Keep Up-to-Date on ARRA
McKesson Submits Comments to HITPC for Meaningful Use Stage 3
On January 14, McKesson submitted feedback to the Health Information Technology Policy Committee (HITPC) on their Request for Comments for Meaningful Use Stage 3. McKesson provided detailed responses to their proposed objectives and criteria, as well as to their questions on quality measures, and privacy and security. While our comments were specific to the topic, in the accompanying letter to the HITPC, we encouraged the committee to consider five overarching recommendations:
- Provide an adequate implementation timeframe for Meaningful Use Stage 3.
- Refine the scope of recommendations to fit industry readiness.
- Continue to invest in quality measurement alignment, infrastructure and standards
- Limit the scope of recommendations to advance the most critical initiatives.
- Ensure that patient safety remains a high priority and any related requirements are synchronized with Meaningful Use and emerging patient safety initiatives.
McKesson closely monitors progress and participates in the discussion and public rule-making process related to the HITECH provisions in the American Reinvestment and Recovery Act (ARRA). We will continue to keep you updated as these recommendations progress.
Stage 2 Meaningful Use Final Rules Released
The long-awaited final rules for Stage 2 meaningful use requirements for Medicare and Medicaid providers have been released. The Centers for Medicare & Medicaid Services (CMS) released the final rule for the Stage 2 Electronic Health Record Incentive Programs on August 23, and hours later the Office of the National Coordinator for Health IT (ONC) released the complementary 2014 Edition Standards & Certification Criteria final rule.
- CMS - Review the full rule, fact sheet and helpful resources
- ONC – Review the full rule, fact sheet and helpful resources
Review McKesson Comments on Stage 2 Proposed Rules
The Centers for Medicare & Medicaid Services and the Office of the National Coordinator (ONC) posted the Meaningful Use Stage 2 Proposed Rule, and the Standards and Certification Criteria for EHRs (S&CC) on March 7, 2012, and invited public comment by May 7, 2012. The proposed rules establish the requirements for the next stage of meaningful use for the EHR Incentive Programs. Meaningful Use Stage 2 begins in federal FY/CY 2014, which takes effect in October 2013 for eligible hospitals. For eligible providers, the effective date is January 2014.
McKesson gathered a team of experts from across the company to interpret and review the Stage 2 proposed rules in detail. McKesson's comments were submitted to CMS and ONC on May 7. You can review:
- A high-level summary of McKesson's Comments
- McKesson's letter with detailed comments submitted to CMS
- McKesson's letter and detailed comments submitted to the ONC.
CMS Releases Proposed Rules for Stage 2 and Stage 1 Revisions
On February 24, 2012, the Centers for Medicare & Medicaid (CMS) and the Office of the National Coordinator (ONC) released the Meaningful Use Stage 2 Proposed Rule and Standards and Certification Criteria for EHRs (S&CC). The proposed rules establish the requirements for the next stage of meaningful use for the EHR Incentive Programs for eligible hospitals, critical access hospitals and eligible providers. Meaningful Use Stage 2 begins in federal FY14, which takes effect in October 2013 for eligible hospitals. For eligible providers, the effective date is January 2014.
McKesson is reviewing the proposed rules for Meaningful Use Stage 2, which emphasize health information exchange, quality measurement and patient engagement, incorporating many of the Health IT Policy Committee's recommendations from last June. We strongly recommend that you also review them with a view to how they may affect your plan to address Stage 1 and Stage 2 criteria. There are several characteristics of the Stage 2 objectives that you may want to note:
- Stage 1 Menu objectives go to Core for Stage 2, with increased values.
- A few Stage 1 objectives were clarified or changed.
- New objectives added mainly target the exchange of patient data.
- Payment adjustments are made for early attestation (to avoid penalties).
You can review McKesson's high-level summary of the Stage 2 proposed rules and proposed revisions to Stage 1 criteria that you'll want to carefully note if you attest beyond federal fiscal year 2012.
Stage 1 Final Rules
In July 2010, the Department of Health and Human Services (HHS) published the stage 1 final rules for meaningful use and certification standards of EHR systems. The rules establish the requirements for eligible hospitals and providers to qualify for Medicare and Medicaid incentives for meaningful use of certified EHRs. In February 2012, Stage 1 revisions were submitted with the Stage 2 proposed rules. Note that the CMS proposed rules for Stage 2 also include proposed Stage 1 revisions.
Learn more by reading the New England Journal of Medicine perspective article, The "Meaningful Use" Regulation for Electronic Health Records, by David Blumenthal, M.D., M.P.P., and Marilyn Tavenner, R.N., M.H.A.
Eligible hospitals and providers have the flexibility to achieve meaningful use by taking different paths to implementing an EHR based on their needs and priorities, which is critical to adoption. McKesson believes the changes to the final rules position more healthcare providers to be able to participate in the program in a timely manner.
The final meaningful use rules (which apply to healthcare providers) reflect the real-world perspective and changes requested in industry and public comments. Key changes from the proposed rules include:
- Two categories of requirements are established (Core and Menu):
- The 15 Core set of objectives are not optional, and the specified measurement for each objective must be achieved.
- The Menu set of objectives allows eligible hospitals and physicians to select five of the 10 objectives based on their current stage of EHR implementation.
- Achievement levels of many of the objectives were reduced.
- Administrative and financial objectives (electronic claims submission and eligibility checking) have been deferred to Stage 2.
- The proposed meaningful use rule limited all process and measurements to the inpatient setting (Point of Service Code 21). The final rule includes the Emergency Department for process and measurements (Point of Service Code 23) for eligible hospitals.
Other notable changes to the final vs. previously proposed meaningful use objectives:
- For computerized provider order entry (CPOE), 30% of patients must have at least one medication order entered via CPOE (previously proposed for 10% of all clinical orders).
- Security and Privacy requirements call for a security risk analysis, implementation of security updates and deficiency correction.
- For e-prescribing, 40% of all permissible prescriptions written by an ambulatory physician must be transmitted electronically (reduced from 75%).
- One clinical decision support rule must be implemented (five previously proposed).
- Information exchange now required for quality measures reporting.
- Providers must be able to electronically exchange key clinical information among providers (pass at least one test transaction).
- Incorporate lab results as structured data (at 40% level).
- Generate lists of patients by specific conditions (at least one condition).
- Provide patients with an electronic copy of their health information upon request for more than 50% of all patients within 3 business days (previously proposed for 80% within 48 hours).
- Provide clinical summaries to patients for more than 50% of all offices visits within 3 business days (reduced from 80%).
- New: Use the EHR to identify patient-specific education resources (10% level).
- New: Record advance directives for patients over 65 (for more than 50% of patients).
- Perform medication reconciliation between care settings (for more than 50% of transitions of care).
Clarifying the Final Rules
While the healthcare industry now has final rules for both meaningful use and certification, some questions still remain. Eligible hospitals and eligible professionals should visit the official CMS website for the Medicare and Medicaid EHR Incentive Program for FAQs related to meaningful use. You should also check with your stimulus governance team or legal counsel to address questions specific to your organization and qualifying for incentive payments.
Additionally, you may be interested in reviewing:
Providers should confirm their roadmaps and finalize the needed work to achieve meaningful use. McKesson has been actively moving our EHR systems toward having the capabilities our customers need to achieve the meaningful use objectives. We are committed to supporting your efforts to achieve meaningful use.
McKesson Using CCHIT and Drummond to Certify its EHRs
To earn stimulus incentives, physicians and hospitals must demonstrate meaningful use of a certified electronic health record (EHR) solution. Certification under the Department of Health & Human Services (HHS) approved process will signify that an EHR has the capabilities needed to support hospitals and physicians in their efforts to achieve meaningful use. To date, six Authorized Testing and Certification Bodies (ATCBs) have been named by the Office of the National Coordinator (ONC) under the temporary certification program:
- Certification Commission for Health Information Technology (CCHIT)
- Drummond Group, Inc.
- InfoGard Laboratories, Inc.
- Surescripts LLC
- ICSA Labs
- SLI Global Solutions
Certification by an ONC-ATCB carries the same weight regardless of the certifying body since all ATCBs must follow the same processes and test scripts.
McKesson's priority is to support our customers' efforts to achieve meaningful use and certify our EHR solutions under the ONC-ATCB program. We have several certified EHR soltuions. To verify if a McKesson product is certified, please visit the ONC's Certified HIT Product List (CHPL) for a full listing of certified solutions.