Meaningful Use

On July 13, 2010 the US Department of Health and Human Services released the final rules for the EHR Incentive Programs including the Stage 1 Meaningful Use criteria. The full rule can be found here and additional information from HHS is available here. The New England Journal of Medicine has a summary available here. Michigan did not modify the Stage 1 meaningful use requirements from the federal requirements. The September 4, 2012 Stage 2 Final Rule made certain changes to Stage 1 Meaningful Use requirements for 2013 and beyond. Please refer to the CMS tipsheet for Changes to Stage 1 of Meaningful Use.

On September 4 2012, the US Department of Health and Human Services released a final rule that specifies the Stage 2 Meaningful Use criteria. All providers must achieve Meaningful Use under the Stage 1 criteria before moving to Stage 2. The full rule can be found here and additional information from HHS is available here. Michigan did not modify the Stage 2 Meaningful Use requirements from the federal requirements.

Meaningful Use (MU) Adoption, Implementation, Upgrading (AIU) of EHR

In order to receive and continue to receive incentive payments, providers must achieve and maintain a set of Meaningful Use measures as defined by CMS. Meaningful Use employs a three stage approach, with each stage building on the preceding stage.

• Stage 1 - 2011: Data capture and sharing
• Stage 2 - 2014: Expand upon the Stage 1 criteria to encourage the use of health information technology for continuous quality improvement
• Stage 3 - 2016: Expand on Stage 2 with a focus on promoting improved outcomes in quality, safety, and efficiency

Only Stage 1 and Stage 2 are currently defined. To demonstrate Stage 1 and Stage 2 of Meaningful Use, a provider must comply with “core” and “menu” requirements.

Adoption, Implementation, Upgrading (AIU)

Medicaid providers do not have to meet Meaningful Use criteria in their first year of participation. Instead, all first year Eligible Professionals (EPs) are required to attest to adopting, implementing, or upgrading an EHR. However, Meaningful Use criteria must be met in subsequent years.

• Adoption – acquired certified EHR technology (e.g., evidence of purchasing or securing access to certified EHR technology)
• Implementation – began using EHR (e.g., staff training, data entry of patient demographic information on EHR)
• Upgrading – expanded EHR (e.g., upgraded to certified EHR technology or added new functionality to meet MU)

MU Objectives/Measures for Eligible Professionals

CMS has developed objectives and measures for Meaningful Use. Meaningful Use includes both a core set and a menu set of objectives that are specific for eligible professionals (EPs). For EPs, in stage 1 there are a total of 20 Meaningful Use objectives; 15 are core objectives that are required and the remaining 5 objectives may be chosen from the list of 10 menu set objectives and a total of 6 clinical quality measures.

Details on each of the eligible professional Stage 1 Meaningful Use measures and clinical quality measures.

In the Stage 2 Final Rule, CMS modified, removed, and condensed some of the objectives and measures for Stage 1 of Meaningful Use. For program year 2013, there are now only 13 core objectives for Stage 1 and 10 menu set objectives, 5 of which must be met. The 6 clinical quality measures requirement remains in effect for 2013. Please refer to the Changes to Stage 1 of Meaningful Use document and the Eligible Professional’s Guide to the Michigan Medicaid EHR Incentive Program for details on Stage 1 Meaningful Use changes.

CMS has also developed a new framework for Stage 2 Meaningful Use, which begins in 2014. For EPs, in Stage 2 there are a total of 20 Meaningful Use Objectives; 17 are core objectives that are required and the remaining 3 objectives may be chosen from the list of 6 menu set objectives.

Details on each of the eligible professional Stage 2 Meaningful Use measres.

In 2014, EPs in Stage 1 and Stage 2 of Meaningful Use will be required to report 9 Clinical Quality Measures (CQMs) out of a set of 64.

MU Objectives/Measures for Eligible Hospitals

CMS has developed objectives and measures for Meaningful Use. Meaningful Use includes both a core set and a menu set of objectives that are specific for eligible hospitals (EHs). For EHs, in stage 1 there are a total of 19 Meaningful Use objectives; 14 are core objectives that are required and the remaining 5 objectives may be chosen from the list of 10 menu set objectives and a total of 15 clinical quality measures.

Details on each of the eligible hospital core and menu meaningful use measures.

CMS has developed a new framework for Stage 2 Meaningful Use, which begins in 2014. For EHs and critical access hospitals (CAHs), in Stage 2 there are a total of 19 Meaningful Use Objectives; 16 are core objectives that are required and the remaining 3 objectives may be chosen from the list of 6 menu set objectives.

Details on each of the eligible hospital Stage 2 Meaningful Use measres.

In 2014, EHs in Stage 1 and Stage 2 of Meaningful Use will be required to report 16 Clinical Quality Measures (CQMs) out of a set of 29.

MU Reporting Period

The MU reporting period is a continuous period during which the provider successfully demonstrates all the MU objectives of certified technology.

• Providers entering their first year in the program must attest under AIU, and do not have to meet MU requirements. The subsequent year would then be the first Meaningful Use reporting period and is a consecutive 90-day period in that calendar year. Meaningful Use must be met prior to receiving the second payment.
• For all subsequent payment years, the reporting period is the full calendar year. There is one exception for 2014; due to the mandated upgrade to 2014-ONC Certified EHR Technology for participation in the Meaningful Use programs, all EPs, regardless of their stage or year of Meaningful Use, will only have a 3-month (not 90-day) reporting period.

For example, let’s say an eligible professional (EP) registers under AIU in 2011 and receives his or her first-year incentive payment. To receive the second-year payment in 2012, the EP would have to wait at least 90 days after January 1, 2012—in order to demonstrate MU for 90 days (a requirement for the second-year payment)—before re-registering. To receive the third-year payment (nominally, the 2013 payment), the EP would have to demonstrate MU for the entire year (all 12 months in 2013) and then re-register in early 2014. To receive the fourth-year payment (nominally, the 2014 payment), the EP would have to demonstrate MU for any 3-month calendar quarter in 2014 with a 2014-compliant CEHRT. Once this is complete, the EP would re-register prior to the end of the 2014 attestation/registration period (likely in early 2015). In 2015, MU reporting would once again require the EP to report data for the whole year. Of course, the EP can skip years if he or she so desires; this example simply illustrates how an EP could receive incentive payments consecutively.

Medicare Payment Adjustments (Medicare and Medicaid Program Eligible EPs Only)

EPs who are eligible for the Medicare EHR Incentive Program must meet Stage 1 of Meaningful Use in 2013 through either the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program in order to avoid Medicare payment adjustments in 2015. CMS has issued a tipsheet for EPs regarding the timing and amount of these payment adjustments, as well as possible hardship exemptions for these adjustments.