The most confusing element of Stage 2 Meaningful use Final Rule has to do with a 'mandatory' requirement for patients to access their records online. In stage 1, the objective was the following:
Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies), upon request.
The key here is 'upon request'. In my experience, I have not a single instance where patients have requested an electronic copy of their health information.
Stage 2 objective now states the following:
Provide patients the ability to view online, download and transmit their health information within four business days of the information being available to the EP.
If you notice here, the words 'upon request' have been eliminated. Let's examine and dissect what the Stage 2 Measure states. The measure is split in two parts:
- More than 50% of all unique patients seen by the EP during the EHR reporting period are provided timely (available to the patient within 4 business days after the information is available to the EP) online access to their health information.
- More than 5% of all unique patients seen by the EP during the EHR reporting period (or their authorized 4 representatives) view, download, or transmit to a third party their health information.
This Measure will be left to individual interpretation by both the certifying authority as well as the EHR Vendor. Every vendor has a unique way of presenting information and the implementation will vary. It will be easiest for vendors that have an integrated Patient Portal system. This way, the entire measure can be 'automated' without requiring the provider to do anything at all.
The second part of this measure will be tricky. How do you require and ensure that at least 5% patients view, download, or transmit to a third party their health information? What if your patient population does not have online access? Who can be defined as a 'third party'?
The first bit of clarification may come from the certifying authorities. In any case, seek out clarification from your vendor.