Healthcare providers working to qualify for EHR incentive payments and avoid payment adjustments have a new set of criteria to prepare for. The Centers for Medicare and Medicaid Services released a proposal for the third -- and what is expected to be the final -- stage of the meaningful use program, in which it details the final requirements to be met by participating eligible professionals and hospitals.
The meaningful use stage 3 proposed rule represents the culmination of the EHR incentive project that began as part of the HITECH Act. The broad goal of the meaningful use program is to encourage eligible professionals (EPs) and eligible hospitals (EHs) to use more health IT tools. More specifically, the program is set up to promote collaborative and less costly patient care through health information exchange and data interoperability.
The meaningful use stage 3 proposed rule lists several significant changes that will affect incentive program participants. Stage 3's preliminary emphasis is on reducing the complexity of the program established during stages 1 and 2.
Meaningful use in 2017 and beyond
If the proposal stands, EPs and EHs will face a year-long attestation period. The only exception to that rule will be Medicaid EPs and EHs that attempt to demonstrate meaningful use for the first time. They will have to attest only for the duration of the current 90-day period. The reporting period for stage 3 will begin in 2017, when it will be optional for participants. In 2018, it becomes required for all EPs and EHs.
Requirements, objectives and measures
To simplify the set of requirements in this stage, HHS has proposed a limited set of eight objectives to help achieve the goals of the final stage.
Objective 1: Protect patient health information -- Providers will have to guard patients' electronic protected health information by maintaining physical and technical security measures.
Objective 2: Electronic prescribing -- Under the proposed objective, EPs would have to electronically create and transmit prescriptions to patients.
Objective 3: Clinical decision support -- Stage 3 would have clinical decision support efforts target improvement in treating high-priority conditions.
Objective 4: Computerized provider order entry (CPOE) -- Credentialed medical staff will be able to use CPOE for laboratory, diagnostic imaging and medication orders under the stage 3 proposal.
Objective 5: Patient electronic access to health information -- Patients will be offered access to their health information through an API within 24 hours of its availability.
Objective 6: Coordination of care through patient engagement -- This objective would have providers interact with patients about their care through certified EHR technology (CEHRT).
Objective 7: Health information exchange -- EPs, EHs or critical access hospitals will receive and transmit a patient's summary of care record as that patient moves between different care facilities.
Objective 8: Public health and clinical data registry reporting -- This proposed objective would have meaningful use participants communicate with and share health data with public health agencies or clinical data registries.
Payment adjustments and hardship exceptions
The meaningful use stage 3 proposed rule would permit the following four exceptions that would excuse providers from incentive payment adjustments:
- "The lack of availability of Internet access or barriers to obtain IT infrastructure.
- A time-limited exception for newly practicing EPs or new hospitals that would not otherwise be able to avoid payment adjustments.
- Unforeseen circumstances such as natural disasters that would be handled on a case-by-case basis.
- (EP only) exceptions due to a combination of clinical features limiting a provider's interaction with patients or, if the EP practices at multiple locations, lack of control over the availability of CEHRT at practice locations constituting 50 percent or more of their encounters."
Summary of costs and benefits
The federal costs of the Medicare and Medicaid EHR Incentive Programs between 2017 and 2020 is projected to be approximately $3.7 billion. The stage 3 proposal does not contain a sum cost estimate for healthcare providers as a group, but suggests that segment of the healthcare industry can derive significant value from the meaningful use program by improving population health, reducing patient and operational costs, and increasing patient safety and outcomes.
Providers may welcome the flexibility offered to them in the stage 3 proposal. If they have additional changes or other feedback to offer CMS, it must be received by the May 29, 2015 deadline.
About the author:
Reda Chouffani is vice president of development at Biz Technology Solutions Inc., which provides software design, development and deployment services for the healthcare industry. Let us know what you think about the story; email [email protected] or contact @SearchHealthIT on Twitter.
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