YES NO
2015: Unless are hospital-based or meet an exception, penalty begins
Are you a non-hospital based EP? (CMS) NO
YES
NO: $0; no penalty
Are you an eligible professional (EP)?

3. Stages of Meaningful Use By Payment Year
First Payment Year
Payment Year
2011
2012
2013
2014
2015
2016
2017
Stage 1
Stage 2
Stage 3
Stage 2
Source: Federal Register, Table 2 (March 7, 2012 p )

4. Stage 1 Stage 2 EPs 15 core 3 of 5 menu 20 total objectives
5 or 10 menu
20 total objectives
EPs
17 core
3 of 5 menu
20 total objectives
Hospitals/CAHs
14 core
15 of 10 menu
19 total objectives
Hospitals/CAHs
16 core
2 of 4 menu
18 total objectives

5. Stage 1 Menu Moved to Proposed Stage 2 Core
Implement drug-formulary checks Record existence of advance directives (core for EH only) Incorporate lab results as structured data (only where results are available) Generate pt lists for specific conditions Send pt reminders Summary of care record Submit reportable lab data (core for EH only) Submit syndromic surveillance data

6. New Measures – ProposedEP EH
30% visits have at least 1 electronic EP note 
30% of EH pt days have at least one e-note by MD, NP or PA
30% of EH med orders automatically tracked via electronic med admin recording
80% of pts offered ability to view and download via web-based portal w/in 36 hrs of discharge relevant info in the record
Online secure pt messaging in use
Pt preferences for communication medium recorded for 20% of pts
List of care team members (including PCP) available for 10% of pts in EHR
Record of longitudinal care plan for 20% of pts with high priority health conditions

7. Major Clinical Quality Measure (CQM) Changes (EPs and Hospitals)
Through 2013 –
Report 3 core/alternate core + 3 measures (EPs)
Attest to results or EHR-PQRS pilot submission (EPs)
Continue to report 15 CQMs finalized in Stage 1 (Hospitals)
Changes in 2014 –
Criteria for CQM same for all stages (EPs)
3 options for reporting, including group reporting (EPs)
Electronic submission (EPs)
Report 24 out of 49 (proposed) CQMs (Hospitals)
Must have at least one measure in each of the six quality domains (Hospitals)
Ability to pick the measures most relevant to their patient population or services offered (Hospitals)

8. 2014 CQM - 3 Options for EPs
1a) 12 measures/ 6 domains
At least one measure in each of the 6 domains
125 measures
1b) 11 “core” plus 1 measure
11 core measures listed
One additional measure
2) PQRS-EHR
Follows rules for PQRS-EHR submission
Could change in future rule-making
Group Reporting
>=2 NPI per Tax ID Number
ACOs*
GPRO* OR
* Option only available for Medicare EHR Incentive
CMS will finalize either option 1a or 1b.

9. Group Reporting - CQM Three possible methods
2 or more NPIs within single TIN
ACO
GPRO
Group options available for:
CQM reporting only AND
All EPs in the group are beyond the first year of Stage 1
Data must be reported from Certified EHR Technology

10. Penalties- EPs
In general, a penalty will be based on data from 2 years prior to the penalty. (Exception: EPs can apply up to Oct of the previous year if it is their first year of MU)
Determining 2015 penalty:
1% percent reduction based on 2013 reporting period (for most EPs)
Can report until Oct 2014 if first year reporting
Additional 1% reduction if not an e-prescriber in 2014

11. To avoid penalties, do what by when? (Hospitals)
To Avoid Penalties in FY:
Existing Meaningful User:
MU for All of FY 2013
Attest by November 30, 2013
New Meaningful User:
MU for April 3, - June 2, 2014
Attest by July 1, 2014
MU for All of FY 2014
Attest by November 30, 2014
MU for April 3, - June 2, 2015
Attest by July 1, 2015
2015
2016

12. AAMC Concerns/Comments with the Proposed Rule
The requirements and timelines for achieving Meaningful Use Stage 2 are too aggressive.
New attesters should have more time to meet the requirements for Meaningful Use Stage 1.
The core measures in the proposed rule are new and untested and therefore greater flexibility should be provided to hospitals and EPs to report this information.
The proposed CQMs are not market ready and would not lead to better outcomes in patient care. These quality measures should not be incorporated into the pay-for-performance programs without a supplemental process to ensure the validity of the EHR data capture.
A group reporting option for CQMs and meaningful use measures should be implemented.