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:
Highlights
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:
Robert Hitchcock, M.D., FACEP, is T-System’s vice president and CMIO, leading the company efforts for solving regulatory issues and identifying trends. He is a nationally recognized meaningful use expert and active member of the HIMSS Physician Committee and other HIMSS subcommittees advocating usability and responding to regulatory issues.
Dr. Hitchcock also is a practicing ED physician and an Emergency Department Practice Management Association (EDPMA) board member. In 2001, he earned recognition for excellence in teaching from internal medicine residents, and in the early 2000s, he trained basic and advanced life-support EMS providers. His goal is to advance system adoption and usability to improve the quality and efficiency of ED delivery.
Here, he provides perspective about developments of meaningful use Stage 2 and Stage, how meaningful use is impacting vendors and practices, how they feel — or should feel — about it, and what Stage 3 means for everyone in the industry.
How do you see the market responding to meaningful use? How are physicians moving forward, or beyond, it?
The market’s overall response to meaningful use is generally clear: they’re pushing back, particularly on Stage 2. Vendors aren’t ready, so there are not as many certified products out there. Physicians and hospitals are both calling for delays. By some estimates, as many as 50 to 70 percent of physicians who were successful in Stage 1 will not be successful in Stage 2.
To give some perspective, the Eisenhower interstate system was authorized and construction began in 1956. Phase 1 was completed in 1992. It took 35 years to build roads in this country, a decidedly low-tech undertaking. With meaningful use, we’re attempting to take a relatively un-automated industry and automate it beyond what was ever considered possible in six years. Everyone is pushing back because it’s simply too much, too fast.
Help me understand, if you will, where the soul of meaningful use lies. I’ve seen the rules that have been made final and I’ve heard the stories of folks in the field that have had their lives and practices changed because of it.
But all of this just doesn’t seem to lead to a very innovative end.
Sure, the technology is needed in healthcare as the antiquated use of paper continues to overwhelm, but what’s the real proposition here? As far as I’m concerned, some of the real questions remain unanswered, and I am slightly suspicious as to why the feds are so heavily involved.
Granted, I shouldn’t be surprised given all the money that’s been spent in numerous non-government areas (like cars, banking and solar), but let’s peel back here a little and ask why the industry really needs the incentives. Let’s agree that on its own, the healthcare industry would have adopted the technology and was doing so; the incentives just moved adoption along much more quickly. So, why are the feds involved? Agree with me or not, they want our data.
This is the coup d’état. Collected data leads to predictive analysis and evidence-based treatment protocols. This leads to the dissolution of independent care protocols and removes independent will and turns healthcare into committee care.
Getting care is going to be similar to applying to government grants and scholarships. I’m oversimplifying the matter here, but please, let’s admit that there is a price that’s going to be paid for the federal incentives.
That said, my soap boxing out of the way, I’m back to my original question: Where is the soul of meaningful use?
Let’s take a look at the upcoming Stage 3. In large part it’s a lot of increased measures and new “patient engagement” provisions such as: giving patient the opportunity to request amendments to their records online, requiring electronic health records to receive, generate or access appropriate immunization recommendations, and requiring EHRs to be able to query other entities for outside records.
(Yawn.) (Wipe my eyes.)
These are valiant efforts and worthy of exploring, certainly. But, where is the real innovation that we’re supposed to be seeking? Where’s the game-changing approach to healthcare information that blows our minds? This is a technology based process after all and I think we need to begin demanding more of the technology we employ.
The technology is not holding us back, either. It’s us and our continually lowered expectations. If we’re going to take some risks then those risks need to be real risks and not some marketing speak for a data grab slight of hand.
From my perspective, about 90 percent of the technology vendors in the space do just enough and nothing more. Their investments are in sales teams, not in research and development.
But how can you blame them when the one leading body of the mandated changes is asking so little of the community.
What this is beginning to feel like a bunch of self-appointed “decision” makers trying to affect change of a program that’s been in place for decades, in the end, no matter the tinkering, may be nothing but waste having been accomplished.
