It seems as if CMS has a magic number of measures that they believe they can market to the provider community as a “fair” amount of requirements to meet CMS Meaningful Use stage 2. It appears that the number they have settled on is 20. In stage 1 of the Meaningful Use program EPs report 15 core measures and 5 menu measures. In stage 2 EPs report 17 core and 3 menu measures, either way it’s 20. Here’s the concern, do 20 measures in stage 1 equal 20 measures in stage 2? The simple answer is no. CMS Meaningful Use stage 2 is marketing 20 measures but they have crammed many more hidden measures within the CMS Meaningful Use stage 2 requirements.
There are several measures that were stage 1 requirements that are no longer listed as distinct measurements in stage 2 but that does not mean that they are no longer required.
- Maintain Allergy List
- Maintain Medication List
- Maintain Problem List
The above captioned stage 1 measures are not included as distinct measures in stage 2, but providers still must continue to maintain those lists in a structured format. They are required in all PHR (Personal Health Record) exports. Exporting personal health records in a format that includes these structured lists is required as part of several measures, therefore these three stage 1 measures are still required but tangentially via newer PHR related measures.
Report ambulatory clinical quality measures to CMS or the States
Reporting CQMs (Clinical Quality Measures) is still a requirement but that measure is no longer listed as distinct measure in stage 2. Remember our thesis, the magic number is 20 and reporting CQMs would make the list too long. Therefore reporting CQMs is required to meet CMS Meaningful Use stage 2 but it is no longer listed as a measure on the Meaningful Use measure list however it is certainly not gone. The new rule basically says that you can’t meet Meaningful Use stage 2 requirements without reporting CQMs.
Implement drug-drug and drug-allergy interaction checks
Still a requirement but no longer a distinct measure, this easy to achieve stage 1 measure has been folded into the clinical decision support measure in stage 2.
Implement drug formulary checks
Also still a requirement but no longer a distinct measure, another easy to achieve stage 1 measure that has been folded into another stage 2 measure. Implementing drug formulary checks in stage 2 is now part of the e-prescribing measure.
Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, test results), among providers of care electronically
This stage 1 measure was ill conceived and CMS finally realized that it really did nothing to advance quality or interoperability, therefore it was deprecated in 2013. In a sense this measure has been folded into the much more comprehensive stage 2 measure “Provides a summary care record for each transition of care or referral”.
When is 20 > 30?
Answer: Meaningful Use stage 2
CMS has clearly crammed more work and certainly more tasks into the 20 stage 2 Meaningful Use measures. In fairness, providers that reported stage 1 for two or three years should now be more proficient with EHR technology and therefore could be held to a “higher standard”. EPs that want to be successful in stage 2 need to pick a vendor that offers a long lead-time to reporting in 2014. They require a vendor that is not struggling to just get their technology certified, but one like MediTouch that is already certified and ready to train their users in 2014 technology today. At MediTouch our focus is not just certification, but usability and we have plenty of time to make sure Meaningful Use in 2014 will not slow our providers down.