Meaningful Use Stage 3: A Glimpse behind the Curtain

After much speculation about what would be included, the proposed rules for Stage 3 of Meaningful Use have been released. We are not through the woods yet when it comes to knowing exactly what the final rules of Stage 3 of Meaningful Use will look like, as these are just proposed rules. It’s like we’re getting a glimpse of what’s behind the curtain.

How is CMS planning to “restructure” the EHR incentive program, and did they listen to the feedback that was given from the healthcare community? 

In reading the proposed rules and lifting that curtain just a bit, some of the key takeaways are that CMS has placed some flexibility into the requirements, restructuring has taken place to better align with other programs, and there is increased interoperability to enable better communication between providers and access to more information for improved patient outcomes.

For Stage 3 there are a total of eight objectives and 16 associated measures that EPs will need to attest with to meet Meaningful Use. The table below outlines the objectives for Stage 3, Meaningful Use.

Objective and Measures for Meaningful Use in 2017 and Subsequent Years

Program Goal/Objective	Delivery System Reform Goal Alignment
Protect Patient Health Information	Foundational to Meaningful Use and Certified EHR Technology*Recommended by HIT Policy Committee
Electronic Prescribing (eRx)	Foundational to Meaningful UseNational Quality Strategy Alignment
Clinical Decision Support (CDS)	Foundational to Certified EHR TechnologyRecommended by HIT Policy CommitteeNational Quality Strategy Alignment
Computerized Provider Order Entry (CPOE)	Foundational to Certified EHR TechnologyNational Quality Strategy Alignment
Patient Electronic Access to Health Information	Recommended by HIT Policy CommitteeNational Quality Strategy Alignment
Coordination of Care through Patient Engagement	Recommended by HIT Policy CommitteeNational Quality Strategy Alignment
Health Information Exchange (HIE)	Foundational to Meaningful Use and Certified EHR TechnologyRecommended by HIT Policy CommitteeNational Quality Strategy Alignment
Public Health and Clinical Data Registry Reporting	Recommended by HIT Policy CommitteeNational Quality Strategy Alignment

CMS Provides Select Flexibility
Within the proposed rules there are select objectives that give eligible professional (EPs) flexibility to match select measures to a provider’s specialty. The flexibility that CMS has proposed is that “providers would be required to attest to the results for the numerators and denominators of all measures associated with an objective; however, a provider would only need to meet the thresholds for two of the three associated measures.” Those proposed flexible objectives/measures include the following:

• Objective 6 – Coordination of Care through Patient Engagement
• Measure 1: 25% of patients are provided access to “view online, download, and transmit their health information, or retrieve their health information through an API, within 24 hours of its availability.”
• Measure 2: 35% of patients were sent a secure message with relevant health information for their personal healthcare.
• Measure 3: 15% of patient-generated health data or non-clinical data is incorporated into the EHR.
• Objective 7 – Health Information Exchange (HIE)
• Measure 1: 50% of Transitions of Care would have a Summary of Care record that was electronically exchanged.
• Measure 2: 40% of Transitions of Care of patients that an EP has not seen before a Summary of Care is incorporated “from a source other than the providers EHR system.”
• Measure 3: 80% of Transitions of Care of patients that an EP has not seen before a Clinical Information Reconciliation has been performed, which includes medications, medication allergies, and current problem list.
• Objective 8 – Public Health and Clinical Data Registry Reporting
• Within the objective there are six measures. An EP would need to select from “Measures 1 – 5, and would be required to successfully attest to any combination of three measures.”

Alignment of the EHR Incentive Program
As a way to better align the EHR Incentive program CMS is giving EPs the opportunity to start attesting to Stage 3 objectives/measures starting in 2017. By 2018 all EPs, regardless of their “prior participation in the EHR Incentive Program” will be required to attest to the Stage 3, Meaningful Use objectives/measures. By moving all EPs to the same Stage of Meaningful Use, it will support the goal of CMS to “Align” the EHR Incentive Program with other programs that utilize Certified Electronic Health Record Technology (CEHRT).

Also, CMS is proposing to eliminate the 90-day reporting period to “simplify reporting timelines across all settings.” This would mean that EPs, CAHs, and Hospitals would all be reporting based on a full calendar years’ 365 days, worth of data.

The Goal of Interoperability
Under the Stage 3 proposed rule there are increased requirements for interoperability and communication for providers. One of the goals from Stage 2 was to increase the access and use of healthcare data and sharing across platforms. Stage 3 is building on this groundwork from Stage 2 by not only moving towards more health information being exchanged electronically, but also giving patients easier access to their personal healthcare information and online care tools. One of the proposed tools is an application-program interface (API), which provides more flexibility in giving patients easier access to their personal health information. “If the provider elects to implement an API, the provider would only need to fully enable the API functionality, provide patients with detailed instructions on how to authenticate, and provide supplemental information on available applications that leverage the API.” There is a shift from Stage 2 to Stage 3 that takes the responsibility off the patient to interact with the provider and flips it to the provider to initiate that interaction.

In closing, the proposed rules from CMS are brought down to eight objectives and associated measures that are designed to, “Align with national health care quality improvement efforts, promote interoperability and health information exchange, and focus on the 3-part aim of reducing cost, improving access, and improving quality.”

With all this in mind there is still time to submit comments to CMS on the proposed rules of Stage 3 of Meaningful Use. The comment period will close at the end of this month on May 29, 2015. Then it’s just a matter of waiting for the final rules to be released before we will finally see behind the curtain on the future of Meaningful Use.

For more updates and resources on Meaningful Use, visit the Kareo Meaningful Use Resource Center.