MU Objectives and Measures, by Stage
Bold = Core; Non-bold = Menu
Red = Change to Stage 1 Criteria
Health
Outcomes
Policy
Priority
General
•
Program
Requirements,
Advancements
and Changes
Stage 1 Final
Eligible Providers
Meet or qualify for •
exclusion to 15 core
objectives and 5 of
10 menu objectives.
An EP could reduce
by the number of
exclusions
applicable the
number of menu set
objectives they
must meet. I.e.: an
EP that has an
exclusion for a
menu objective only
must meet 4 of the
9 non-excluded
menu objectives.
Hospitals
Stage 2 Final
Eligible Providers
Analysis
Hospitals
• Delay Stage 2 till 2014 •
Meet or qualify for an • Delay Stage 2 till 2014
exclusion to 14 core
objectives and 5 of 10 • 3 month EHR reporting
• 3 month EHR reporting
menu objectives.
period for providers
period for providers
attesting to stage 1 or 2 •
attesting to stage 1 or 2 in
in 2014; future years 12
2014; future years 12 mo
mo reporting period for
reporting period for those
those not in initial year
not in initial year
• Stage 3 to be
implemented on time
(2016)
• Stage 3 to be
implemented on time
(2016)
• Core and menu set
• Core and menu set
maintained; must meet
maintained; must meet or
or qualify for an
qualify for an exclusion to
exclusion to 16 core
17 core objectives and 3
objectives and 3 of 6
of 6 menu items
menu items
• Qualifying for an exclusion •
no longer reduces the
number of menu
objectives a provider must
meet
1
Qualifying for an
exclusion no longer
reduces the number of
menu objectives a
provider must meet
•
Overall, this rule is very strong, with key
benefits for consumers, even with a delay of
Stage 2.
Stage 3 should proceed as scheduled, and
future reporting periods should be12 months,
rather than the 3 month reporting period for
early attesters.
Patients and consumers will benefit from the
closing of a major loophole that allowed
providers to reduce the number of criteria
they had to meet in Stage 1 by qualifying for
exclusions.
Health
Outcomes
Policy
Priority
Stage 1 Final
Eligible Providers
Improve
•
quality, safety,
efficiency, and
reduce health
disparities
•
Hospitals
Stage 2 Final
Eligible Providers
Use CPOE for 30% • Use CPOE for
of unique patients’
medication, labs, and
med orders
radiology orders
Use CPOE for 30%
of unique patients’
med orders
Analysis
Hospitals
• Use CPOE for
medication, labs, and
radiology orders
Implement one
clinical decision
rule relevant to
specialty or high
clinical priority
•
Implement one
clinical decision
rule relevant to
specialty or high
clinical priority
• Implement 5 CDS
• Implement 5 CDS
interventions related to
interventions related to
4 or more CQMs
4 or more CQMs
•
Implement drugdrug and drugallergy checks
•
Implement drugdrug and drugallergy checks
• Enable and implement • Enable and implement
•
functionality for
functionality for
drug/drug and
drug/drug and
drug/allergy interaction
drug/allergy interaction
checks for the entire
checks for the entire
EHR reporting period
EHR reporting period
•
Implement drugformulary checks
•
Implement drugformulary checks
•
Generate and
transmit 40% of
permissible
prescriptions
electronically
(eRx)
•
N/A
• More than 50% of all
permissible
prescriptions are
generated and
transmitted
electronically and
queried for a drug
formulary
•
•
•
Record
demographics
(RELG and DOB)
for 50% of unique
patients
2011-2013: Record •
2
• The lack of any appreciable advancement in
the use of health IT to reduce disparities is a
major shortfall. While the increase in threshold
is positive, without a requirement to actually
USE this data, the actual impact on disparities
will be minimal.
N/A
• There are many missed opportunities to
increase health equity in this final rule,
including:
•
• More than 80% of
Record
demographics
unique patients have the
(RELG, DOB, and
following demographics
date/preliminary
recorded:
cause of death in
the event of
Preferred language
mortality) for 50%
Sex
of unique patients
Race
Ethnicity
Date of birth
Date and prelim
cause of death (EH
only)
2011-2013: Record • Record and chart
vital signs for 50%
changes in vital signs
Drug/drug and drug/allergy checks have
significant safety benefits for patients, so the
requirement that these be implemented for the
entire reporting period will significantly benefit
patients.
More than 80% of
unique patients have
the following
demographics
recorded:
-
-
Preferred language
Sex
Race
Ethnicity
Date of birth
Date and prelim
cause of death (EH
only)
• Record and chart
changes in vital signs
-
Using more granular standards for
collecting demographic information
Collection of additional demographic
information (disability status and SOGI)
Stratification of lists of patients generated
by condition
Stratification of quality metrics
Health
Outcomes
Policy
Priority
Stage 1 Final
Eligible Providers
Hospitals
vital signs for 50%
of patients age 2
and over: height,
weight, BP, BMI,
growth charts.
2014: Record BP
for 50% of patients
age 3 and over,
and height/weight
for 50% of all
patients.
of patients age 2
and over: height,
weight, BP, BMI,
growth charts.
2014: Record BP
for 50% of patients
age 3 and over, and
height/weight for
50% of all patients.
•
•
Record smoking
status for 50% of
patients 13 yo and
older
•
Incorporate 40% of
lab-test results
ordered into EHR
as structured data
•
Generate at least 1
report listing
patients with
specific condition
[Note: states may
elect to make this a
core criteria]
N/A
•
80% of patients
Eligible Providers
Hospitals
for more than 80% of
unique patients
Height/length
Weight
BP
BMI
Growth charts
for more than 80% of
unique patients
Height/length
Weight
BP
BMI
Growth charts
•
Incorporate 40% of • More than 55% of all
clinical lab test results
lab-test results
incorporated as
ordered into EHR as
structured data
structured data
•
Generate at least 1 • Generate at least 1
report by specific
report listing patients
condition
with specific
condition [Note:
states may elect to
make this a core
criteria]
20% of patients
aged 65 and older
or 5 years and
younger were sent
a reminder, per
patient preference
•
80% of patients
have at least one
• More than 50% of all
unique patients 65 yo or
older have advance
directive status recorded
as structured data
• Subsumed into Summary • Subsumed into
Summary of Care
of Care Document
3
Availability of electronic lab data is critical to
the ability of patients managing chronic
illnesses and their caregivers to be
successful with self-care.
• More than 55% of all
clinical lab test results • Elimination of the age restrictions for reminders
incorporated as
is a significant improvement over Stage 1.
structured data
Given the wider range of individuals that will be
impacted by this revision, the reduction of the
threshold to 10% is still likely to result in
• Generate at least 1
greater numbers of individuals receiving
report by specific
reminders for key elements of care .
condition
• More than 10% of all
• N/A
unique patients having 2
or more visits w/in 24
mos prior to reporting
period sent reminder,
per pt preference
• 50% of patients 65
• N/A
years and older have
an indication of an
advance directive
recorded
•
Analysis
• Record smoking status • Record smoking status
Record smoking
for more than 80% of all
for more than 80% of •
status for 50% of
unique patients 13 yo
all unique patients 13
patients 13 yo and
and older
yo and older
older
N/A
•
Stage 2 Final
• Advance directives provide critical information
about an individual’s personal desires for his or
her health care, yet this criterion was not
advanced in any way. At a time when all agree
that care must be better coordinated and
patient-centered, and that patients must take a
more active role in their care, it is a major
weakness that such an established and widelyaccepted method of achieving these goals
remains optional.
• The inclusion of family health history as a
menu item is a very positive addition that both
provides important longitudinal information and
opportunity for inclusion of patient generated
data in the EHR.
Health
Outcomes
Policy
Priority
Stage 1 Final
Eligible Providers
Hospitals
have at least one
entry in a problem
list or an
indication that no
problems are
known
•
80% of all patients
have at least one
entry into a med
list or an
indication that the
patient is not
currently
prescribed any
medication
•
80% of all patients
have at least one
entry into a med
allergy list or an
indication that the
patient does not
have any med
allergies
Stage 2 Final
Eligible Providers
entry in a problem
list or an indication
that no problems
are known
Analysis
Hospitals
Document
•
80% of all patients • Subsumed into Summary • Subsumed into
have at least one
Summary of Care
of Care Document
entry into a med list
Document
or an indication
that the patient is
not currently
prescribed any
medication
•
80% of all patients • Subsumed into Summary • Subsumed into
have at least one
Summary of Care
of Care Document
entry into a med
Document
allergy list or an
indication that the • N/A
• More than 10% of
patient does not
medication orders
have any med
have all doses tracked
allergies
using eMAR
• More than 10% of all
imaging test results
accessible through
CEHRT
• More than 10% of all
imaging test results
accessible through
CEHRT
• More than 20% of all
• More than 20% of all
unique patients have a
unique patients have a
structured data entry for
structured data entry for
family health history (1
family health history (1 or
st
st
or more 1 degree
more 1 degree relatives)
relatives)
• N/A
• More than 10% of
hospital d/c meds
queried for
drug/formulary and
transmitted electronically
• More than 30% of unique • More than 30% of
4
•
Though menu, the addition of a criteria
focused on accessing images
electronically is an important step that
will help decrease costs in the form of
repeat tests. Avoiding repeat tests also
improves safety and convenience for
patients.
Health
Outcomes
Policy
Priority
Stage 1 Final
Eligible Providers
Hospitals
Stage 2 Final
Eligible Providers
patients have at least 1
electronic progress note
created, edited and
signed; must be text
searchable
Analysis
Hospitals
unique patients have at
least 1 electronic
progress note created,
edited and signed; must
be text searchable
• N/A
Engage
patients and
families
•
•
•
2011-2013: 10% of •
patients have
timely electronic
access to their
health information
within 4 business
days. 2014: 50% of
all patients are
provided online
access to their
health information,
subject to EP’s
discretion to
withhold certain
info
• Results of at least 20%
of electronic lab orders
received are sent to
ordering provider
•
50%
of
all
patients
are
•
50% of all patients are •
2011-2013: N/A.
provided online access
provided online access
2014: 50% of all
(within 4 business days)
to their health
patients are provided
information, within 36
to their health
online access to their
hrs of d/c
information, subject to
health information,
EP’s discretion to
within 36 hrs of d/c
withhold certain info.
•
• 5% of all patients view, • 5% of all patients view,
download, or transmit
download, or transmit
rd
rd
their health info to a 3
their health info to a 3
party
party
2011-2013: 50% of •
patients receive
electronic copy of
their health
information, upon
request. 2014:
Requirement
eliminated.
2011-2013: 50% of
patients receive
electronic copy of
their health
information, upon
request. 2014:
Requirement
eliminated.
50% of all office •
visits result in
clinical summary
being provided to
patients within 3
days
N/A
• 10% of patients are • 10% of patients are
provided patientprovided patientspecific education
specific education
• Clinical summaries
• N/A
provided to patients (or
patient-authorized
representatives) within 1
business day for 50% of
office visits.
• Patient-specific
• More than 10% of all
education resources are
unique patients are
provided to patients for
provided patient-
5
Inclusion of the View/Download/Transmit
criterion in both the EH and EP settings will
result in greater numbers of patients having
the information they need to engage in and
coordinate their care, make better informed
health care decisions, and live healthier lives.
CMS rightly holds providers accountable for
their role in patient engagement with the low
requirement that 5% of patients actually use
the V/D/T function once in a year. This will
incentivize providers to have a conversation
with their patients about how they can access
and use their health information, a key factor
in whether or not patients choose to access
their information when such access is
available. Data show that if implemented
well, about half of patients will use this
feature 3 times a year or more.
•
Secure messaging is extremely beneficial to
patients and their caregivers, due to its
potential impact on improving communication
and subsequent improvements in care and
reductions in cost. It is also a critical
component of information exchange.
•
Future stages of MU should require providers
to collect patient preferences for
communication (purpose and type), since
some patients prefer different communication
media for different purposes (e.g. mail bills
but email appointment reminders).
•
CMS missed another opportunity to address
Health
Outcomes
Policy
Priority
Stage 1 Final
Eligible Providers
resources, if
appropriate
Improve care •
coordination
2011-2012:
•
Conduct one test
of capability to
exchange key
clinical
information. 2013:
Requirement
eliminated.
•
A summary of care •
record is provided
to receiving
provider for 50% of
all
referrals/transfers
Hospitals
resources, if
appropriate
Stage 2 Final
Eligible Providers
more than 10% of all
office visits.
Analysis
Hospitals
specific education
resources
• 5% of all unique patients • N/A
(or their authorized
representative) seen
during reporting period
send a secure message
using electronic
messaging
2011-2012: Conduct • Summary of care
• Summary of care
•
record, including care
record, including care
one test of
capability to
plan and care team
plan and care team
exchange key
members, provided for
members, provided for
clinical information.
50% of transitions of
50% of transitions of
2013: Requirement
care and referrals
care and referrals
eliminated
• Summary of care record • Summary of care
record provided
provided electronically
•
electronically for more
for more than 10% of
A summary of care
than 10% of
transitions and referrals
record is provided to
transitions and
receiving provider for
referrals
50% of all
referrals/transfers
• One or more successful • One or more
•
successful electronic
electronic exchanges of
exchanges of
summary of care
summary of care
document with recipient
document with
who has technology
•
designed by a different
recipient who has
technology designed
developer than sender
OR one or more
by a different
successful tests with
developer than sender
the CMS designated
OR one or more
successful tests with
test EHR
the CMS designated
test EHR
• Med rec is
• Med rec is performed • Med rec is performed for • Med rec is performed
performed for 50%
for 50% of transitions
50% of transitions of
for 50% of transitions
of transitions of care
of care
care by receiving
of care by receiving
provider.
provider.
6
•
disparities through MU 2 by failing to require
providers to use language data they are
already collecting to provide educational
materials in a language their patients
understand.
Removal of the “test of exchange” from Stage
1 without replacing it with any requirement for
information exchange is puzzling. While
there is wide agreement that the test, as
written in Stage 1 was not useful, this leaves
Stage 1 without any requirement for
exchange of information.
For Stage 2, CMS has finalized a critical
advancement in care coordination and
exchange of information by requiring the
Summary of Care document to be exchanged
electronically 10% of the time.
For Stage 3, and in all future stages, the
threshold for electronic exchange of SOC
documents should increase significantly.
Requiring one or more successful electronic
exchanges of summary of care documents
with a recipient who has technology designed
by a different developer than the sender
presents a critical opportunity to begin
electronic exchange with non-MU providers
(ie: SNFs and HHAs). CMS should consider
opportunities to encourage this exchange
through the Medicare SSP and Pioneer ACO
programs.
The required content of the Summary of Care
Document is very strong, and the inclusion of
functional status will not only provide vital
information for patient-centered care, but also
provides a foundation for patient reported
Health
Outcomes
Policy
Priority
Stage 1 Final
Eligible Providers
Hospitals
Stage 2 Final
Eligible Providers
Analysis
Hospitals
measures.
•
Improve
population
and public
health
Successful, ongoing • Submission of data to public health agencies
submission to an
and specialized registries is an important new
immunization registry
way that the final rule advances health
or immunization
information exchange.
information system for
the entire reporting
• The submission of case information to
period
specialized registries is an important step
toward using EHRs more effectively to
• Successful ongoing
• N/A
measure and improve quality on the population
• Perform one test of • N/A
submission of
capability to provide
level. Registries will likely be an important
electronic reportable
electronic submission
future data source for the kinds of quality
lab results from
of reportable lab
measures that are most meaningful and useful
CEHRT to public health to consumers,
results to PHAs and
agencies for the entire
follow-up submission
reporting period
if successful
• Population health is an integral part of
achieving the goals of the National Quality
• Successful ongoing
• Perform one test of • Perform one test of • Successful ongoing
Strategy, and population health data is
submission of
capability to provide
capability to provide
submission of electronic
absolutely essential for supporting new
electronic syndromic
electronic syndromic
electronic syndromic
syndromic surveillance
payment models, making submission of data to
surveillance data from
surveillance data to
data from CEHRT to a
surveillance data to
public health agencies and specialized
CEHRT to a public
public health agency for
registries a much needed foundational step
public health
PHAs and follow-up
health agency for the
submission if test is
the entire reporting period
toward building a health IT infrastructure that
agencies (PHAs)
entire reporting period
supports reform.
and follow-up
successful
submission if test is
successful
• Successful ongoing
• N/A
submission of cancer case
information from CEHRT
to a public health agency
for the entire reporting
period
• Perform one test of •
capability to submit
electronic data to
immunization
registries and followup submission if
successful
•
Perform one test of • Successful, ongoing
submission to an
capability to submit
immunization registry or
electronic data to
immunization
immunization
information system for
registries and followthe entire reporting
up submission if
period
successful
While SOC document required content is very
strong, CMS missed a critical opportunity to
require documentation of a patient’s
caregiver. Documentation of caregiver name
and contact information is critical for
improving coordination of care, given that
currently, family caregivers are the most
active coordinators of care, and will continue
to play a critical role in safe, effective
transitions when there is a better established
method of coordinating care within the health
care system itself.
7
Health
Outcomes
Policy
Priority
Stage 1 Final
Eligible Providers
Stage 2 Final
Hospitals
Eligible Providers
Analysis
Hospitals
• N/A
• Successful ongoing
submission of specific
case information from
CEHRT to a specialized
registry for the entire
reporting period
Ensure
• Conduct or review • Conduct or review a • Conduct or review a
• Conduct or review a • The emphasis on encryption is a positive step
adequate
a security risk
security risk
security risk analysis,
security risk analysis,
in a multi-faceted approach to privacy and
privacy and
analysis and
analysis and
including addressing
including addressing
security in health IT.
security
implement security
implement security
the encryption/security
the
protections for
updates as
updates as
of stored data;
encryption/security of
personal
necessary and
necessary and
implement security
stored data;
health
correct identified
correct identified
updates as necessary
implement security
information
security
security
and correct security
updates as necessary
deficiencies
deficiencies
deficiencies identified
and correct security
in the security risk
deficiencies identified
analysis
in the security risk
analysis
Clinical
Quality
Measure
Submission
• 2011-2012: Report • 2011-2012: Report •
clinical quality
clinical quality
measures to CMS.
measures to CMS.
2013: Objective
2013: Objective
incorporated
incorporated
directly into
directly into
•
definition of a
definition of a
meaningful EHR
meaningful EHR
user and
user and eliminated
eliminated from
from functional
•
functional criteria
criteria list
list
• Report 6 CQMs
• Report 15 CQMs
•
For CY 2013: report 3
core or alternate core
measures and 3 menu
measures
•
For FY 2013: report all •
15 CQMs finalized for
Stage 1
For CY 2014: report 9
CQMs in at least 3
domains, OR
•
For FY 2014: report 16
CQMs in at least 3
•
domains
Submit and
satisfactorily report
PQRS measures (must
comply with changes to
PQRS program)
Case number threshold •
instituted – 5 cases per
quarter or 20 cases per
year, consistent with
Medicare hospital
public reporting
program
8
•
Case number
threshold instituted –
5 cases per quarter or
20 cases per year,
consistent with
•
Medicare hospital
public reporting
program
The adoption of the six domains and
requirement that providers submit quality data
for measures in at least half of the domains is
a significant improvement in the approach to
CQM submission in Stage 2.
The measure sets remain marginal in their
usefulness, and serious gaps remain unfilled
in areas of critical importance to new
payment and delivery models.
The EHR Incentive Program – which contains
no requirement for actual performance on
quality metrics – should be used both to
improve the collection and reporting of
existing quality metrics when they are
meaningful and useful AND to test measures
that could potentially fill measurement gaps.
Alignment of MU with PQRS creates a
significant need to evaluate and improve the
PQRS reporting program.
Health
Outcomes
Policy
Priority
Relevant ONC •
Standards and •
Certification •
Rule
•
Components
Stage 1 Final
Eligible Providers
Stage 2 Final
Hospitals
Eligible Providers
•
Patient population
•
designated as sampling
– all payer
•
Group reporting
finalized as an option;
EPs must still meet
functional criteria
individually; Medicare
SSP and Pioneer ACO
programs satisfy if
using CEHRT to submit
CQMs; if meeting
requirement through
PQRS, only need to
meet reporting
requirement as
individual in the first
year of MU
Patient ability to amend record
Patient communication preferences
Caregiver name and contact information
Demographic data
Analysis
Hospitals
Patient population
designated as
sampling – all payer
•
•
•
•
Included in Final ONC Rule
Included in final ONC Rule
Not specified
Not specified beyond RELG
For questions about this document or for more information about the National Partnership’s Consumer Health IT Program, please contact Eva
Powell at [email protected] or at (202) 986-2600.
9