This is the second in a series of blog posts examining the Meaningful Use Stage 3 Proposed Rule and its impact on medical practices. You can also review our first post, “5 Things You Need to Know About the Meaningful Use Stage 3 Proposed Rule.” This post examines three wins for providers in the Meaningful Use Stage 3 Rule.
1. Data Portability – Providers have been struggling to migrate from their old EHR to a more modern one. Providers using old client server applications want to move to the cloud. In addition, there have been many EHR systems that have had trouble keeping up with new regulations and standards. Certain EHRs have not made the commitment to transform their applications such that users can perform comprehensive charting on mobile tablets. Because of the failure of older legacy EHRs to “keep up with the times” 30 – 40% of practices want to switch EHRs.
Today the cost and hassle of data migration makes switching untenable for many practices. In the Stage 2 rule, the Office of the National Coordinator (ONC) started to require that certified EHRs include certain data portability features. There were 2 major obstacles relating to data portability in Stage 2; the first is that some EHRs have hidden the data export feature mandated by the ONC (we have witnessed this) and the second is that those data export specifications were not comprehensive enough to meet the needs of a functional data migration.
In the new rule, the ONC has responded to provider concerns relating to data portability and they have expanded the type of data included in the data portability requirements. Now the ONC would also require that export summaries be able to be created according to any of the following document-template types:
- Consultation Note
- History and Physical
- Progress Note
- Care Plan
- Transfer Summary
- Referral Note
- Discharge Summary
The ONC does not speak to the ability to export in bulk scanned images in a uniform format, and therefore we expect that data migration per the new proposed standard will be helpful but not make EHR switching completely hassle free.
2. Enhanced ePrescribing – Perhaps one of the most broadly adopted features of EHRs is the ability to prescribe electronically. In fact, according to CMS providers report that they prescribe around 90% of all permissible prescriptions electronically. The ONC has proposed adding more features to ePrescribing that we think will further enhance the ePrescribing experience and improve the quality of care.
These proposed enhancements include:
- Change Prescription
- Refill Prescription
- Cancel Prescription
- Fill Status
- Medication History messages (see the table below)
As an example, the Fill Status message could positively impact the quality of care because it will offer physicians a method to know whether a patient has filled a drug that might be crucial to the treatment of a life-threatening disease.
3. Standards for Sharing Direct Messaging Provider Directories – In Stage 2 the ONC required that vendors support “Direct”, a protocol for the exchange of secure email. This was to be the replacement for the fax machine and, we hoped, a time- and paper-saver. The implementation of Direct has not worked as originally planned (see this previous blog post on the problems with Direct Messaging) and the proof is that the Stage 2 Transition of Care measure that depended on the use of Direct was specifically addressed and relaxed in the September 2014 flexibility rule.
Part of the reason for poor adoption was the lack of a consistent standard for the sharing of provider directories for “look up” of provider Direct addresses in a practices’ referral network. The proposed rule will require that EHRs have the capability to exchange directories such that they have the ability for:
A. Querying for an individual provider
B. Querying for an organizational provider
C. Querying for both individual and organizational provider in a single query
D. Querying for relationships between individual and organizational providers
This new standard should make Direct more effective and simplify the exchange of medical records between providers. We encourage CMS to continue to offer flexibility with regard to Direct between now and when these new standards are incorporated into EHR technology by 2018.
Initially Meaningful Use was a term that put a smile on the face of physicians, when the incentives were high and there were no penalties. Now many physicians view Meaningful Use as a burden. These three proposed standards may prove to reduce the burden for many providers and we advocate they are included in the final rule.
For a live discussion of the Meaningful Use Stage 3 Proposed Rule and its impact on practices, join us for a webinar on April 28: Meaningful Use Stage 3: What the Future Holds.