How to fulfill stage 2 of meaningful use

CMS releases final rule for EHR Incentive Program – allows use of 2011 CEHRT in special cases

The final rule for the EHR Incentive Program recently released by the Center for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology is not significantly different from the proposed rule published in May. The final rule allows providers to use the 2011 Edition of certified electronic health record technology (CEHRT), a combination of the 2011 and 2014 Editions, or the 2014 Edition for participation in 2014. The rule spells out various options for providers who, for example, were unable to upgrade to 2014 CEHRT or upgraded to 2014 CEHRT but could not fully implement all of the new functions required for Stage 2. However, these options are only applicable for providers whose inability to do either was directly related to vendor capability, such as the availability and timing of product installation, deployment of new processes and workflows, and employee training. Beginning in 2015, all providers will be required to report using 2014 Edition CEHRT. The rule also indicates that Stage 3 is scheduled to begin in 2017. Click here to read the final rule.

To fulfill Stage 2 of meaningful use, dermatologists will need to complete all 17 core measures — unless an exclusion applies — and select three additional measures to complete from a menu set of six measures. Dermatologists must also complete the requirements to report clinical quality measures. Please note: All measures need to be performed on the patients listed in your EHR system, not just on Medicare patients.

Core measures

1. Use computerized provider order entry (CPOE) for medication, laboratory, and radiology orders directly entered by any licensed health care professional who can enter orders into the medical record per state, local, and professional guidelines.

View information about the measure here.

Additional details: This measure adds on to the CPOE measure from stage 1 by not only requiring electronic ordering of medications but also of lab orders and radiology orders. Physicians are exempt if they writer fewer than 100 medication orders, 100 radiology orders, or 100 lab orders. Credentialed medical assistants or scribes can perform this measure as long as the physician reviews the order before it is submitted.

2. Generate and transmit permissible prescriptions electronically.

View information about the measure here.

Additional details: Most Mohs surgeons will be exempt from this measure because any physician who writes fewer than 100 non-controlled prescriptions during the reporting period is exempt. An additional exemption is available to physicians who do not have access to a pharmacy that accepts electronic prescriptions within 10 miles of their practices. Please note, this measure adds to Stage 1 by not only requiring the physician to e-prescribe 50 percent of all prescriptions, but also query a drug formulary when e-prescribing.

3. Record the following demographics: Preferred language, sex, race, ethnicity, date of birth.

View information about the measure here.

Additional details: Race and ethnicity have discrete definitions that should be noted by your EHR vendor. The most efficient method for collecting this measure is to include this question on your practice’s intake form so patients can simply select each of their demographic measures. If a patient doesn’t wish to disclose any of his or her demographic information, this can be noted in the EHR record and counted as part of the numerator for this measure.

4. Record and chart changes in the following vital signs: Height/length and weight (no age limit); blood pressure (age 3 and older); calculate and display body mass index (BMI); and plot and display growth charts for patients 0-20 years, including BMI.

View information about the measure here.

Additional details: Dermatologists can exclude themselves from this measure if they take the occasional blood pressure, height, or weight on a patient. Additionally, dermatologists can only record the blood pressure and exclude themselves from recording height and weight if they so choose.

6. Use clinical decision support to improve performance on high-priority health conditions.

View information about the measure here.

Additional details: This measure requires the physician to implement five clinical decision support interventions related to four or more clinical quality measures (CQM) (or other high-priority health conditions if no CQMs apply) and requires the EHR to have drug-drug and drug-allergy interaction checks enabled. Physicians can be exempt from the drug-drug and drug-allergy interaction checks if they prescribe fewer than 100 non-controlled prescriptions during the reporting period. Dermatologists should implement clinical decision support interventions centered on melanoma. Check with your EHR vendor to determine if there are any pre-built clinical decision support interventions already.

7. Provide patients the ability to view online, download, and transmit their health information within four business days of the information being available to the EP.

View information about the measure here.

Additional details: This measure builds upon stage 1 by requiring physicians to install a patient portal within their EHR that is accessed by at least 5 percent of their patients. Dermatologists are only exempt if they do not have reliable access to an internet connection. The following information is required to be included in the portal: Patient name, provider's name and office contact information, current and past problem list, procedures. laboratory test results, current medication list and medication history, current medication allergy list and medication allergy history, vital signs if relevant (height, weight, blood pressure, BMI, growth charts), smoking status, demographic information (preferred language, sex, race, ethnicity, date of birth), care plan field(s), including goals and instructions, and any known care team members including the primary care provider (PCP) of record unless the information is not available in certified EHR technology (CEHRT), is restricted from disclosure due to any federal, state, or local law regarding the privacy of a person’s health information, including variations due to the age of the patient or the provider believes that substantial harm may arise from disclosing particular health information in this manner.

8. Provide clinical summaries for patients for each office visit.

View information about the measure here.

Additional details: Consult with your EHR vendor to determine how best to generate a clinical summary. Some vendors require the dermatologist to complete his or her notes before a clinical summary can be generated, which would require the physician to complete the notes before the patient leaves the office. A practice also could upload the clinical summary to a patient portal that the patient can then download within three business days. Physicians should not charge patients a fee for this information.

 

The Academy's EHR Implementation Task Force created a letter to help dermatologists who are audited for Meaningful Use support their exemption of the vital signs measure. Download the letter. 

10. Incorporate clinical lab-test results into Certified EHR Technology as structured data.

View information about the measure here.

Additional details: The dermatologist’s EHR must incorporate clinical lab test results into structured data in to meet this measure. The act of inserting a PDF document with the clinical lab test results into the patient’s medical chart does not qualify as structured data.

12. Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care and send these patients the reminders, per patient preference.

View information about the measure here.

Additional details: Patients who are seen for at least two office visits prior to 24 months of the dermatologist starting the meaningful use program are eligible for this measure. 

13. Use clinically relevant information from Certified EHR Technology to identify patient-specific education resources and provide those resources to the patient.

View information about the measure here.

Additional details: The EHR should identify the patient-specific education resources, however, the resources do not have to be in electronic format.

14. The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation.

View information about the measure here.

Additional details: Medication reconciliation requires the practice to identify the most accurate list of medications for the patient based on an external list from either the patient or another provider or hospital. Consult with your EHR vendor to determine how best to identify a patient from another provider in the electronic record.

15. The EP who transitions his or her patient to another setting of care or provider of care, or refers the patient to another provider of care should provide a summary care record for each transition of care or referral.

View information about the measure here.

Additional details: A summary of care record can be in the format of a letter that the dermatologist can either send electronically or on paper. However, this measure builds upon Stage 1 by requiring that at least 10 percent of such referrals are sent electronically by the EHR. The dermatologist must also conduct at least one successful electronic exchange of this information with another provider who has a different EHR. Consult with your EHR vendor to determine how best to identify a transition of care in the patient’s record. Dermatologists can be excluded from this measure if they refer patients less than 100 times to another provider.

17. Use secure electronic messaging to communicate with patients on relevant health information.

View information about the measure here.

Additional details: This measure builds upon stage 1 by requiring at least 5 percent of patients to send the dermatologist an electronic message through his or her EHR or patient portal. Dermatologists are not required to respond to the message electronically. Dermatologists without reliable Internet access are also excluded from this measure.

Menu measures

Choose three: exclusions no longer count as completion of a measure. You must fulfill the measure for it to count, however if you cannot perform a measure due to an exclusion you may still qualify.  You would report which menu set measures you cannot meet due to an exclusion and which menu set measures you can meet when you report.

2. Record electronic notes in patient records.

View information about the measure here.

Additional details: Dermatologists should select this as a menu set measure because it requires a standard of practice.

3. Imaging results consisting of the image itself and any explanation or other accompanying information are accessible through CEHRT.

View information about the measure here.

Additional details: Dermatologists who order less than 100 imaging tests should not report this measure because it counts as an exclusion.

4. Record patient family health history as structured data.

View information about the measure here.

Additional details: Dermatologists should select this as a menu set measure. The most efficient method for collecting this measure is to include this question on your practice’s intake form so patients can simply fill out their family health history.

5. Establish the capability to identify and report cancer cases to a public health central cancer registry, except where prohibited, and in accordance with applicable law and practice.

View information about the measure here.

Additional details: Dermatologists should not select this as a menu set measure if they meet the following exclusions: Do not diagnose melanoma directly or operate in a jurisdiction where there is no capability for electronic reporting through the EHR to a state cancer registry. If the dermatologist is already reporting electronically to a state cancer registry, this measure requires that the reporting is performed through the EHR and not through an online registry.

6. Capability to identify and report specific cases to a specialized registry (other than a cancer registry), except where prohibited, and in accordance with applicable law and practice.

View information about the measure here.

Additional details: Dermatologists should not select this as a menu set measure if they do not diagnose a condition associated with a specialized registry sponsored by a national specialty society or the public health agencies in their jurisdiction. Please note, the dermatologist must submit this electronic information through his or her EHR and not an online registry.

Clinical quality measures

Stage 2 requires physicians to report additional clinical quality measures (CQMs). Dermatologists do not need to perform any CQMs that are not relevant to their practices. This measure simply requires the physician to report his or her numerators and denominators for each CQM, however, it is changed from Stage 1 in that the physician is allowed to report this through his or her EHR. 

The physician can report zero numerators, zero denominators, or any combination of such if a measure does not apply. You should speak with your EHR vendor to determine how they plan on allowing your specialty practice to report the CQMs. 

If your vendor does not have this capability, you can continue reporting the CQMs via attestation. Please note: you should not select that you participate in the Medicare PQRS-EHR Incentive Pilot when you attest to this question on the CMS website. The AAD’s QRS registry does NOT qualify as a submission vendor for clinical quality measures for purposes of meaningful use. 

Additionally, you are allowed to report the CQMs in a different time period from the core and menu set measures.  Thus, a provider could report all the meaningful use measures except CQMs from Jan. 1-March 31, 2014 and then report the CQMs from April 1-June 30, 2014.

Physicians can also report via one method for both PQRS and the meaningful use CQMs. The dermatology-specific PQRS measures are not allowed to be reported through this option; however dermatologists can select other measures to participate. Contact your EHR vendor to find out if they currently offer this option.

CMS has posted additional clinical quality measure information here.