One of the greatest challenges in Meaningful Use Stage 2 will be the health information exchange and related transitions-of-care requirements. So many organizations have had trouble with the Stage 1 requirement that they test their ability to trade key clinical data with other providers that the Centers for Medicare & Medicaid Services (CMS) dropped that criterion. But in Stage 2, providers will have to go beyond testing and actually exchange the information, noted CMS officials in a session at last week's Healthcare Information and Management Systems Society's (HIMSS) conference in Las Vegas.
Under the proposals CMS has made for the Stage 2 core requirements, hospitals and eligible professionals (EPs) will have to provide a specified summary of care record for more than 65 percent of transitions of care and referrals. In more than 10 percent of those transitions and referrals, providers must send data to unrelated business entities that use a different electronic health record than the sender does.
EPs must provide online access to health information to at least half of their patients within four business days of being seen. Hospitals must give 50 percent of patients access to data about an ED visit or hospitalization within 36 hours of discharge. More than 10 percent of patients seen by EPs or discharged from hospitals or EDs during the reporting period must "view, download or transmit to a third party" their health information. Some observers think that last requirement will be hard to meet because it depends on the willingness of patients to view or transmit the data.
EPs must use their EHRs to provide clinical summaries to patients within 24 hours of being seen for more than half of office visits. And they must send preventive care reminders to 10 percent of patients, although not necessarily online.
Both hospitals and EPs will have to perform medication reconciliation during 65 percent of transitions of care, both to the hospital or ED and back to the physician.
In Stage 2, sending data to immunization registries becomes a core requirement. (In Stage 1, testing the ability to submit this data was on the optional menu.) On the Stage 2 menu is the submission of information to cancer and other specialized registries. Reporting of syndromic surveillance and reportable lab data remains on the menu, but moves forward from testing to actual submission of data.
Enterprise health information exchanges (HIEs), which are rapidly growing across the country, should enable healthcare organizations to meet some of these requirements. But others, such as the exchange of data across business boundaries and the submission of data to registries, probably will require the use of public HIEs that are still missing in many areas.
Of course, providers won't have to meet the Stage 2 criteria until 2014. But it's anyone's guess whether regional and state HIEs will be able to fill the gaps by then.
To learn more:
- see the NPRM for Meaningful Use Stage 2 (.pdf)