Guest post by Dr. Seth Flam, CEO, HealthFusion.
The proposed rule for meaningful use Stage 3 was announced on Friday, March 20, 2015, and is now available for comment by stakeholders. Here are five highlights of the Stage 3 proposed rule and what I see as three provider wins:
- 2017 is now a Flex Year– Meaningful use Stage 3 was originally slated to begin in 2017 for providers that had completed Stage 2; now 2017 is a flex year. This means that providers who would have progressed from Stage 2 to Stage 3 in 2017 now have the option to stay in Stage 2 an additional year. Only providers who use an EHR certified to the 2015 ONC standards will be allowed to attest to Stage 3.
- Every provider will be Meaningful Use Stage 3 in 2018 even if 2018 is the provider’s first reporting year – In order to simplify the meaningful use program, all providers will be in the same stage. This will allow group practices to focus on a single set of measures for all providers.
- Meaningful Use Stage 3 is the final stage of meaningful use– However, CMS is clear that because it expects technology and care standards to evolve over time it will consider (and we expect) that there will be future rulemaking related to meaningful use Stage 3 somewhere down the line.
- All providers will report for one calendar year – in an effort to continue to align meaningful use with other government reporting programs such as PQRS, all providers will report for a full year based on the calendar with one exception. Medicaid first year providers will still be allowed to report based on a 90-day period measurement period. In the past CMS has shortened measurement periods based on provider feedback and we expect that to be true about this year. This year (2015) was slated to be a full year for most providers, but we expect it to be scaled back to a quarterly measurement period because of the continued side effects of the poor implementation of Stage 2 last year. For 2017 and beyond, we expect the implementation will be smoother and we don’t foresee more flexibility on measurement periods beginning next year.
- There are eight objectives and some objectives have more than one measure – the total number of measures that providers will be required to report is 16.
Wins for Providers in the Meaningful Use Stage 2 Proposed Rule
I see three wins for providers in the meaningful use Stage 3 Rule, including:
- Data Portability – Providers have been struggling to migrate from their old EHR to a more modern one. Providers using old client server applications want to move to the cloud. In addition, there have been many EHR systems that have had trouble keeping up with new regulations and standards. Certain EHRs have not made the commitment to transform their applications such that users can perform comprehensive charting on mobile tablets. Because of the failure of older legacy EHRs to “keep up with the times,” 30 percent to 40 percent of practices want to switch EHRs.
Today the cost and hassle of data migration makes switching untenable for many practices. In the Stage 2 rule, the Office of the National Coordinator (ONC) started to require that certified EHRs include certain data portability features. There were two major obstacles relating to data portability in Stage 2; the first is that some EHRs have hidden the data export feature mandated by the ONC (we have witnessed this) and the second is that those data export specifications were not comprehensive enough to meet the needs of a functional data migration.
In the new rule, the ONC has responded to provider concerns relating to data portability and they have expanded the type of data included in the data portability requirements. Now the ONC would also require that export summaries be able to be created according to any of the following document-template types:
- Consultation Note
- History and Physical
- Progress Note
- Care Plan
- Transfer Summary
- Referral Note
- Discharge Summary
The ONC does not speak to the ability to export in bulk scanned images in a uniform format, and, therefore, we expect that data migration per the new proposed standard will be helpful but not make EHR switching completely hassle free.
- Enhanced ePrescribing– Perhaps one of the most broadly adopted features of EHRs is the ability to prescribe electronically. In fact, according to CMS providers report that they prescribe around 90 percent of all permissible prescriptions electronically. The ONC has proposed adding more features to ePrescribing that we think will further enhance the ePrescribing experience and improve the quality of care.
These proposed enhancements include:
- Change Prescription
- Refill Prescription
- Cancel Prescription
- Fill Status
- Medication History messages
As an example, the Fill Status message could positively impact the quality of care because it will offer physicians a method to know whether a patient has filled a drug that might be crucial to the treatment of a life-threatening disease.
- Standards for Sharing Direct Messaging Provider Directories – In Stage 2 the ONC required that vendors support “Direct,” a protocol for the exchange of secure email. This was to be the replacement for the fax machine and, we hoped, a time- and paper-saver. The implementation of Direct has not worked as originally planned (see this previous blog post on the problems with Direct Messaging) and the proof is that the Stage 2 Transition of Care measure that depended on the use of Direct was specifically addressed and relaxed in the September 2014 flexibility rule.
Part of the reason for poor adoption was the lack of a consistent standard for the sharing of provider directories for “look up” of provider Direct addresses in a practices’ referral network. The proposed rule will require that EHRs have the capability to exchange directories such that they have the ability for:
- Querying for an individual provider
- Querying for an organizational provider
- Querying for both individual and organizational provider in a single query
- Querying for relationships between individual and organizational providers
This new standard should make Direct more effective and simplify the exchange of medical records between providers. We encourage CMS to continue to offer flexibility with regard to Direct between now and when these new standards are incorporated into EHR technology by 2018.
When meaningful use began, physicians were happy about the large incentives and there were no penalties. Now many physicians view meaningful use as a burden. These three proposed standards may prove to reduce the burden for many providers and we believe they should be included in the final rule.
Dr. Seth Flam is one of the founders of HealthFusion and serves as the company’s CEO and President. He is board certified in family practice. He blogs regularly on healthcare issues on the HealthFusion blog.