Meaningful use stage 3 is the third phase of the meaningful use EHR incentive program. The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) published the final rule on meaningful use stage 3 on October 6, 2015.
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Despite the requirements set by stage 3, there are important upcoming changes through a new law called MACRA -- or the Medicare Access and CHIP (Children's Health Insurance Program) Reauthorization Act. MACRA will eventually modify the meaningful use program as a means to push forward with value-based reimbursement.
"The meaningful use program, as it has existed, will now be effectively over and replaced with something better," said Andy Slavitt, the acting administrator of CMS, in January 2016.
As things stand, in summer 2016, meaningful use stage 3 will be optional for providers in 2017 and mandatory for all participants in 2018. Objectives and measures for all providers, regardless of prior participation, are finalized for the 2018 reporting period with this rule.
Along with meaningful use stage 1 and meaningful use stage 2, the third list of criteria and requirements mandates that all hospitals and eligible healthcare professionals use certified electronic health record (EHR) systems.
Meaningful use program requirements
Meaningful use stage 3 includes all of the requirements that physicians must meet to receive their incentives and avoid any penalties. In this program, physicians must meet eight overall objectives, in contrast to the earlier requirement for them to choose from a core menu of options. The objectives cover the following areas:
- Protected health information (PHI): Eligible physicians must attest to conducting a security risk analysis to assess vulnerabilities to PHI that could lead to data breaches. In addition to the fact that the Health Insurance Portability and Accountability Act (HIPAA) requires practices to perform risk analysis and other security audits, the requirements attached to meaningful use objectives make it a must-have in order to receive incentives.
- Electronic prescribing: Eligible physicians are required to have more than 80% of their permissible prescriptions queried for drug formulary and transmitted to pharmacies electronically.
- Clinical decision support (CDS): For this objective, there are two different measures available for eligible physicians. The first measure covers implementing five CDS interventions. The second measure relates to the active use of drug-drug and drug-allergy interaction checks during the reporting period, which are available within a certified EHR platform.
- Computerized provider order entry (CPOE): Eligible physicians are required, under this objective, to meet three different measures for medication, lab and diagnostic imaging orders.
- Patient electronic access: To help encourage patient engagement, meaningful use stage 3 includes an objective in which eligible physicians must provide access to EHRs to more than 80% of patients, with the option to view and download the records. In addition, eligible physicians must offer the option to receive educational data to more than 35% of their patients.
- Coordination of care through patient engagement: The measures included in this objective encourage patients to actively engage in their care by necessitating physicians to educate them on and offer capabilities to view patient health data. The measures in this objective cover three different aspects. The first measure requires physicians to have more than 25% of patients interact with their EHR. The second measure requires that more than 35% of patients receive a secure digital communication from a care provider. The third measure focuses on encouraging the collection of patient generated health data from fitness trackers or wearable devices from more than 15% of patients. Eligible providers must attest to all three measures, but meet the thresholds for two of the three.
- Health information exchange (HIE): The measures included in this meaningful use objective encourage interoperability. The first measure requires that more than 50% of care transition and referrals include the exchange of care records, such as continuity of care documents (CCD), electronically. The second measure requires physicians who are seeing a patient for the first time to receive care documents electronically from a secondary source more than 40% of the time. The final measure requires physicians to use e-prescribing services to reconcile medication lists from online sources with their own for more than 80% of new patients they see. Eligible providers must attest to all three measures, but meet the thresholds for two of the three.
- Public health and clinical data registry reporting: In this objective, providers must choose three out of five available EHR reporting destinations to which they will submit data periodically. Reporting options include an immunization registry, syndromic surveillance, cases, a public health registry and a clinical data registry.
Stage 3 also promotes the use of APIs to bridge the gaps between health IT systems and to provide increased data access.
Meaningful use and MACRA
MACRA is federal legislation signed into law on April 16, 2015 that establishes ways to pay physicians for caring for Medicare beneficiaries and includes funding for technical assistance for providers and related measure development. The law also sets requirements for data sharing.
More EHR incentive program updates
It is important to note that in July 2016, CMS published an outline describing changes that it proposed for the Hospital Outpatient Prospective Payment System (OPPS) for 2017. In the document, CMS requested that Congress enact changes to the meaningful use program, including:
- Reduction of the EHR reporting period from a full year to 90 days.
- The elimination of CDS and CPOE objectives.
- Reduction of the thresholds for a subset of the remaining objectives and measures in meaningful use stage 2 for 2017 and meaningful use stage 3 for 2017-2018 for eligible and critical access hospitals.
- Flexibility for those who have not successfully demonstrated meaningful use in a prior year, enabling them to attest to a modified stage 2 by October 1, 2017.
Lawmakers must formally vote in these changes to meaningful use in order for them to take effect.
Despite the recent meaningful use stage 3 final ruling release and proposed changes, physicians in 2017 will have access to a newly introduced program called Advancing Care Information (ACI) with the Medicare Incentive Payment System (MIPS), which are both part of MACRA. Under the new law, ACI will only affect Medicare physicians' offices and not Medicare hospitals or Medicaid programs. These new programs are designed to offer flexibility such as:
- Reduced number of measures to meet.
- Elimination of CDS and CPOE.
- More emphasis on interoperability and health information exchange.
- Multiple options to receive incentives for physicians.
- Exception for certain physicians from reporting when EHR technology is less applicable.
The recent proposed changes to meaningful use rules have received praise from a number of different medical associations throughout the nation, but it remains to be seen how physicians will navigate the different programs and requirements they face under each one.