Beginning Jan. 1, 2015, eligible professionals (EPs) who do not adopt and successfully demonstrate meaningful use of a certified EHR technology each year for the appropriate stage will be subject to a payment adjustment.
In 2012 when the Centers for Medicare & Medicaid (CMS) issued the final Meaningful Use (MU) Stage 2 Rule, they acknowledged that the specialties of pathology, radiology and anesthesiology lack the face-to-face patient interaction and follow-up needed with patients to comply with meaningful use criteria. These specialties were granted a hardship exception and are automatically exempt from the penalties that would otherwise apply beginning in 2015 for failure to meet MU requirements, by CMS.
However, these exemptions are subject to an annual review. The College of American Pathologist (CAP) along with the College of Radiology and American Society of Anesthesiology are advocating that CMS extend these exemptions.
While CMS has recognized that the MU requirements are outside the scope of a pathology practice, several of the MU criteria relate directly or indirectly to pathology laboratory testing and laboratory information management.
MU includes core and menu objectives that providers must achieve to demonstrate compliance. Core objectives must be met by all providers. In addition, EPs must select a predetermined number of menu objectives from a list to demonstrate MU. In Stage 2, EP’s must meet all 17 core objectives and three of the six menu objectives.
Two Stage 2 EP Core Objectives relate directly to laboratory.
- Core Objective 1: Use computerized order entry (CPOE) for more than 60% of medication, 30% of laboratory and 30% of radiology orders. This objective increased from only mentioning medication orders to the addition of laboratory and radiology in Stage 2. It may increase to 60% of laboratory and radiology orders in Stage 3.
- Core Objective 10: Incorporate clinical lab-test results into a Certified EHR Technology as a structured data for more than 55% of all clinical lab test results. This objective increased from 40% in Stage 1 to 55% in Stage 2. In stage 3 this may be moved to 80% of clinical lab-test results.
Future requirement are anticipated to impact pathology and laboratory as well because of their integral role in enabling EPs in meeting the MU objectives. Stage 3 criteria are currently scheduled to go into effect in 2017.
Therefore, referring physician practices are seeking providers who can help them comply with MU. The ability to provide electronic ordering and reporting which is interfaced with the practice EMR can directly impact referral patterns in the market.
To remain competitive, laboratories need to begin promoting their EMR and results reporting capabilities to providers are also positioning themselves as consultants for MU guidance to select referring physician practices.