CMS released the stage 2 final rule for meaningful use in August 2012. For hospitals that started the meaningful use process in 2011, they will not be required to begin reporting against the stage 2 requirements until July 1, 2014. Although 2014 may seem like quite a distance away, the next 21 months will move very quickly, especially given the many competing priorities hospitals have. According to Laura Kreofsky, a Principal at Impact Advisors, a healthcare technology consulting firm, hospitals should make it a point to start preparing for stage 2 meaningful use regardless of their status with stage 1.
This may be easier said than done. How will hospitals begin preparing for stage 2 if they still need to meet stage 1? Well, according to Ms. Kreofsky, the stage 2 rule finalized changes to stage 1 that may make stage 1 attestation and eventual transition to stage 2 easier.
"CMS intended two things with the changes to stage 1 requirements published in the stage 2 final rule: to better align stage 1 with stage 2 so it was not apples and bananas, and at the same time, to help organizations ramp up for stage 2. While an organization's journey to stage 1 may depend on its clinical processes and workflows, the adjustments to stage 1 requirements could still benefit many hospitals," says Ms. Kreofsky.
Here, Ms. Kreofsky discusses three ways hospitals can start now to ease the transition to stage 2 meaningful use.
1. Review, consider utilizing stage 1 changes. Ms. Kreofsky recommends hospitals review the stage 1 changes defined in the stage 2 final rule, whether they started stage 1 or not, because the adjustments could help them better implement stage 1 and/or meet stage 2 starting in 2014.
"There are about 10 different objectives in stage 1 that were changed under stage 2. Some are intended to help with the 'ramp up' to stage 2. In many cases, hospitals will have the option to implement these changes in 2013 for their stage 1 attestation, so when they move to stage 2, there is less of a jump," says Ms. Kreofsky. "It is very important for every organization to look at those changes as well as the stage 2 requirements themselves to identify the high-level gaps right now. Where are the most challenging pain points going to be? Anything [hospitals] can do now to make the stage 1 to stage 2 transition easier is beneficial," she says.
For instance, the stage 1 objective for computerized provider order entry has a denominator based on a number of unique patients. The stage 2 rule changes this objective's denominator to be based on all orders entered. For some hospitals, the new denominator may be more challenging. However a hospital may want to adopt the new denominator — even if still in stage 1 — because it drives towards the right performance standard. "Ultimately, a hospital wants all its providers to do all their orders via CPOE. Not just some orders for some patients. From a patient-care perspective, the new denominator is the right one. If hospitals start out of the gate using that denominator or moves to the new denominator in its second year at stage 1, it is not such a drastic change from stage 1 to stage 2," says Ms. Kreofsky.
2. Start patient engagement activities now. Ms. Kreofsky recommends hospitals start now to bolster their patient engagement activities in order to meet the stage 2 requirements for patient engagement and clinical information exchange.
"[Patient engagement] needs to happen. Although there is a considerable amount of grumbling — some of it justified — by providers who will have to coach their patients to use secure messaging or by hospital departments that will have to spend a great deal of time educating patients, healthcare organizations need to meet the requirement. They need to spend the time initially to educate staff and patients and ensure the appropriate technologies are in place. That is something they can start doing now before the stage begins," says Ms. Kreofsky.
If hospitals start before it is necessary, they can spend more time training staff to prompt patients to view or download their health information. If the number of patients at the hospital or practice that engage in secure messaging rise before the organization begins stage 2 or even stage 1, the process could be easier.
3. Take advantage of the reporting period changes. According to Ms. Kreofsky, hospitals need to take advantage of the nine months of preparation they will gain under the reporting changes finalized in the stage 2 rule.
"Effectively almost all hospitals and providers have a three-month reporting period in 2014, meaning they gain nine months of preparation time for stage 2. They should use that to their advantage," says Ms. Kreofsky. "A lot of organizations 'got by' on stage 1 by minimizing the change in their workflows. They were putting a band-aid on things. This is an opportunity to really transform clinical processes by using that extra nine months."
The July 1, 2014 deadline may seem far, far away, but as we all know, a year can pass very quickly. Hospital leaders have multiple initiatives demanding their focus and attention. However, slow and steady preparation for stage 1 and/or stage 2 will give hospitals a leg up in attesting to meaningful use. Even small steps like reviewing the stage 1 changes, beginning patient engagement or utilizing the extra nine-months in 2014 prior to beginning their reporting period can make a difference.
Study: CPOE is Still Hospitals' Largest Barrier to Meaningful Use
4 Reasons Hospitals Need Leadership Collaboration for Success in HIT Implementations
This may be easier said than done. How will hospitals begin preparing for stage 2 if they still need to meet stage 1? Well, according to Ms. Kreofsky, the stage 2 rule finalized changes to stage 1 that may make stage 1 attestation and eventual transition to stage 2 easier.
"CMS intended two things with the changes to stage 1 requirements published in the stage 2 final rule: to better align stage 1 with stage 2 so it was not apples and bananas, and at the same time, to help organizations ramp up for stage 2. While an organization's journey to stage 1 may depend on its clinical processes and workflows, the adjustments to stage 1 requirements could still benefit many hospitals," says Ms. Kreofsky.
Here, Ms. Kreofsky discusses three ways hospitals can start now to ease the transition to stage 2 meaningful use.
1. Review, consider utilizing stage 1 changes. Ms. Kreofsky recommends hospitals review the stage 1 changes defined in the stage 2 final rule, whether they started stage 1 or not, because the adjustments could help them better implement stage 1 and/or meet stage 2 starting in 2014.
"There are about 10 different objectives in stage 1 that were changed under stage 2. Some are intended to help with the 'ramp up' to stage 2. In many cases, hospitals will have the option to implement these changes in 2013 for their stage 1 attestation, so when they move to stage 2, there is less of a jump," says Ms. Kreofsky. "It is very important for every organization to look at those changes as well as the stage 2 requirements themselves to identify the high-level gaps right now. Where are the most challenging pain points going to be? Anything [hospitals] can do now to make the stage 1 to stage 2 transition easier is beneficial," she says.
For instance, the stage 1 objective for computerized provider order entry has a denominator based on a number of unique patients. The stage 2 rule changes this objective's denominator to be based on all orders entered. For some hospitals, the new denominator may be more challenging. However a hospital may want to adopt the new denominator — even if still in stage 1 — because it drives towards the right performance standard. "Ultimately, a hospital wants all its providers to do all their orders via CPOE. Not just some orders for some patients. From a patient-care perspective, the new denominator is the right one. If hospitals start out of the gate using that denominator or moves to the new denominator in its second year at stage 1, it is not such a drastic change from stage 1 to stage 2," says Ms. Kreofsky.
2. Start patient engagement activities now. Ms. Kreofsky recommends hospitals start now to bolster their patient engagement activities in order to meet the stage 2 requirements for patient engagement and clinical information exchange.
"[Patient engagement] needs to happen. Although there is a considerable amount of grumbling — some of it justified — by providers who will have to coach their patients to use secure messaging or by hospital departments that will have to spend a great deal of time educating patients, healthcare organizations need to meet the requirement. They need to spend the time initially to educate staff and patients and ensure the appropriate technologies are in place. That is something they can start doing now before the stage begins," says Ms. Kreofsky.
If hospitals start before it is necessary, they can spend more time training staff to prompt patients to view or download their health information. If the number of patients at the hospital or practice that engage in secure messaging rise before the organization begins stage 2 or even stage 1, the process could be easier.
3. Take advantage of the reporting period changes. According to Ms. Kreofsky, hospitals need to take advantage of the nine months of preparation they will gain under the reporting changes finalized in the stage 2 rule.
"Effectively almost all hospitals and providers have a three-month reporting period in 2014, meaning they gain nine months of preparation time for stage 2. They should use that to their advantage," says Ms. Kreofsky. "A lot of organizations 'got by' on stage 1 by minimizing the change in their workflows. They were putting a band-aid on things. This is an opportunity to really transform clinical processes by using that extra nine months."
The July 1, 2014 deadline may seem far, far away, but as we all know, a year can pass very quickly. Hospital leaders have multiple initiatives demanding their focus and attention. However, slow and steady preparation for stage 1 and/or stage 2 will give hospitals a leg up in attesting to meaningful use. Even small steps like reviewing the stage 1 changes, beginning patient engagement or utilizing the extra nine-months in 2014 prior to beginning their reporting period can make a difference.
More Articles on Meaningful Use:
Meaningful Use is Up to You: 4 Key Points From Dr. Farzad MostashariStudy: CPOE is Still Hospitals' Largest Barrier to Meaningful Use
4 Reasons Hospitals Need Leadership Collaboration for Success in HIT Implementations