Meaningful Use Stage 2 Proposed Rule

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It’s Here! Meaningful Use Stage 2 Proposed Rule

Electronic Health Records and Meaningful Use are on the minds of physicians and administrators all around the country.  David Lee from wrote a post about the Meaningful Use Stage 2 Proposed Rule that was just announced. He writes a nice summary on the main points of the rule. I have included his post so you can take a quick read of this new information.

What else could we talk about as our perspective?  Of course, Meaningful Use Stage 2 Proposed Rule…


It’s finally here.  The long awaited and much anticipated proposed rule for meaningful use stage 2. Okay, maybe not everyone was anxiously waiting for it but it does start to shed some light to what the providers, hospitals and EHR vendors must do with the 2nd stage of meaningful use.  First of all, let’s review what the high level goal is for Stage 2.  Sitting between Stage 1 (data capture) and Stage 3 (improved and more efficient care) goals, stage 2 is about exchanging data.  Like stage 1, CMS and ONC were very pragmatic about how they came up with the proposed rule.  They seem to have balanced the need to sustain the momentum from stage 1 while keeping an eye towards providers who are struggling to meet stage 1 requirements.  Here’s the list of key items from the proposed rule for meaningful use stage 2 for Eligible Professionals. 

  • Everyone starts stage 2 in 2014.  For those who have attested for meaningful use in 2011, stage 2 now starts in 2014 (from 2013) to be in sync with everyone else.  Essentially, there is no penalty for early achievers of meaningful use.
  • Stage 1 requirements will have updates for 2013.  The good news is that you have options to either meet the updated stage 1 requirements or simply stick with what’s defined with the stage 1 final rule.
  • Qualification requirement for the Medicaid incentive program have greatly loosened.  If you did not qualify for Medicaid incentive program in 2011 or 2012, check again because you may qualify under the new qualification requirements.  The best part is once the stage 2 is in final rule form, new qualification goes in effect.  That means it could be as early as 2013.
  • Stage 2 requirements are much tougher.  Number of Measure objectives remained the same (20) with 17 Core measures (was 15) and 3 of 5 Menu measures (was 5 out of 10).  CQM requirements however, increases to 12 (was 6).  In addition, measurement goals are generally higher (e.g. recording vital signs increases from 50% to 80%) and overall requirements are much more complex (some measures have multiple components to meet).  Don’t kid yourself.  Stage 2 is definitely more challenging than stage 1.
  • Patient engagement will play a bigger role in meeting stage 2 requirements.  For example, it is no longer good enough to just provide patients their health information.  Patients will need to actually view and download their health information.
  • Transmission and exchange of information is no longer satisfied by simply doing a “test”.  With stage 2, you actually need to transmit and exchange “real” information and more than just once.
  • Although exchanging of data is key to stage 2 goal, HIE is not required.  Secure email can be used to exchange data instead.
  • Alignment with other programs has begun, starting with the PQRS.
  • Payment adjustments begin in 2015 but deadlines differ.  If you achieve meaningful use in 2011 or 2012, you will need to achieve meaningful use in 2013 to avoid penalty adjustment in 2015.  However, if you don’t achieve meaningful use by 2013, you must achieve meaningful use three months before the close of 2014 to avoid penalty in 2015. 

Let’s also not forget the sister proposed rule related to the standards and specifications for EHR system that was released at the same time.  This proposed rule is primarily about updating the certification rules so that the ONC certified EHR systems meet the stage 2 requirements.

For most providers, meaningful use stage 2 means little in 2012.  However, for those who have achieved or are planning to achieve stage 1 requirements at the minimal level, stage 2 proposed rule should be reviewed before the end of 2012 to determine gaps.  That way, at least you have the 2013 year to close the gaps.

For additional resources, visit and checkout their Worry Free™ Program that takes away the hassle and gives you a worry-free way to achieving meaningful use and get your EHR incentive payments.

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