Stage 3 of Meaningful Use is expected to be the final stage. It incorporates major portions of prior stages while introducing many new challenges. What else does this 300-page document contain in its fine print?
CureMD investigates to make it simple for you.

The March 20^th announcement of the proposed Meaningful Use Stage 3 rule by the Centers for Medicare & Medicaid Services (CMS) is still being dissected, analyzed, and reanalyzed by healthcare experts. While we can spend our time going through 300-page long documents, physicians might not find it the easiest thing to read. For your convenience, we have compiled a list of things you should know about Meaningful Use stage 3. You can also read the complete proposed rule here.

Remember that CMS is open to public comments and will be taking your feedback before finalizing the rule in the third quarter of this year. This feedback period will end on May 29, 2015.

1. Reporting in 2017 isn’t compulsory – Phew!

Instead of 2017, the compulsion for all providers to report for Stage 3 would be 2018.

In 2017, providers expected to move from Stage 2 to Stage 3 could choose to stay on Stage 2; and make the ‘more convenient’ transition in 2018.

To attest to Stage 3, you will require a 2015 ONC certified EHR.

2. Every provider must attest to Stage 3 in 2018 – No training wheels for New Providers.

Irrespective of your first year of reporting, you will have to attest to MU Stage 3 in 2018. Group practices will benefit from this change as they will have to focus on a single set of measures for everyone.

However, critics are of the view that startup practices or people using the EHR technology for the first time will find it difficult. They will have to adjust their workflows for such advanced level of reporting from the get go.

3. You must report for one whole calendar year unless you are a Medicaid EP – Unfair much?

Starting from 2017, all providers will report according to a full calendar year period. This step is being taken to align MU closer to other CMS quality-reporting initiatives such as the Physician Quality Reporting System (PQRS).

In the past CMS has shortened reporting periods based on provider feedback and would probably do the same this year, due to the poor implementation rates of MU Stage 2. But beyond that, we highly doubt there would be any further flexibility. There will not be a 90-day reporting period for new provider-registrants of the MU program either.

The only exemption, which is garnering a lot of criticism from some quarters, is that Medicaid Eligible Professionals (EPs) and hospitals can report for 90 days in their first year.

We agree with this criticism and think that the playing field should be leveled for all new entrants into the program. We would definitely like to get your feedback on this.

4. Eight specific objectives, but higher thresholds – Interoperability and Patient Engagement returns with a bang.

The number of specific objectives has been reduced to eight so that providers maximize their attention towards the “advanced usage” of EHRs. Patient engagement and interoperability are the areas of maximum focus. Stage 3 will require an excess of 35 % of patients to be sent a secure message via the provider’s EHR, or in response to a secure message sent by the former.

Given the low levels of patient engagement (electronically) at most practices, another addition that many will find difficult to implement, is that more than 25% of the patients who visit an EP (or are discharged by a hospital) must obtain their health information electronically. After this, you might want to read How to Succeed with Patient Portals for Meaningful Use Stage 2?

There is some fine-print though. Contained within many of the objectives are multiple measures.  Depending on which options one chooses, and whether you are a provider or a hospital, the total number of MU measures could range from 15 to 20, and that’s NOT INCLUDING the clinical quality measures, which have always been like a MU menu all of their own, and which are now going to be determined through a different process and won’t be defined until later in 2015.

5. Meaningful Use concludes at Stage 3, but the mission continues

While the MU program will conclude with Stage 3, the CMS expects technology and quality care to improve with time. So a significant proportion of healthcare experts including myself are of the view that the CMS will build on the base set by the MU program through other government-backed quality and technology programs in the future.

Our two cents

We think that for a first draft, the CMS is definitely on the right track. They’ve addressed and rectified many of the issues that providers faced in the earlier stages of the program, however, they might have been too ambitious in certain areas.

A yearlong reporting period for example, is asking too much of the physicians. This data helps to improve healthcare in US, agreed. But seriously can’t a subset of this information be enough to monitor disease patterns?

Micky Tripathi and John Halamka have highlighted this concern beautifully

“If a clinician has 12 minutes to see a patient, be empathetic, document the entire visit with sufficient granularity to justify an ICD-10 code, achieve 140 quality measures, never commit malpractice, and broadly communicate among the care team, it’s not clear how the provider has time to perform a “clinical information reconciliation” that includes not only medications and allergies, but also problem lists 80 percent of the time.

 Maybe we need to reduce patient volumes to 10 per day? Maybe we need more scribes or team-based care? And who is going to pay for all that increased effort in an era with declining reimbursements/payment reform?” ……. Boiling the Frog, each incremental proposal is tolerable, but the collective burden is making practice impossible.”

 

On the other side of the spectrum our policy makers believe in

@dschwartz20 Flexibility, simplification, focus on outcomes and interoperability.

— Karen DeSalvo (@KBDeSalvo) March 25, 2015

Which side of the debate are you on? We would love to hear from you.

What’s next?

Subscribe to our blog for future updates on MU stage 3.

Visit CureMD’s Meaningful Use resource Center for Questions on eligibility and attestation for MU stage 1 and Stage 2.

You can also download our eBook for a step by step guide to MU.