The proposed Meaningful Use Stage 3 rule includes 8 objectives. Some objectives are subdivided into multiple measures; therefore, providers will need to attest to approximately 16 measures. Meet all 8 objectives and you meet Meaningful Use Stage 3; fail just 1 objective and for most providers, payment adjustments (financial penalties) will be assessed.
Since a single challenging objective could result in Meaningful Use failure, it is important to understand the hurdles that lie ahead should the current proposed rule become law. We define a Challenging Stage 3 Objective as one where either the provider does not have complete “control” or one that may increase the cost of compliance. Provider “control” can be negatively influenced by two factors: either measures that rely on the cooperation of patients, or those that are dependent on the healthcare ecosystem.
1. Coordination of Care through Patient Engagement
Based on our characterization of a challenging measure and dependence on patient cooperation, the “Coordination of Care through Patient Engagement” objective meets our definition. To meet the performance metrics for this objective, your patient must assist you in meeting the thresholds for 2 of these 3 engagement activities:
A. Review their health record
B. Exchange secure messages with providers
C. Interact with their health record by generating their own data
CMS is clearly “upping the ante” with regard to patient engagement. Studies show that increasing patient engagement may help to improve the health of a population. We are not sure that mandating changes in workflow and tying physician compensation to patient engagement is fair, but we don’t expect a complete about-face on this objective.
Our advice: make sure you have a great patient portal and make that portal part of your workflow ASAP.
2. Health Information Exchange
We’ve established that lack of control always makes an objective challenging. Successful performance with regard to the objective “Health Information Exchange” is coupled to the maturity of the adoption of standards relating to interoperability. Not just standards implemented by the provider, but also standards adopted by the provider’s healthcare ecosystem.
To meet the performance metrics for this objective, the provider must meet the thresholds for 2 of the 3 engagement activities:
A. For transitions of care and referrals, the sending provider creates a summary of care record (CCDA) and exchanges the record electronically
B. For transitions or referrals that are received in which the provider has never before encountered the patient, the provider incorporates into the patient’s EHR the CCDA as discrete data for certain data elements such as the Medication List
C. For transitions or referrals received and patient encounters in which the provider has never before encountered the patient, the provider must reconcile medications, allergies and problem list findings
These measures are all betting on a radical improvement in adoption of the Direct method of secure email exchange. Remember, Direct is the most likely way that electronic exchange of CCDA documents will occur. The challenge: Direct use has been slowed by poor Stage 2 adoption and a lack of standards/mandates regarding exchange of provider directories. Is it possible that the healthcare ecosystem will mature such that Direct is ubiquitous by 2018? If yes, then this measure will be a lot less challenging.
3. Public Health and Clinical Data Registry Reporting
Our final challenging objective is “Public Health and Clinical Data Registry Reporting.” This is an ecosystem and expense challenge. Per the table below, providers are required to attest to 3 of the 5 measures in the first column.
Our experience with Immunization Registry reporting over the past few years has led us to conclude that the majority of state registries are not prepared technologically and financially for the onslaught of connection requests spurred by Meaningful Use. In one state, we have a provider who is waiting 2 years for a connection to their immunization registry. Should this rule pass as proposed, there will be hundreds of possible connections required for national EHR vendors to make and test on behalf of their constituents.
The healthcare ecosystem is not prepared today, and we don’t foresee the radical changes needed coming in time for 2018 Meaningful Use Stage 3. If connectivity to these state registries does not become more automated in the next couple of years, we see this measure raising the cost of ownership for providers. Frankly, I just hope that the provider waiting for immunization registry connection I referred to above is allowed to connect by 2018!
The Meaningful Use Stage 3 proposed rule is now in the comment stage. Worried about meeting some of the challenging measures captioned in this blog? Make your voice heard by commenting on the objectives at http://www.regulations.gov/#!documentDetail;D=CMS-2015-0033-0002 no later than 5 p.m. on May 29, 2015.