Q: What should I expect when fulfilling Stage 2 of meaningful use in 2014?
A: The Centers for Medicare and Medicaid Services (CMS) has extended Stage 2 of the electronic health record incentive payment program to three years, and has pushed back the start of Stage 3 until at least 2017.
To fulfill Stage 2, 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. All measures need to be performed on the patients listed in your EHR system, not just on Medicare patients. View all of the measures here.
Direct exchange of health information is a key component of Stage 2 of meaningful use, and it ensures that the transfer of information is secure and confidential, as stipulated in the Health Insurance Portability and Accountability Act (HIPAA). Direct exchange will be integrated into upgraded electronic health record technology for 2014, and systems must be certified as having this capability. Direct exchange is like e-mail, but it has an added layer of security. It is a way for users of two separate EHR systems to send and receive information securely.
Physicians will be able to use direct exchange to communicate with other physicians, health care professionals, patients, and some payers.
Patient engagement is a challenging aspect of Stage 2 because a practice must have a Web-based patient portal to comply with "view, download, and transmit" requirements. The portal must be able to send, via direct exchange, certain health information documents.
To meet the patient engagement objective, patients must be able to view, download, and transmit a summary-of-care record provided by the EHR technology to a third party of their choosing, and 5 percent of patients must do this to fulfill the requirement.
Incentives and penalties
Starting in 2015, there is a 1 percent penalty for non-participation in the program. View the payment schedule for participation in the Medicare EHR incentive program here. The penalty begins at 1 percent in 2015 and increases to 2 percent in 2016, 3 percent in 2017, and can go up to as much as 5 percent of your total Medicare Part B allowed charges. You must participate in the program two years preceding the penalty year. The following options are available to avoid the penalty in 2015:
- If you have attested in 2011 or 2012: Attest in 2013 for the full year.
- If your first year of reporting is 2013: Attest for any 90-day period in 2013.
- If your first year of reporting is 2014: Attest by Oct. 1, 2014.
Future penalty years will require this participation schedule.
Registration and attestation
Dermatologists can register for the EHR Incentive Program on the CMS website. Participants must be enrolled in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) and have a National Plan and Provider Enumeration System (NPPES) username and password.
The first year you participate in the program, there is a 90-day reporting period. Therefore, the last day to begin the program in your first year of reporting is on Oct. 1 of the reporting year. Participating from Oct. 1 to Dec. 31 will allow the physician to report for 90 days. Every subsequent year requires the dermatologist to report for the full year, except for 2014 when all providers, regardless of the stage they are reporting, are allowed to report for a 90-day period.
After your practice has finished performing all of the meaningful use measures for that year, you must log back into the CMS website where you registered and attest. View the CMS guide to attestation here. This guide will help you navigate the attestation module.
For questions about Stage 2 of meaningful use, email firstname.lastname@example.org.