As the comment period has come and gone (ended May 29, 2015) for meaningful use Stage 3, and as multiple organizations, like CHIME, and countless other individuals have taken the time to comment on the final rule, I thought it was a good time to ask the question: Does the meaningful use Stage 3 rule sail or sink?
Procuring responses to this question from a number of health IT insiders helps to identify some of the most pressing issues with the final stage of meaningful use, a topic that is almost second to none in regard to generating support or opposition from those in the sector.
The College of Healthcare Information Management Executives, in its comments on the rule, called federal plans for the third stage of meaningful use too ambitious and in need of several important changes, but still offered their support for a corresponding CMS proposal that would shorten meaningful use reporting in 2015 from a full year to any continuous 90-day period. In total, CHIME said meaningful use Stage 3 is “unworkable.”
“Were all requirements finalized as proposed, we doubt many providers could participate in 2018 successfully,” CHIME said. “And with so few providers having demonstrated Stage 2 capabilities, we question the underlying feasibility of many requirements and question the logic of building on deficient measures.”
Bennett Lauber, chief experience officer, at The Usability People offered a slightly different take: “The MU3 program contains some well-needed enhancements to the Safety-enhanced design portion of the 2015 certification criteria. They have also proposed significant changes to the Safety-enhanced Design (aka usability) testing requirements. These new requirements might seem burdensome to some of the smaller EHR vendors, as they require 17 and not seven items to be usability tested and finally set a minimum number of participants for these studies and more. With everyone complaining about the (lack of) usability of healthcare software these additional requirements should be welcome as they force the vendors to perform real summative usability tests and as a result it eventually might actually save lives.
David Muntz, former principal deputy director of the ONC and current CIO of GetWellNetwork adds, “Getting to a common stage is a good thing, but there is still some concern expressed by those who are struggling with the move from Stage 1 and Stage 2 to the future state. The limit on adding new elements is a positive, though some of the thresholds that need to be met will be a concern to many, particularly those that require a provider to affect behaviors in the patients. Standardizing quality measures and adjusting the reporting period are good moves, but the possibility of requiring all vendors to have a complete set will delay release dates.
“The encouragement to add APIs for data exchange is a positive. More thought, however, is needed to the areas where open APIs can prove beneficial. Secure messaging is great, but the threshold for usage is really based on patient preference and may be a bit aggressive. The greatest disappointment was the continued use of specific features and functions without an alternative to deem features and functions based on a combination of appropriate process and outcome measures. A deeming approach would have given the users a great deal of latitude in how to implement features and functions that would have produced favorable outcome.”