Annals of Health Law
READY OR NOT
meeting standards of interoperability, clinical functionality and security as
required by each of three successive “stages” of MU. 153 Starting in 2011,
hospitals that met the definition of MU for their EHR became eligible for
bonus payments. 154 Beginning in 2015, failing to meet MU will bring
reductions in the annual IPPS market basket update. 155
The EHR Incentive Program structure is remarkably similar to the VBP
include: 1) use of a certified EHR in a meaningful manner, such as e-prescribing; 2) use of
certified EHR technology for electronic exchange of health information to improve quality
of health care; and 3) use of certified EHR technology to submit clinical quality and other
measures. See Meaningful Use, CENTERS FOR MEDICARE & MEDICAID SERVICES,
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/
Meaningful_Use.html. To satisfy MU Stage 1, hospitals are required to meet fifteen core
objectives (one of which includes an objective to submit fifteen quality measures for stroke,
VTE and ED using eMeasures) as well as five out of ten menu objectives; to move to Stage 2
they must meet sixteen core objectives (including reporting on twenty-four quality measures)
and two out of four menu objectives. See generally Bryn Hunt & Claire Turcotte, CMS
Proposes Aggressive Stage 2 Meaningful Use, BRICKER & ECKLER (2012), available at
http://www.bricker.com/publications-and-resources/publications-and-resources-
details.aspx?publicationid=2390; Brenda Pawlak & Sandra Newman, A Closer Look at the
Stage 2 Meaningful Use Proposed Rule, IHEALTHBEAT (2012), available at
http://www.ihealthbeat.org/features/2012/a-closer-look-at-the-stage-2-meaningful-use-
proposed-rule.aspx#ixzzlpCH36ggZ (discussing MU Stage requirements).
