Software Solutions/EHR

Meaningful Use Stage 2: Action Points to Ready Your Practice

By Ian Lane, OD

Ready for Stage 2 Meaningful Use? Here are the critical steps to ready your practice for electronic data connectivity.

Meaningful Use Stage 2 begins on January 1, 2014. Many ODs are not aware of this upcoming challenge, or are still scrambling to figure out how to pull off this next stage of electronic records implementation. Here are the key points to be aware of as you ready your practice to get to the next level of EHR use.

Define Stage 1
Stage 1 of Meaningful Use started in 2011 and focuses on EHR implementation and data capture and small steps in information sharing. To receive payment for Stage 1, ODs must meet the requirements of 15 core objectives, five of 10 menu objectives and six clinical quality measures (three core and three additional). The reporting period for attestation is a consecutive 90-day period for the first year and a full year subsequently.

Define Stage 2
Stage 2 of Meaningful Use begins on January 1, 2014, and has a stronger focus on advanced clinical processes including increased requirements for e-prescribing and incorporating lab results, electronic transmission of patient care summaries across multiple settings and more patient-controlled data. To attest for Stage 2, ODs must meet 17 core objectives, three of six menu objectives and nine of 64 clinical quality measures. The requirement is for 90 consecutive days that can start at the beginning of each quarter throughout the year. Stage 2 will span for two years to allow for ODs that attested for Stage 1 in 2013.

Complete Vs. Modular
It’s important to understand that EHRs can either have complete EHR certification or modular EHR certification. A complete EHR is one that has met all of the government’s requirements and has been tested and certified by a federally approved certification organization. Complete EHRs allow ODs to install one system in order to qualify for Meaningful Use and obtain incentive payments, and avoid late adoption penalties down the road. Modular EHR systems can be used by purchasing and combining multiple certified EHR modules so that when used together they meet all the requirements of a complete EHR.

First Steps/Requirements & Options
In order for ODs to get started with Meaningful Use in 2014 they’ll need to ensure that they have a 2014 Certified Complete EHR or a group of two or more 2014 Modular certified applications that together equal a “Complete EHR” equivalent. For ODs who have already attested with a 2011 Certified EHR they will still need to complete attestation using a 2014 certified EHR. The system certifications are different, so just because a system was certified for 2011 does not mean that it is certified for 2014 standards. This means they need to either implement their vendor’s upgraded EHR that has been certified for the 2014 standards and criteria, or install and implement a different EHR that is 2014 certified. It’s also important to note for ODs who have not yet completed Stage 1, that 2014 certification is good for both Stage 1 and Stage 2.

This makes it all the more important for ODs to request a status of 2014 Certification. If 2014 Certification has not yet been achieved, ask: has a date been scheduled? Will it be complete or modular certification? If modular, which other modules will be required and will there be additional charges?

ODs also have to get registered to participate in the incentive program. Registering does not mean that they have to participate, but they’ll be able to check their eligibility and other issues that could interfere with or delay their participation in the program.

After they’ve implemented a certified EHR and completed the registration process, it’s time to take a look at the criteria for 2014 Meaningful Use to ensure that they’re able to meet all of the requirements.

Cost: Time and Money

There is no denying that implementing a certified EHR and participating in the incentive program is going to cost time, in training, and money. But the monetary commitment is offset by the Meaningful Use reimbursement from CMS. Another way to save money is by selecting a complete certified EHR that doesn’t require the purchase of a third-party tool needed to attest with the solution. Because so many solutions out there require the purchase of a third-party tool, the government requires a pricing statement to accompany all certification statements so that there is no surprise for someone when they select a solution. And, remember, if you already have a system that was certified prior to 2014, it will have to be re-certified, which means there could be additional costs on upgrade agreements with the vendor.

It’s also important to think about the long-term costs, and money you could be missing out on. There are going to be penalty fees down the road for practices that do not implement a certified EHR solution, and that’s on top of the money ODs will miss out on by not attesting in the first place. Your patient care could also be affected in the long run, as it won’t be possible to coordinate care without this technology.

If ODs choose not to participate by 2015, they’ll be penalized through lower reimbursements for care provided to Medicare patients. They will be subjected to payment adjustments to their Medicare reimbursements that start at 1 percent per year, up to a maximum of 5 percent annual adjustment.

Timing

In order for ODs to participate in Stage 2 of Meaningful Use, they must have completed Stage 1. Stage 2 begins on January 1, 2014, and the requirement is 90 consecutive days that can start at the beginning of any quarter. Stage 2 spans for two years to allow for ODs who attested to Stage 1 in 2013.

A page from Uprise, VisionWeb’s cloud-based EHR solution, that aids users in meeting Meaningful Use Stage 1 or Stage 2 requirements.

Best Practices & Support

Thirty-two percent of most doctors have familiarized themselves with Stage 2 requirements for Meaningful Use, and 25 percent have reviewed requirements and are taking action toward Stage 2.

Optometric staff will play a large role in meeting 2014 Meaningful Use requirements. Meaningful Use is all about change management and compliance. Being diligent about recording the necessary requirements such as smoking status, height and weight during the history taking process will help a lot. Having the staff work closely with the ODs to review the reports generated by the EHR frequently will assure that the metrics required for attestation will not fall behind. Staff members can also:

• Make sure the appropriate documentation that is time sensitive has screenshots that can prove the requirement was met during the attestation period.

• Be vigilant in Patient Privacy Protection and make sure that all the provisions of the Privacy Policy are met and reviewed as required.

• Be supportive of the ODs as they all work through the mandated change.

Some of the biggest Meaningful Use pain points causing the most trouble for ODs are keeping up with records in the event of an audit, delegation of tasks to staff and remaining engaged and in control–and ODs are ultimately accountable for doing all these things. The best way around these problems is having a clear plan of action to accomplish attestation.

Having a clear plan of action will help identify what tasks need to be completed, when they need to be done and the needed communication among the team involved in the process.Click HERE for more information on creating an EHR attestation plan.

Beware of Audits

One thing to be aware of if participating in the incentive program is pre- and post-payment audits. The CMS has retained an accounting firm to conduct a 10 percent random audit either pre- or post-payment review. It’s important to remember that the audits are at random and not necessarily caused by suspicious activity. Here’s a few ways you can prepare yourself and your practice in the event of an audit:

• Document everything. And keep your documentation for at least six years after attestation
• Send all records requested as soon as possible; don’t delay compliance
• Do not alter any records you send in
• Contact the auditor and maintain contact so you are clear on expectations they have.
• Audits will remain in your records and increase your chances of being audited in the next stages.

With all the changes unfolding it’s important for ODs to choose EHR partners. It’s not just a simple customer-vendor relationship. It is also important not to make mission critical decisions like this using price alone as a deciding factor. Keep in mind the technology platform that the EHR is built upon. Older technologies are unlikely to keep up with the rigors of more modern EHRs. Be sure the system you choose is up-to-date and ready to meet Meaningful Use Stage 2 and Stage 3 requirements.

Related ROB Articles

Taking EHR to the Next Level: What ODs Should Know

Ready to Make the Switch? Why Transitioning to Cloud-Based EHR is Worth It

Cloud-Based Technology 101: Is Your Practice “In the Cloud” Yet?

Ian Lane, OD, is an experienced health information technology executive, accomplished lecturer and writer, with almost 30 years of extensive ophthalmic and global experience. To contact him: ilane@visionweb.com

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