ARRA: Frequently Asked Questions
- What are the core requirements for demonstrating meaningful use?
- What were the HIT Policy Committee's recommendations?
- What is McKesson's overall position in helping its customers achieve meaningful use?
- Can you provide a timeline since the American Recovery and Reinvestment Act was enacted in February 2009?
- What is the latest on Stage 2 of meaningful use?
- What are the focus areas for Stage 2?
- What is the timeline for Stage 2?
- Isn't the timeline too short between the release of the Final Rule from CMS and the requirement that hospitals and physicians be on Stage 2 meaningful use software?
- How is McKesson preparing for Stage 2?
- What authorized testing and certification body (ATCB) does McKesson use to certify its EHRs?
- What is the National Institute of Standards and Technology (NIST) and what role does this organization play in certification?
- Where can I find more information about the ARRA EHR incentive program?
- How is McKesson helping its customers prepare for the move to ICD-10 coding?
- What is the status of the Clinical Quality Measures (CQMs)?
In Stage 1 there are two categories of meaningful use objectives: Core and Menu. The Core objectives are not optional and the specified measure must be achieved. There are:
There are 10 Menu objectives, but providers can select five out of the 10 to demonstrate meaningful use based on their current stage of EHR deployment. Please note: After the publication of the final rule, an FAQ from the Office of the National Coordinator (ONC) notes that eligible hospitals and eligible professionals must possess the technology capabilities for the entire set of Menu objectives—even though they are only required to demonstrate meaningful use against five objectives.
- Delay Stage 2 by one year for eligible hospitals (EH) and eligible physicians (EP) that attest to Stage 1 in either the 2011 federal fiscal year (EH) or the 2011 calendar year (EP).
- Impact: This provides the necessary time between the release of the Stage 2 Final Rules (anticipated late spring/early summer 2012) and the start of Stage 2. Currently, the deadlines for providers that attest in 2011 are Oct. 1, 2012 (CMS FY 2013) for EHs, and Jan. 1, 2013 for EPs.
- Providers starting Stage 1 in 2011 would remain on Stage 1 for three years. The schedule would not change for providers that don't start meaningful use until 2012.
- Although CMS has not yet indicated when it will provide a final ruling on this proposal, Farzad Mostashari, the national coordinator for health information technology, indicated ONC's support for the delay.
- There were no big surprises in the Stage 2 objectives that were presented and approved, based on the meetings McKesson has been following and information to date. Items to note:
- All menu options are now converted to Core.
- There were a few new objectives:
- Under Care Coordination, the new objective regarding a patient care plan has been greatly simplified from earlier discussions. The proposed care plan is now merged with providing a Summary of Care (a Stage 1 objective) and consists of unstructured goals and patient instructions, as well as the care team members.
- The proposed objective for an electronic medication administration record now “implies” the five rights checking and must be implemented in only one unit/ward.
- Under Patient Engagement, many of the proposed objectives require the patient to be able to view and download their information.
- Clinical Quality Measures have not yet been proposed for Stage 2.
McKesson is well-positioned to help customers take advantage of stimulus incentives. We have strong offerings in both hospital and physician markets and connectivity solutions to enable health and other information exchange. Many of our EHR solutions—both complete and modular—have been certified, and we will continue to seek certification of additional solutions as appropriate. Our ability to understand the interactions that take place in this fragmented healthcare system and to create solutions from that knowledge ultimately benefits our customers and their patients.
Can you provide a timeline since the American Recovery and Reinvestment Act was enacted in February 2009?
- Since ARRA became law, the Office of the National Coordinator (ONC), the Centers for Medicaid and Medicare Services (CMS) and other federal agencies have been actively engaged in the rule-making process to put the systems and programs in place for hospitals and physicians to qualify for the incentives.
- In July 2010, the final rules for both meaningful use and temporary certification were published in the Federal Register, giving healthcare providers (meaningful use) and HIT vendors (certification) most of the information they needed to participate in the EHR incentive program.
- In January 2011, the ONC issued the final rule that established the permanent certification program. Eventually, the permanent certification program will replace the temporary certification program, which is expected to sunset on Dec. 31, 2011, or at a later date when all the necessary processes for the permanent program are in place
- In mid-January 2011, the ONC issued a request for comments on proposed Stage 2 meaningful use objectives. McKesson submitted comments to the RFC on Feb 25, 2011.
- In June 2011, The Health Information Technology Policy Committee (HITPC) formally submitted Stage 2 recommendations to the ONC. Quality measure recommendations were not included.
In January, the Office of the National Coordinator (ONC) HIT Policy Committee issued a Request for Comments for potential Stage 2 meaningful use objectives. McKesson was among vendors and associations that submitted comments.
In order to successfully implement meaningful use while maintaining safety, quality and efficiency in patient care, McKesson offered the work group the following recommendations:
- Define a long-term roadmap to guide meaningful use evolution through both Stages 2 and 3
- Extend flexibility for adoption and emphasize achievable objectives
- Provide an adequate time frame for successful implementation
- Harmonize requirements across all Federal programs and accreditation organizations
- Clearly define criteria within the control of providers
- Encourage patient engagement requirements that are within the provider's ability to influence
In June 2011, The Health Information Technology Policy Committee (HITPC) formally submitted Stage 2 recommendations to the ONC. Stage 2 Clinical Quality Measures were not included in these recommendations.
Most of the proposed objectives for Stage 2 in the Request for Comments stem from Stage 1 objectives, increasing the measure percentages that must be met, moving an objective from Menu to Core or adding incremental requirements to the objective.
There are several new objectives in the HIT Policy Committee Stage 2 recommendations, including some proposed Stage 3 objectives. The intent is to alert the industry to potential new EHR functionalities so vendors can get a head start on developing new functionalities.
- Jan. 2011: Request for Comment issued, with a 45-day comment period.
- April 2011: The Meaningful Use Workgroup presented the revised draft of Stage 2 meaningful use criteria to The Health Information Technology Policy Committee (HITPC), after review of all the comments.
- June 2011: HITPC made its final recommendations for Stage 2 to CMS.
- Jan 2012: CMS will issue a Notice of Proposed Rulemaking (NPRM). The Office of the National Coordinator (ONC) will issue an Interim Final Rule (IFR) on Standards and Certification around the same time frame.
- Late spring/early summer 2012: CMS will issue the Final Rule. ONC will issue the Final Rule on Standards and Certification shortly after this.
- Oct. 1, 2012: Hospitals that attested in FY 2011 will begin Stage 2 (CMS fiscal year 2013) as currently planned without the proposed delay.
- Jan. 1, 2013: Physicians who attested in CY 2011 will begin Stage 2 (calendar year 2013) as currently planned without the proposed delay.
Isn't the timeline too short between the release of the Final Rule from CMS and the requirement that hospitals and physicians be on Stage 2 meaningful use software?
McKesson is among stakeholders that have expressed concern about the short timeline between Final Rule and the start of Stage 2 for hospitals (Oct. 2012) and physicians (Jan. 2013), while supporting alternative solutions to help assure customer success and patient safety. The Office of the National Coordinator has listened to these concerns, recommending a one-year delay for providers that attest to Stage 1 in 2011.
McKesson is not waiting for the final rules and has begun developing product enhancements that are likely to be included among Stage 2 objectives.
McKesson representatives attend all Office of the National Coordinator (ONC) policy and standards meetings and have carefully analyzed all meeting discussions and recommendations. From that data, educated “assumptions” for needed functionality have been made, with contingency plans to fill any requirement gaps. Work groups are striving to address each area of Stage 2 meaningful use in order to leverage knowledge and resources across the company, determining strategies to address new requirements.
McKesson and RelayHealth have been using the Drummond Group Inc. to certify most of its offerings. In addition, our physician practice solutions (Practice Partner, Medisoft Clinical, Lytec MD and McKesson Practice Complete) are certified by the Certification Commission for Health Information Technology (CCHIT).
What is the National Institute of Standards and Technology (NIST) and what role does this organization play in certification?
In collaboration with the Office of the National Coordinator for Health Information Technology (ONC), NIST is the federal agency charged with developing the functional and conformance testing requirements, test cases and test tools to support the certification process for the EHR incentive program.
Our account teams are working with customers to document their current readiness status. We offer a comprehensive service path to assist customers with the transition process. We are encouraging customers to stay current on their product releases to ease the burden of transitioning as the deadline nears. In addition, we are partnering with third-party consulting firms to ensure we have adequate resources to help customers in this important transition.
For Stage 1, eligible hospitals (EHs) must report on 15 clinical quality measures. Eligible providers (EPs) must report on three required core CQMs, and if the denominator of one or more of the required core measures is zero, then EPs must report results for up to three alternate core measures. EPs also must also select three additional CQMs from an additional set of 38 CQMs.
- In December 2010, the Quality Measures workgroup issued a request for comments on proposed Stage 2 quality measures; read McKesson's response
- Feedback from providers and vendors on the implementation and use of the Stage 1 clinical quality measures indicates that this has been one of the most challenging areas of meaningful use.
- McKesson provided testimony on some of these challenges at a hearing held by the Quality Measures Workgroup on May 19, 2011. A copy of our testimony can be found here.
- In August 2011, the Quality Measures Workgroup provided a draft letter to the HIT Policy Committee recommending areas to consider for Stage 2 and Stage 3.
- Based on the current timeline discussion, CMS may signal proposed Stage 2 quality measures in late 2011, with more definition by the spring of 2012.