The Meaningful Use Stage 2 Final Rule

Overview and Outlook

On August 23, 2012, the Centers for Medicare and Medicaid Services (CMS) published a final rule on the Stage 2 Meaningful Use criteria that eligible professionals (EPs), eligible hospitals and critical access hospitals (CAHs) must meet to qualify as meaningful users of electronic health records (EHRs) and receive incentive payments under the Medicare and Medicaid programs. This final rule builds upon the Stage 2 proposed rule, released on March 7, 2012. The Stage 2 final rule also revises certain Stage 1 criteria, which were finalized in the July 28, 2010 final rule. Stage 1 of the incentive program, designed to encourage providers to move key clinical data into an electronic format, was focused on establishing the functionalities of a certified EHR system to allow for quality improvement and exchange of health information.

With the final rule, CMS continues its careful, incremental approach to continuing this transitional process and strikes a balance between stakeholders calling for Stage 2 to require demonstrated improvements in care as a result of EHR use and those seeking more flexibility in the rules, with incentives simply to acquire EHR technology. Stage 2 also increases expectations for more robust health information exchange, allowing information to follow the patient through care transitions and referrals.