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Proposed changes to stage 3 of the EHR Incentive Programs

On May 5, CMS outlined its proposed changes to the EHR Incentive Programs as part of meaningful use stage 3.

In a webinar held on May 5, Elisabeth Myers, policy and outreach lead for CMS' Center for Clinical Standards and Quality, outlined CMS' newly proposed rules and discussed possible changes for stage 3.

In 2015, providers will be expected to report on the stage 2 objectives and measures with accommodations made for providers still in stage 1. "[They will] be able to attest to those exclusions of reduced thresholds," Myers said. "We're also allowing for a 90-day reporting period aligned to the calendar year for all providers and that is to allow for these changes that we're making in the program."

By 2017, all providers will be subject to reporting for the full calendar year.

"We have heard thousands of times how difficult it is to have multiple providers on multiple reporting periods and especially in complex health systems," Myers said. "You also have your eligible hospitals … who are on a different reporting period within the fiscal year."

In 2016 all providers will report on the reduced set of stage 2 objectives and measures -- nine objectives for eligible professionals and eight for eligible hospitals, Myers said. In 2017, providers will attest to the stage 2 objectives and measures or the stage 3 objectives and measures if they are able to do so. By 2018, all providers will attest to the full version of stage 3.

Concerning the newly proposed clinical quality measures for stage 3: "We'll be starting with [the] 2014 set [of measures] that everyone is currently using and the adjustments or changes to that, which might be in the form of additional measures here or there or measures being removed if they are topped out."

Myers said CMS looked over the current list of measures and objectives and identified those it believed were "redundant, duplicative and topped out" and are proposing to remove them from the reporting requirements and altering others.

Proposed changes to the list of measures and objectives for stage 3

CMS has drawn up a mostly new list of eight measures and objectives with only a couple remaining in their stage 2 form. The objectives CMS has proposed to change for stage 3 of the EHR Incentive Programs include the following:

Electronic prescribing

"We have essentially just changed the definition of permissible prescriptions to allow providers to include controlled substances in such a manner as is applicable in their state," Myers said. At present, 48 states allow controlled substances to be electronically prescribed, she added.

Clinical decision support

The new rule for clinical decision support is very similar to the stage 2 version, Myers said. The only difference in the new proposal for stage 3 is that CMS has expanded on and clarified what types of technologies are available.

"There are lots of different methods by which clinical decision support can be implemented, it doesn't just have to be a pop up on a screen," Myers said. She added that CMS does, however, maintain the drug-drug and drug-allergy interaction check that must be turned on throughout the entire reporting period.

Computerized provider order entry

The stage 3 proposal for computerized provider order entry is also very similar to the stage 2 version, Myers said, but CMS has proposed to broaden the category to include more types of imaging orders. "This was again at the provider request to expand that category and allow a wider range of orders to be met through this fashion to capitalize on the potential efficiencies and cost savings and patient safety improvements that are made through computerized provider order entry."

Patient electronic access to health information

CMS is also proposing that providers be able to use APIs when it comes to patients electronically accessing health information. Myers explained this would allow patients to use different types of applications to access their health data.

"[A patient] could potentially access their health data from multiple providers and pull it into a single personal health record, [and] if they're a caregiver they could potentially access multiple patients for whom they are a caregiver," Myers said. "It sort of changes and provides a new option for how data is accessed and helps, again, to eliminate barriers and promote innovation in how patient health data can be accessed by the patient."

Coordination of care through patient engagement

CMS is also proposing a new coordination of care through patient engagement rule that would allow for multi-directional messaging, Myers said. This means messages could be sent from provider to patient, from patient to provider, and from provider to provider within a care team --"as long as the patient is at the center of that communication," Myers said.

We have heard thousands of times how difficult it is to have multiple providers on multiple reporting periods and especially in complex health systems. You also have your eligible hospitals… who are on a different reporting period within the fiscal year.
Elisabeth MyersCMS' Center for Clinical Standards and Quality

In addition, CMS' proposed coordination of care rule also addresses patient-generated health data or health data generated in a non-clinical setting. "By non-clinical setting we mean ancillary care providers who may be part of a care team, who may potentially have an EHR, [who may] be able to provide information to a provider who has an EHR, [but] who may not necessarily be included in the meaningful use program and therefore there isn't currently a good workflow or process available to get their information in," Myers said.

She added that CMS is proposing this new care coordination rule to help develop standards and workflow processes so that other provides may better incorporate information from ancillary providers.

People can submit their comments and suggestions concerning CMS' EHR Incentive Programs proposed rules by hand, by mail or electronically. Comments are due by 5 p.m. on May 29.

Let us know what you think about the story; email Kristen Lee, news writer, or find her on Twitter @Kristen_Lee_34.

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