As promised, the Centers for Medicare and Medicaid Services have offered up plans for Meaningful Use Stage Three just in time for discussion at the HIMSS Annual Conference. Based on conversations I’ve had with CIOs, there will be a lot to discuss in Chicago.
As with the previous incarnations (Stages 1 and 2), there’s a 60-day comment period during which anyone can weigh in on the proposals. Although the previous rules reflected input from groups like HIMSS and CHIME, I heard frequent grumbling from healthcare providers that the regulations elevated political and economic interests over those of physicians, hospitals and most importantly, patients themselves.
Perhaps because Stage 3 represents the end of the process, CMS is signaling its intent to finalize a rule that puts patients first, and believes that eligible providers and hospitals can use technology creatively and flexibly to meet the latest requirements.
The Basic Overview
To get a basic overview of the rules, take a look at this infographic produced by my former colleagues over at Healthcare IT News. For a more substantive take, John Halamka, a physician and CIO at the CareGroup Health System, posted a definitive summary of the proposed rules on his blog.
There are eight objectives, and as many as 20 measures of meaningful use for providers and hospitals. Some measures are essentially repeats from earlier rules (although the thresholds are increased), while others represent new and uncharted territory.
Despite its length of 300-plus pages, Halamka calls the MU Stage 3 proposal a good first draft.
“CMS deserves a lot of credit,” he says, “for streamlining and consolidating… and making the Stage 3 rule coherent and relatively easy to understand.” But he’s not so kind about the the rule’s sibling proposal, also released on March 20 – the Office of the National Coordinator’s 2015 EHR standards.
Although meaningful use and EHR certification are generally thought to go hand-in-hand, this time “ONC includes a variety of certification specifications for which there are no corresponding MU requirements from CMS,” Halamka notes. “This has the potential to create market confusion, an overwhelming scope for vendors/developers and a laundry list of requirements that serve narrow interests.”
Scott MacLean, Deputy CIO and Director of IS Operations at Partners HealthCare in Boston, agrees that the industry is already suffering from regulation fatigue. It’s not that any single regulation is, by itself, difficult or noxious, but rather it’s the sum of regulations which are often times at odds with each other.
Particularly challenging are the requirements for patient engagement. Twenty-five percent of patients must access their records electronically under the MU Stage 3 proposal, while 35 percent of patients must receive a clinically relevant secure message. Providers must also incorporate data from non-clinical settings for 15 percent of their patients.
“Whether its between systems and providers, or between patients and providers, I’m worried about the interoperability requirements,” MacLean notes. “When we’re dependent on other people doing something, it’s cause for concern.”
Charles Christian, CIO of St. Francis Hospital in Columbus, Georgia and chair of the CHIME Board of Trustees, agrees. “Providing electronic access to the information is important,” he says. “However, holding the organizations accountable for their patients’ behavior after their encounter is a requirement that many organizations can’t successfully accomplish. I agree that we need to engage our patients; however, there are many that do not want to interact with their healthcare providers electronically.”
Overall Christian is confident that the nation’s healthcare CIOs can have an impact on the final Stage 3 rules. “It appears that CMS is working toward the flexibility that they outlined, but I'm sure that some in the industry will wish for more,” he says. “CMS is specifically asking for comments on a large number of items and options. This leads me to believe that they are seeking additional input from the industry and they are listening to the concerns and impacts. We will need to wait until the final rule to see what impact the comments have had.”
What do you think about the Stage 3 proposal? Is it ready for prime time yet? What changes would you seek?
Jack Beaudoin co-founded MedTech Media with the launch of Healthcare IT News in 2003 and is a sponsored corresponded for Intel Health & Life Sciences.