The Centers for Medicare & Medicaid (CMS) have released the final rule (PDF, 3 MB) for Modified Stage 2 (2015-2017) and Stage 3 Meaningful Use (MU) requirements. The final rule’s provisions encompass 2015 through 2017 (Modified Stage 2) as well as Stage 3 in 2018 and beyond. The final rule outlines the program requirements that eligible professionals (EP), eligible hospitals (EH), and critical access hospitals (CAH) must complete in order to avoid payment adjustments associated with the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program.

Hardship Exceptions

According to the rule no changes were included in the Stage 2 Modification or Stage 3 to hardship exceptions previously finalized.1 In 2012 when the Centers for Medicare & Medicaid (CMS) issued the final Meaningful Use (MU) Stage 2 Rule (PDF, 1.2 MB), 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. Therefore, EP’s whose primary specialty is listed in PECOS as Diagnostic Radiology (30), Nuclear Medicine (36), Interventional Radiology (94), Anesthesiology (05), or Pathology (22) 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.

Objectives and Measures Consolidation

Previous requirements included core and menu objectives that providers must achieve to demonstrate compliance. EP’s were previously required to meet all core objectives and three of the six menu objectives to demonstrate compliance.

Starting in 2015, these objectives were compiled into a single set of measures and objectives. EPs are required to comply with ten objectives and EH and CAHs are required to comply with nine.

Laboratory Testing

While CMS has recognized that the MU requirements are generally outside the scope of a pathology practice, several of the MU criteria relate directly or indirectly to pathology laboratory testing and laboratory information management. 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.

  • Computerized provider order entry: Previous Stage 2 Core Objective 10 computerized order entry (CPOE) was retained. EPs, EHs, and CAHs must use computerized order entry (CPOE) for more than 60% of medication, 30% of laboratory and 30% of radiology orders. This objective remained unchanged for Stage 2 Modification. Stage 3 includes an increase to 60% of laboratory and radiology orders.
  • Incorporate clinical lab: Previous Stage 2 Core Objective 10 included a requirement that more than 55% of clinical lab test results be incorporated into a Certified EHR Technology as a structured data. While CMS removed this measure in 2015, incorporating laboratory test results are a requirement under the Health Information Exchange measure.
  • Health Information Exchange: EPs, EHs, and CAHs that refer patients to another healthcare setting must provide a summary of care documented electronically for more than 10% of their patients. Laboratory test results must be listed, if available, for the summary of care document to meet this objective.2 Stage 3 includes an increase to more than 50% of transitions or referrals. Stage 3 also includes an additional measure that the providers electronically receive and incorporate the summary of care document for more than 40% of new patient encounters.
  • Patient Electronic Access: EPs, EHs, and CAHs must provide more than 50% of patients timely access online to view their health information and at least one patient must view, download or transmit the information.3 Stage 3 includes an increase to 80% of patients provided timely access. Stage 3 also includes a new measure that providers must use clinically relevant information from the EHR to identify and provide patient-specific electronic educational resources to more than 35% of patients.
  • Public Health Reporting, Objective 10: EHs and CHAs are required to meet three of the four measures. Measure 4 requires EHs and CAHs to submit electronic reportable laboratory results to a public health agency.

142 CFR Parts 412 and 495 Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 3 and Modifications to Meaningful Use in 2015 Through 2017; Final Rule (PDF, 1.1 MB). Federal Register. Oct. 16, 2015. Page 62911
2 Ibid at Page 62805.
3 Ibid at Page 215.

Author - Female

About the author

Leigh Polk is Pathology Marketing Specialist of McKesson Business Performance Service.