Stage 2 meaningful use success rests on 3 elements
■ A practical look at information technology issues and usage
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Unlike the first stage of the meaningful use incentive program, for which practices mostly had to demonstrate they were capable of performing certain tasks with their electronic health record systems, stage 2 will require practices to actually perform those tasks.
Experts said doctors should start preparing now, because they are going to need cooperation from practice employees, patients, hospitals and health facilities, and other practices — anyone with whom they will share data — to meet stage 2. Many vendors guaranteed that their systems would meet stage 1, but because stage 2 focuses more on how the systems are used rather than what they are capable of doing, they may not offer the same level of guarantees for stage 2.
Practices can earn up to $44,000 per physician over five years from Medicare, or up to $63,750 over six years from Medicaid if they meet the requirements of the meaningful use incentive program. Stage 1 is under way, and stage 2 begins in January 2014. Doctors are required to adopt electronic health records systems and achieve meaningful use criteria by October 2014, or they will see reduced Medicare payments in 2015.
Practices should assess where they are and then make a road map of what needs to be purchased, what needs to be upgraded, and what changes need to be made, said Amit Trivedi, health care programs manager for Mechanicsburg, Pa.-based ICSA Labs, which is federally certified to test products for meaningful use compliance,
Experts broke down the process into three major tasks: patient engagement, data sharing and data security.
They said physicians should take small steps toward meeting meaningful use so they are less likely to be surprised by last-minute glitches.
Under stage 1 of meaningful use, physicians must be capable of providing electronic copies of records if patients ask for them. Many physicians requested exemptions to this rule because no patients asked for their records. Under stage 2, physicians must provide online access to records and ensure that at least 5% of their patients look at them.
Although most practices did not get requests for records, they didn’t publicize their availability either, said Jeff Loughlin, project director for the Massachusetts eHealth Collaborative, Massachusetts’ ONC-sanctioned regional extension center.
“The mentality is that patients think medical records are for medical professionals,” Loughlin said. Practices can alert patients to this shift by educating them about the importance of accessing and reviewing medical records, he said.
During the next year, physicians need to think about what they want online access to look like so it’s designed in a way that patients will use it, said Dianne Bourque, a Boston-based attorney who specializes in health law at the international firm of Mintz Levin.
Trivedi said one idea is to survey patients to determine their needs and wants and get feedback on how EHR implementation is changing the patient experience. This not only will foster patient engagement, but also will guide practices to the right technology and help them meet patient expectations.
Most practices probably will go with a patient portal system that offers online access to records and secure messaging, also a requirement under stage 2. Physicians should be talking with their EHR vendors to determine whether their systems will offer what is needed. If not, they should seek out a third-party vendor, Loughlin said.
A big focus of stage 2, Loughlin said, is care coordination that is made possible through data exchange. Physicians need to examine their options — such as regional or statewide health information exchanges or private exchanges with local hospitals — for sharing their data outside the four walls of their practices, he said.
Some of those exchanges might not be up and running, or there may be more than one from which to choose. All come with different costs and governance. Now is a good time for physicians to weigh their options, Loughlin said.
Practices need to prepare for the possibility that meeting some of the data exchange or quality reporting requirements are out of their control, Trivedi said. Some organizations to whom physicians are required to send data electronically, such as immunization registries and state health departments, may not have the ability to receive electronic data, he said. Practices should ask other practices, local hospitals and regional extension centers for their advice. Physicians can take exemptions for situations outside of their control, Bourque said.
Data security and privacy
In drafting the rules, the Dept. of Health and Human Services acknowledged that stage 2 will mean that more data are flowing outside practice walls. Therefore, practices need to focus on security every step of the way.
HHS also gave a nod to the proliferation of mobile technology by requiring practices to conduct a risk analysis of data “at rest,” including data stored on mobile devices, to determine encryption needs. These new rules build on stage 1 data protection requirements.
“Security can’t take a back seat,” Bourque said.
Practices need to consider every point at which data can be accessed, viewed and shared and then assess security at each of those points.
As was the case with stage 1, if practices take the planning one piece at a time and are thoughtful about each step, Bourque said, it not only will get buy-in from practice employees but also will break down a large project into smaller, more manageable pieces.