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Technical Doctor's insights and information collated from various sources on EHR selection, EHR implementation, EMR relevance for providers and decision makers
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For Stage 2 Meaningful Use Attestation, Pick a Larger EHR Vendor

For Stage 2 Meaningful Use Attestation, Pick a Larger EHR Vendor | EHR and Health IT Consulting | Scoop.it

Larger EHR vendors tend to make better partners in achieving Stage 2 Meaningful Use, according to a recent study by Peer60. The study, which discusses insights and trends in EHR vendors, sought to identify the which vendors play a bigger and more supportive role in providers’ work to achieve meaningful use.

According to the report, users of notable vendors such as Epic, Cerner, and Allscripts stated that these technology partners delivered adequate support for their efforts to meet meaningful use. Among these vendors, many users also reported being in the midst of attesting to Stage 2. Epic also had several respondents report that it was not an adequate partner in Stage 2 attestation, but given the high volume of users Epic engages with, the positive reviews significantly outweigh the negative.


Other vendors did not receive such favorable reviews, according to Peer60. Among those is McKesson, who received nearly double the percentage of negative reviews as positive ones. McKesson also has a substantial number of users who report still being in the process of attesting Stage 2. A few smaller vendors also received negative meaningful use reporting reviews, including NextGen and Practice Partners (which is owned by McKesson).


Of the practices surveyed, nearly 90 percent of them have either achieved Stage 2 or are in the middle of attestation. Fifty-six percent of respondents had successfully completed Stage 2 attestation, and 34 percent were in the thick of attesting. Only 10 percent had not successfully attested, and Peer60 reports that about half of those who had not been successful “simply don’t have the proper model to receive enough benefits to bother attesting.”


This report comes out after CMS released data regarding meaningful use registration and participation. Given that data, it appeared as though the delay in the release of the meaningful use modificationrules was hindering program growth. According to CMS, meaningful use enrollment stayed stagnant between the months of May and August. Medicare eligible professional (EP) enrollment also remained relatively the same between May and July, and skyrocketed in August. Likewise, eligible hospital (EH) enrollment stayed consistent between May and July and made a notable jump in August.

Now that the Stage 2 Meaningful Use Modifications Rule has been released, the rate of EHR Incentive Program enrollment may increase. Because the modified rule eliminates unnecessary and cumbersome requirements, as well as shortens the initial reporting period to 90 days, it is expected that more providers will enroll in the program and will be able to achieve success.

However, success could potentially be better facilitated by an EHR vendor that is more supportive and provides a product that works better with meaningful use. As such, EHR vendors may need to adjust their practices in helping providers meet meaningful use guidelines in order to remain competitive in the EHR market.

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Senator Gives 5 Reasons to Delay Stage 3 Meaningful Use

Senator Gives 5 Reasons to Delay Stage 3 Meaningful Use | EHR and Health IT Consulting | Scoop.it

Joining the group of critics of Stage 3 Meaningful Use, Senate Chairman of the Committee on Health, Education, Labor, and Pensions (HELP) Lamar Alexander (R-TN) urged the administration not to move forward with the rule in a statement before administration officials, according to a press release.

Alexander advocated against implementing Stage 3 Meaningful Use rules, stating that doing so would be a detriment to the administration’s goals of providing better and more coordinated care for patients. Using that logic, Alexander stated that there was no downside to taking their time in developing an effective and manageable rule, while giving providers adequate time to achieve Stage 1 and Stage 2 Meaningful Use.


Alexander continued by underscoring the importance of the meaningful use programs in achieving broader goals within the healthcare industry, such as goals for precision medicine and transitioning Medicare payments to value-based payments. Because of the high-stakes surrounding meaningful use, Alexander argues that it needs to be developed carefully in order for it to be effective and successful.

In his testimony, Alexander listed five reasons why the administration should delay the Stage 3 rule:


Stage 2 Has Not Yet Been Successful


First, Alexander explained how Stage 2 Meaningful Use has not yet been successful, citing the statistics that a mere 12 percent of physicians and 40 percent of hospitals have managed to achieve Stage 2 success. It would make more sense, Alexander argues, to pause Stage 3 implementation and allow providers more time to comply to Stage 2.


Medicare Payment Issues Meaningful Use Penalties


In Medicare’s transition from fee-for-service payments to value-based payments, the program has put a priority on providers meeting meaningful use standards. Because of this, providers will face harsh penalties if standards are not met. To that end, Alexander explains, it is important that providers be given ample time to properly meet these standards.


Industry Leaders Also Recommend a Stage 3 Delay


Alexander states that the general consensus that he has gathered amongst prominent providers is an overall fear of Stage 3 rules.

“Physicians and hospitals have said to me that they are literally ‘terrified’ of stage 3, because of the complexity and because of the fines that will be levied,” he explains.


Stage 3 Requirements May Actually Hinder Interoperability

A leading goal for the administration includes the interoperability between EHR systems. However, a recent GAO report which Alexander commissioned stated that many industry stakeholders find thatmeaningful use rules hamper interoperability. This is because they concentrate on achieving program requirements rather than on effectively achieving interoperability.

The Final Rule Should Match the Legislation’s Primary Goals

When developing the meaningful use programs, the administration identified seven goals for the program. Alexander argues that meaningful use rules should match and enhance these goals. The seven goals include:


  1. Decreasing unnecessary physician documentation;

  2. Enabling patients to have easier access to their own health records;

  3. Making electronic health records more accessible to the entire health care team, such as nurses;

  4. Stopping information blocking

    1. This could be described as intentionally interfering with access to my personal health information;

  5. Ensuring the government’s certification of a records system means what it says it does;

  6. Improving standards; and

  7. Ensuring the security and privacy of patient records.


Alexander suggests a timeline that would begin with phasing in Stage 2 Meaningful Use modifications, aiding providers in achieving that step of the overall program. From there, Alexander suggests the administration phase in subsequent stages “at a rate that reflects how successfully the program is being implemented.”


Alexander has advocated for delaying Stage 3 Meaningful Use before. Recently, he and Senator John Thune cosigned a letter to HHS Secretary Sylvia Matthews Burwell. In the letter, the two request that the final rule for meaningful use not be implemented until January 1, 2017 at the earliest. This letter, along with Alexander’s testimony before the administration, are just two examples of congressional resistance to the final rule.

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Three Vendors are Driving Patient Engagement and Portal Use

Three Vendors are Driving Patient Engagement and Portal Use | EHR and Health IT Consulting | Scoop.it

Driving patient engagement is still vital for the healthcare sector despite certain inconsistencies from the Centers for Medicare & Medicaid Services (CMS). Even though CMS has proposed new Stage 2 Meaningful Use regulations that drop the 5 percent requirement of patients viewing, downloading, and transmitting their health information to just one patient per provider, the organization still expects eligible professionals and hospitals to meet a much larger percentage – currently proposed to be 25 percent – of patients viewing their medical data through patient portals under the Stage 3 Meaningful Use requirements. As such, providers would be wise to continue integrating patient engagement strategies at their facility.

Vendors play a vital part in developing effective patient portals to assist providers in driving patient engagement among their community of consumers. A report from the research firm KLAS examined which vendors in particular have been most useful in moving forward patient portal adoption amidst healthcare providers.Driving Patient Engagement

Athenahealth, Epic, and Medfusion were reported to be at the top of their game when it comes to increasing portal adoption throughout the patient population. More than half of the customers under all three vendors report that at least 20 percent of their patients have accessed the patient portal. This is well above the previous 5 percent threshold that CMS initially unrolled under Stage 2 Meaningful Use regulations.

KLAS discovered these findings after interviewing 186 medical provider organizations on which vendors have really made a difference in meeting their needs and advancing health IT and patient engagement for a brighter tomorrow.

The KLAS report focused on three main areas regarding patient portal strategies: enterprise, ambulatory, and EMR agnostic. A variety of factors associated with increasing patient portal adoption were addressed in the report including product performance and vendor guidance.

“Value-based care is forcing patient portals to evolve from being merely tools for reactive regulatory compliance to becoming valuable instruments that allow patients to proactively engage in their own care,” said report author Coray Tate. “Providers report that vendor guidance and functionality that patients find useful, such as billing and self-scheduling, are the most effective ways to encourage portal adoption among patients.”

A study published by the American Health Information Management Association (AHIMA) further outlines the use of the patient portal particularly among teenagers and parents. The researchers studied the attitudes of these two groups through one teen digital bulletin board, one parent digital bulletin board, and two focus groups for each faction. Videos and transcripts from the sessions were then analyzed.

The results showed that both teenagers and parents found that patient portals are beneficial and should be used to help teens better manage their own healthcare. Some teenagers were concerned that physicians would not be keeping certain information private and will let their parents see data that is meant to be protected. One parent said: “This kind of access will help my teen become much more interested in her healthcare and also motivate her to take control. And that will be great.”

With greater teamwork between vendors, providers, and the patients themselves, there should be a rise in the use of portals and patient engagement.


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Stage 3 Meaningful Use Proposed Rule: Is More Time Needed?

Stage 3 Meaningful Use Proposed Rule: Is More Time Needed? | EHR and Health IT Consulting | Scoop.it

With the comment period open for providing feedback on the Stage 3 Meaningful Use proposed rule, the Centers for Medicare & Medicaid Services (CMS) along with the Office of the National Coordinator for Health IT (ONC) are likely to receive a multitude of opinions regarding the revision of these meaningful use requirements.


EHRIntelligence.com spoke with Bruce Eckert, National Practice Director at Beacon Partners, to get his perspective on the Stage 3 Meaningful Use proposed rule. Eckert mentioned how Stage 3 will likely advance the utilization of health IT tools even further.


“If the Stage 3 requirements were widely adopted, it would be a significant increase in industry capabilities, a big advancement for healthcare IT and good for the industry in many ways,” Eckert said. “But I think it’s going to be very challenging to bring a significant number of providers up to that level.”


Additionally, Eckert explained that requiring providers to reach the threshold of 25 percent of patients viewing and downloading their health information is a difficult stipulation to achieve. Currently, under Stage 2 Meaningful Use requirements, providers only need to ensure that 5 percent of patients view and access their health records electronically.


“We as an industry have struggled with [a similar stipulation] under Stage 2, so the greatly increased percentage under Stage 3 is likely to be a challenge,” Eckert stated. “I think it’s going to depend on the organization and the demographics. For many of our clients, we found that if they market their portal well, they will get well above the 5 percent of participation. [However,] 25 percent of participation based on today’s experience is high. It’ll take effort.”


“The counter to that is that policymakers are looking ahead to 2018,” the Beacon Partners representative continued. “In almost three years, society will continue migrating to online activities and part of that is using online services for health-related activities. It’ll be a challenge but I have a bit of optimism about it.”


When asked whether there will likely be many comments asking to lower this percentage during the comment period, Eckert replied in the affirmative and encourages healthcare organizations to express their opinions formally to CMS during the comment period. The director went on to discuss the importance of health information exchange (HIE) within the Stage 3 Meaningful Use proposed rule.


“It’s really important that our industry figure out how to [accomplish HIE]. It’s a big piece to the puzzle of care coordination and improving the quality of care. We have to make it work one way or another,” said Eckert. “Right now, under Stage 2, Direct Protocols turned out to not be ready for wide-spread usage. I think it will be by Stage 3. By leveraging Direct, I think we can achieve the Stage 3 level by 2018.”


Eckert stated that he is more optimistic about this objective under the Stage 3 Meaningful Use proposed rule and is “fairly positive about healthcare exchange.” However, Eckert was not as hopeful about most providers meeting all Stage 3 Meaningful Use requirements by the January 1, 2018 deadline.


“I think it’s going to be tough [to meet the deadline.] The reason is because we’re going to run into the same problem that we did with Stage 2. The problem is the [short] timeline for the vendors to develop the products,” Eckert explained. “From today until January 2018, there is about 33 months left. That is a little less time than there was from the [release of the] 2014 CEHRT proposed rule until the October 2014 deadline for most organizations to implement 2014 CEHRT.”


“CMS released the flexibility rule in late 2014 to grant extra room at that point because many vendors were either not ready or had gotten systems out late and providers were not able to fully implement these tools,” said Eckert. “I can see the same scenario developing here because the vendor timeline to create the considerably advanced capabilities is relatively short. The big rush to get these capabilities deployed in time is going to be a challenge.”


Eckert also discussed the increased focus on patient engagement under the Stage 3 Meaningful Use proposed rule. Physicians will have more options and tools available to communicate with patients.

“Studies that have been done in the past about patients using electronic messaging finds that it replaces the telephone,” Eckert mentioned. “Patients use electronic communication to ask questions or send information to providers that they would have done via telephone. Electronic messaging is more time efficient for the physician’s office than the telephone is. Providers will really appreciate the change in the Stage 3 rule around secure electronic messaging.”


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Six Things to Know About Stage 3 of Meaningful Use

Six Things to Know About Stage 3 of Meaningful Use | EHR and Health IT Consulting | Scoop.it

Have you had a chance to read through the proposed rule for the Stage 3 rules of the government's EHR incentive program? If not, we've got you covered.

Here are six things to know about the proposed rule:


1. The rule proposes a significant change to the structure of the meaningful use program by establishing a single stage for meaningful use (Stage 3) starting in 2018. This means that in 2018 and following years, all providers (regardless of prior participation in the program) would need to meet the Stage 3 rules. In 2017, providers could participate in Stage 1, Stage 2, or Stage 3, but in 2018, all would need to attest to Stage 3. The proposed rule notes that the program requirements may change slightly in future years, but Stage 3 would remain the final stage moving forward.

 

2. The proposed rule indicates that Stage 3 would continue to "build on the groundwork" established in Stage 1 and Stage 2.  Many of the measures included in the proposed rule focus on increasing interoperability, information exchange, and patient engagement. Though many of the measures associated with these initiatives are similar to the measures in Stage 2 (but with higher thresholds), there are also some new measures associated with them.


3. The proposed rule establishes a full-year reporting period. The proposed rule specifies that the meaningful use reporting period would be a full year for both physicians and hospitals starting in 2017 and in future years. The only exceptions would be Medicaid eligible providers and hospitals attesting to meaningful use for the first time (they would have a 90-day period).


4. The proposed rule requires electronic quality reporting. Starting in 2018, CMS would require electronic quality reporting for providers who would need to implement five clinical decision support interventions related to four or more quality measures.


5. The proposed rule includes fewer objectives in Stage 3, but many of the measures associated with these objectives may be more challenging. Providers would only need to meet eight objectives in Stage 3 (though some of these objectives have multiple measures associated with them). The proposed rule also includes new requirements that may be difficult for providers.

 

6. The proposed rule includes some flexibility when it comes to the requirements. The proposed Stage 3 objectives include some flexibility, which could make it easier for providers to successfully attest. For instance, for the "coordination of care through patient engagement" objective, providers would only need to meet thresholds of two of three measures and attest to the numerators and denominators of all three measures. And, for the "health information exchange" objective, providers would need to meet the thresholds of two of three measures and attest to the numerators and denominators of all three measures.


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New Measures Under Stage 3 Meaningful Use Requirements

New Measures Under Stage 3 Meaningful Use Requirements | EHR and Health IT Consulting | Scoop.it

The Department of Health and Human Services (HHS), the Office of the National Coordinator for Health IT (ONC), and the Centers for Medicare & Medicaid Services (CMS) have prioritized that all eligible professionals will need to meet Stage 3 meaningful use requirements under the proposed rule by 2018. Along with this determination, providers will also be able to file hardship exemptions if meeting this goal is unsustainable for their practice.


The established payment reductions for not meeting meaningful use requirements haven’t been modified. Along with the announcement about the eight objectives under the Stage 3 Meaningful Use proposed rule, the federal agencies also disclosed the 2015 Edition Health IT Certification Criteria, according to the Journal of AHIMA.

While the Stage 2 Meaningful Use requirements called for ensuring 5 percent of patients used portals to view, download, and share health records, the Stage 3 Meaningful Use proposed rule asks providers to engage 25 percent of their patients in accessing this medical information.


This also includes having 25 percent of patients use secure messaging tools to speak with their physicians. The proposed rule recommends providers to use a third-party interface when collecting this data.

Many stakeholders are encouraging further revisions in one area of Stage 3 Meaningful Use requirements. The full calendar year EHR reporting period is posing undue burden on healthcare facilities and many are urging the inclusion of a 90-day EHR reporting period instead.


Recording patient demographics within the health record is also a key part of Stage 3 Meaningful Use regulations. Some of the data that eligible hospitals will need to record includes patients’ preferred language, race, ethnicity, gender, date of birth, preferred method of communication, sexual orientation, occupation, and disability status.

Another new measure under the Stage 3 proposed rule includes a recommended menu item that states eligible hospitals and providers will need to receive electronic patient-generated medical information through either questionnaires/surveys or secure messaging systems. Patient-generated data through mobile technologies will also count toward this requirement.


Another interesting objective within the proposed rule asks for hospitals to send electronic notifications to a patient’s care team – especially primary care providers – about any important healthcare occurrences. While many of the proposed measures may be challenging to achieve across the healthcare sector, the overall goals of the EHR Incentive Programs is to establish health information exchange and improve interoperability.


“ONC’s proposed rule will be an integral component in the shared nationwide effort to achieve an interoperable health system,” Karen DeSalvo, M.D., M.P.H, M.Sc., national coordinator for health IT, said in a public statement. “The certification criteria we have proposed in the 2015 Edition will help achieve that vision through provisions that consider the range of health IT users and uses across the care continuum, including those focused on interoperable standards, data portability, improved transparency, privacy and security capabilities, and increased oversight through ONC’s Health IT Certification Program.”


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Healthcare Industry Reacts to Stage 3 MU Proposed Rule

Healthcare Industry Reacts to Stage 3 MU Proposed Rule | EHR and Health IT Consulting | Scoop.it
On March 20, the Centers for Medicare & Medicaid Services (CMS), the Office of the National Coordinator for Health IT (ONC), and the U.S. Department of Health and Human Services (HHS) announced that the latest proposed ruling on Stage 3 Meaningful Use requirements have been released for public comment.

The announcement emphasizes how the proposed rules will give providers more flexibility under the EHR Incentive Programs and increase EHR interoperability to improve the access and sharing of patient health information.2015-01-12-chime-small

The healthcare industry as a whole is currently processing the proposed ruling and preparing to contribute during the comment period. Some public statements about the Stage 3 Meaningful Use proposed ruling from leading organizations have been released.

A statement from the College of Healthcare Information Management Executives (CHIME) said: “CHIME is closely evaluating both the CMS Meaningful Use rule and the ONC certification rule. Based on our initial review, we are pleased to see flexibility built into the Stage 3 proposed objectives. We are still trying to understand the implications of moving all Medicare providers to a single definition of MU by 2018, but are encouraged by the potential for this policy to simplify and streamline the long-term viability of Meaningful Use. While we and other stakeholders have been critical of the program over the last two years, we have always underscored how vital Meaningful Use is to modernizing our nation’s healthcare system. We look forward to digging further into the rule, looking for elements that will allow providers to build on their IT investments, specifically in the areas of care coordination, patient engagement and interoperability.”

“We do, however, urge CMS to quickly publish the proposed rule alluded to in Dr. Conway’s January 29 announcement. We were encouraged by the signals to shorten the 2015 EHR reporting period from 365 to 90 days and make other program improvements through a follow-on rule. We call on CMS to propose policy changes to the ‘all-or-nothing’ construct, lengthen timing between required Stage upgrades, and consider much-needed revisions to the hardship exception categories. These changes will enable far better participation among providers, which will in turn, keep them on a path towards improved care through health IT.”

With the inclusion of some more policy changes, CHIME recognizes that Stage 3 Meaningful Use regulations will play a pivotal role in expanding health IT adoption across the country and thereby improving the quality of care. Another statement comes from the American College of Cardiology President Kim Allan Williams Sr., M.D., on the organization’s reaction to the proposed ruling.

“The American College of Cardiology has long supported the adoption of electronic health records (EHRs) as a mechanism for improving patient outcomes,” Williams said. “The EHR Incentive Program as currently structured has been focused more on ‘checking the box’ than changing care delivery to achieve the goal of improved patient care.”

“Although the ACC is still reviewing the proposed regulations, the College is concerned by the proposal to require all providers, even first-time participants, to report for a full calendar year,” the American College of Cardiology President continued. “Implementing an EHR system in a physician practice or a hospital is not as simple as flipping a switch; it takes time, financial investment, careful consideration and planning, as well as education for all staff. The program must take this learning curve into consideration.”

Some players within the healthcare industry find the EHR reporting period of a full calendar year problematic and are urging CMS to transition to a 90-day reporting period instead.

Additionally, there may be too many regulations that are being put forth to advance the meaningful use of health IT systems instead of addressing the various problems in the medical industry today. A statement from the American Hospital Association (AHA) underscores this point.

“Hospitals are implementing electronic health records at a brisk pace in order to improve patient health and health care, but they must do so under the crushing weight of government regulations,” Linda E. Fishman, Senior Vice President of Public Policy Analysis and Development at AHA, said in a public statement. “The release of today’s rule demonstrates that the agency continues to create policies for the future without fixing the problems the program faces today. In January, CMS promised to provide much-needed flexibility for the 2015 reporting year, which is almost half over. Instead, CMS released Stage 3 rules that pile additional requirements onto providers. It is difficult to understand the rush to raise the bar yet again, when only 35 percent of hospitals and a small fraction of physicians have met the Stage 2 requirements.”

“We urge CMS to release the 2015 flexibility rules immediately. Information technology holds the promise of enhancing care for patients and communities,” Fishman continued. “America’s hospitals are committed to adopting technology but need today’s problems to be addressed to make progress for patients and communities.”
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IOM Panel Recommends Addition to Stage 3 Meaningful Use

IOM Panel Recommends Addition to Stage 3 Meaningful Use | EHR and Health IT Consulting | Scoop.it

A committee from the Institute of Medicine (IOM) has released recommended guidelines urging the federal government to include patient socioeconomic status and behavioral health data in Stage 3 Meaningful Use regulations. The IOM report was published in the New England Journal of Medicine last month.

The committee suggests incorporating a number of social determinants into EHRs and asking patients 12 questions about their socioeconomic status and behavioral health. Out of these 12 measures, four are currently being evaluated within the healthcare industry while eight are original questions. This process may cut costs in the healthcare industry as well as provide patient-centered accountable care.

Using such data could lead to improved diagnoses and treatments as well as strengthened decision making among providers. Clinicians would be able to identify risk factors more quickly by learning about a patient’s social background.

In addition to basic healthcare services, physicians would be able to refer patients to community organizations or public health departments when different issues arise such as domestic abuse. Along with these benefits, this kind of questionnaire would broaden the amount of patient data available and aid population health management strategies.

The recommendations stem from an IOM report released in November that attempted to uncover social and behavioral domains that are directly related to health outcomes, Politico reports. The panel in charge of the paper analyzed the ways to capture this data in EHR systems.

Some criticism from the American Medical Informatics Association claims that adopting this questionnaire will cause physician workflow issues as well as patient privacy complications. Additionally, some experts wondered if patients would provide honest answers to the questions.

The authors of the IOM report, however, hold a different opinion. The authors stated that by having data on socioeconomic status, employment status, and personal relationships, doctors would be able to “better partner with the patient to make informed and realistic medication choices.”

“Any new diagnostic technology or mode of therapy creates added demands and necessitates changes in practice,” William Stead of Vanderbilt University and Nancy Adler of the University of California, San Francisco, wrote in the report. “We believe that the benefits of adopting and using the measurement panel will outweigh these costs.”

Nonetheless, providers would need to take patient privacy and security into account when implementing a socioeconomic and behavioral health questionnaire in their practice. The change in workflow, however, will be minor, as much of the data can be self-reported or recorded during initial medical visits.

The most recent report hopes to expand the number of organizations involved in considering the implementation of this socioeconomic and behavioral health questionnaire. In particular, it asks the U.S. Department of Health & Human Services (HHS) to take part in including the survey within Stage 3 Meaningful Use requirements.

To qualify for the EHR incentive program under Stage 3 Meaningful Use regulations, the panel calls for behavioral health and socioeconomic data to be stored in EHR systems. Time will tell whether the federal government decides to include a behavioral health and socioeconomic survey as part of Stage 3 Meaningful Use.


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HHS calls Stage 3 rule 'flexible, clearer framework' | Healthcare IT News

HHS calls Stage 3 rule 'flexible, clearer framework' | Healthcare IT News | EHR and Health IT Consulting | Scoop.it

It's more of a requisite first step than milestone, but the Department of Health and Human Services sent the proposed rule for meaningful use Stage 3 to the Office of Management and Budget.

There’s precious little detail in these submissions, but HHS foreshadowed the major problems it intends to address with this next, and perhaps final, stage of the federal EHR Incentive Program.

"Stage 3 will focus on improving health care outcomes and further advance interoperability," according to OMB’s website. "Stage 3 will also propose changes to the reporting period, timelines and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements."

The Office of the National Coordinator for Health IT also submitted a rule to OMB proposing a new 2015 Edition Base EHR definition, as well as modifications to the ONC Health IT Certification Program, "to make it more broadly applicable to other types of health IT health care settings and programs," another OMB web page states.

ONC’s proposed rule would establish capabilities and criteria, and specify standards and implementation specifications that EHR makers must meet, to "at a minimum support the achievement of meaningful use" for customers including eligible hospitals and eligible providers looking to attest and receive incentives.

OMB ranks both proposed rules as “major” but the in the form’s legal deadline field the status is none.

Stage 3 is expected to begin in 2017.


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AMA Urges CMS to Give Hardship Exemptions for Meaningful Use

AMA Urges CMS to Give Hardship Exemptions for Meaningful Use | EHR and Health IT Consulting | Scoop.it

As the waiting game for the Stage 3 Meaningful Use final rule and Stage 2 modification rule continues, the American Medical Association (AMA) is calling on the Centers for Medicare & Medicaid Services (CMS) to start taking actions to account for their delay. According to a recent press release, AMA is asking CMS to make an automatic hardship exemption due to the delay in the final rule’s release.

According to AMA President Steven J. Stack, MD, many physicians with the AMA are concerned that they will not be able to meet meaningful use standards because the details of the Stage 2 modification rule have not yet been released.


“The AMA has regularly stressed that CMS must finalize Meaningful Use modifications well ahead of Oct. 1 to provide the time that physicians need to plan for and accommodate these changes, yet CMS has continued to delay finalizing this rule,” says Stack. “As a result, many physicians who were counting on this flexibility will be subject to financial penalties under the rules currently in place.”


An automatic hardship exemption would exempt providers of financial penalties if they are not able to meet certain meaningful use standards. CMS developed hardship exemptions for providers who can demonstrate that adhering to meaningful use rules would cause a considerable hardship. AMA maintains that the considerable delay in the final rule is viable cause for an automatic hardship exemption.

The AMA is not the only organization expressing distress over the meaningful use final rule. Many entities, such as the Medical Group Management Association (MGMA) are calling on CMS to extend the meaningful use reporting period due to the delayed final rule.

The organization is concerned that medical groups will not have time to report for the final 2015 reporting period if not given adequate notice of the new EHR Incentive Program modifications.


MGMA stated that even if the modifications rule had been announced in early September, providers still would not have had adequate time to adjust workflows for the final reporting period beginning on October 3. Instead, MGMA suggested CMS extend the reporting period to either the first 90 days of 2016, or the final 90 days of 2015.


Other entities, such as the College of Healthcare Information Management Executives (CHIME), have simply urged CMS to release the modification final rule sooner. CHIME, in addition to several other co-signing industry stakeholders, states that CMS withholding the final rule is preventing providers from having adequate time to prepare to the program modifications.

CHIME reiterated that many industry stakeholders commend CMS’ efforts to refocus meaningful use standards, but feels as though inadequate time is being given to providers to make their own adjustments in time for the October 3 final reporting period.


As the final reporting period is mere days away, CMS will need to release the final rule for the meaningful use modifications soon, or many providers will be left unable to meet the final reporting deadline.

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Stage 3 Meaningful Use ‘Too Ambitious’ on Patient Action Goals

Stage 3 Meaningful Use ‘Too Ambitious’ on Patient Action Goals | EHR and Health IT Consulting | Scoop.it

Various stakeholders have begun taking part in sending their public comments to the Centers for Medicare & Medicaid Services (CMS) with regard to the Stage 3 Meaningful Use proposed rule and the proposed modifications to Stage 2 Meaningful Use requirements for the next few years.


The College of Healthcare Information Management Executives (CHIME) released their comments to CMS about the proposed rulings on May 27. CHIME representatives found that Stage 3 Meaningful Use requirements under the proposed rule are “too ambitious” and need some significant revisions, according to a company press release.


Additionally, the organization showed complete support of CMS in reducing the EHR reporting period in 2015 from a full year to a continuous 90-day period. CMS did reduce the number of objectives under the Stage 3 Meaningful Use proposed rule and improved the reporting periods, but the high number of total proposals for the Stage 3 portion was thought “unworkable” by CHIME representatives.

“Were all requirements finalized as proposed, we doubt many providers could participate in 2018 successfully,” CHIME stated in its public comments. “And with so few providers having demonstrated Stage 2 capabilities, we question the underlying feasibility of many requirements and question the logic of building on deficient measures.”


There are specific steps CHIME offered that may


improve attestation to Stage 3 Meaningful Use requirements if CMS integrates the suggestions in the final ruling. These steps are:


1) Requiring a 90-day reporting period under Stage 3 Meaningful Use regulations for the first year of attestation

2) Retain the same 90-day period for any eligible healthcare provider participating in the Medicare or Medicaid EHR Incentive Program for the first time

3) Discontinue patient action thresholds under the patient portal objectives

4) Reduce the number of measures in certain encompassing objectives like health information exchange and care coordination

5) In limited circumstances, give providers the opportunity to meet objectives via paper-based means

6) Give providers a 90-day remission in any calendar year for program upgrades, bug fixes, or EHR optimization


CHIME was especially concerned with “unrealistic” health information exchange measures and the ongoing uncertainties around patient action objectives. CMS proposed that modified Stage 2 Meaningful Use requirements would mandate that only one patient among a provider’s consumer base would need to view, download, and transmit their health data. However, under the Stage 3 Meaningful Use proposed rule, this requirement goes up to 25 percent of the patient population among eligible hospitals and professionals. CHIME was also concerned that attesting to Stage 3 by 2018 was too soon and providers would not be ready.


“While we acknowledge policymakers’ intention to make each Stage more difficult than the last, we are concerned with the strategy that envisions Stage 3 serving as both the apex of MU requirements and as a starting point for those providers with no experience at Stage 1 or Stage 2 of the EHR Incentive program,” CHIME said. “We worry some of the objectives pose too great a stretch for seasoned meaningful users, let alone those who have never participated in the program.”

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Beacon Partners’ Bruce Eckert on the Proposed Stage 3 Rule for Meaningful Use—and Beyond

Beacon Partners’ Bruce Eckert on the Proposed Stage 3 Rule for Meaningful Use—and Beyond | EHR and Health IT Consulting | Scoop.it

Bruce Eckert, the national practice director at Beacon Partners Healthcare Management Consultants, leads the strategy, business intelligence, and meaningful use teams at the Weymouth, Mass.-based consulting firm, which recently merged with the New York-based KPMG.

In a meeting at the McCormick Place Convention Center in Chicago with HCI Editor-in-Chief Mark Hagland on Monday, April 13 during the HIMSS Conference, Eckert responded to Hagland’s questions about meaningful use and other issues facing the industry.


Asked about the proposed change to Stage 2 meaningful use requirements that would change the previous requirement that eligible providers get 5 percent of their patients to view, download, and transmit their health information to requiring that only one patient do so—with the anticipation that 25 percent of patients must then view, download and transmit under Stage 3, he admitted that he was as puzzled as everyone else seemed to be, and expressed the hope that federal officials at the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) would clarify that point soon.


Below are additional excerpts from their Monday interview.

What do you think of the Stage 3 proposed rule overall?

I like the structure, in that they're very compressed things down to 8 measures, and the menu sets are embedded in the measures. And they're collecting higher level data than before. So it's a nice framework. And we just did a HIMSS focus group around patient engagement. We had 12 people. Not universally but many are having challenges getting patients to use portals. Not so many problems with secure messaging, because the patients find value in it. So what the patients find value in, works well.


One of the challenges, it seems, continues to be timelines. Your thoughts?


Clearly in my mind, CMS is still trying to recover from the 2014 vendor certification debacle, with a lack of time to catch up. And they're setting up possibly the same timeline compression on the vendor side again coming into Stage 3. But I do think we've learned something from the 2014 CEHRT debacle. And perhaps this flexibility will help, because it might provide some breathing room for organizations.

You’ve just finished moderating a focus group with a diverse group of healthcare IT leaders. What kinds of concerns did they talk about?

They talked about things like appointment reminders, and push messaging for diagnostic results. And they didn't seem to think the patient education element in meaningful use would be difficult.

Overall, how did they perceive the challenges of Stage 3?

Most said it would be challenging, but doable, as long as they get the 2015 CEHRT in, in time. There's nothing really revolutionary in Stage 3, to be honest. And though it's not specifically on there, I think we'll see widespread adoption of PHRs, because a lot of the requirements wrap around that.


Who will manage the personal health record has long been a practical issue in the industry. Has that question been resolved?


Not entirely, but there will be third parties. And if you look at how HealthKit and HealthVault are architected, they really do give the patient the power. So I really do see third party vendors doing this. The issue would be whether they would be considered business associates under HIPAA. But if they add data in, the providers, then they would be covered. But I’ll predict that PHRs will be widely adopted under Stage 3. And I think we're approaching the end of the HIE [health information exchange] era. I attended the ONC's annual meeting in February. And they had a panel with all the former national coordinators together. And one of them said, the honest truth we have to face is that there's no business model for HIEs. That's evidence number one And look at the way meaningful is going. CMS is effectively supporting DIRECT protocols. I can see that whole infrastructure development—from regional HIEs to state HIEs to some anticipated nationwide infrastructure, simply not coming to fruition in the end. I think we're going to see the end of HIEs.


What should our audience be thinking about in the next few years?

Having more data, better data, and the ability to analyze data, will be key. Those organizations that manage and analyze data better will succeed, those that don't, won't. And we really moving in the direction of intensive data consumption, analytics, and management going forward, partly because of the impact of meaningful use.


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Six Things to Know About Stage 3 of Meaningful Use

Six Things to Know About Stage 3 of Meaningful Use | EHR and Health IT Consulting | Scoop.it

Have you had a chance to read through the proposed rule for the Stage 3 rules of the government's EHR incentive program? If not, we've got you covered.

Here are six things to know about the proposed rule:


1. The rule proposes a significant change to the structure of the meaningful use program by establishing a single stage for meaningful use (Stage 3) starting in 2018. This means that in 2018 and following years, all providers (regardless of prior participation in the program) would need to meet the Stage 3 rules. In 2017, providers could participate in Stage 1, Stage 2, or Stage 3, but in 2018, all would need to attest to Stage 3. The proposed rule notes that the program requirements may change slightly in future years, but Stage 3 would remain the final stage moving forward.

 

2. The proposed rule indicates that Stage 3 would continue to "build on the groundwork" established in Stage 1 and Stage 2.  Many of the measures included in the proposed rule focus on increasing interoperability, information exchange, and patient engagement. Though many of the measures associated with these initiatives are similar to the measures in Stage 2 (but with higher thresholds), there are also some new measures associated with them.


3. The proposed rule establishes a full-year reporting period. The proposed rule specifies that the meaningful use reporting period would be a full year for both physicians and hospitals starting in 2017 and in future years. The only exceptions would be Medicaid eligible providers and hospitals attesting to meaningful use for the first time (they would have a 90-day period).


4. The proposed rule requires electronic quality reporting. Starting in 2018, CMS would require electronic quality reporting for providers who would need to implement five clinical decision support interventions related to four or more quality measures.


5. The proposed rule includes fewer objectives in Stage 3, but many of the measures associated with these objectives may be more challenging. Providers would only need to meet eight objectives in Stage 3 (though some of these objectives have multiple measures associated with them). The proposed rule also includes new requirements that may be difficult for providers.

 

6. The proposed rule includes some flexibility when it comes to the requirements. The proposed Stage 3 objectives include some flexibility, which could make it easier for providers to successfully attest. For instance, for the "coordination of care through patient engagement" objective, providers would only need to meet thresholds of two of three measures and attest to the numerators and denominators of all three measures. And, for the "health information exchange" objective, providers would need to meet the thresholds of two of three measures and attest to the numerators and denominators of all three measures.


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How Stage 3 MU Concerns Impact EHR Incentive Programs

How Stage 3 MU Concerns Impact EHR Incentive Programs | EHR and Health IT Consulting | Scoop.it

The Medicare and Medicaid EHR Incentive Programs will be impacted by the latest Stage 3 Meaningful Use proposed rule. The proposed ruling calls for stricter security measures for protecting patient health information, increasing the amount of electronic prescribing and computerized order entry conducted in hospitals and physician practices, and pushing forth patient engagement efforts.

“Transmitting the prescription electronically promotes efficiency and patient safety through reduced communication errors,” the Stage 3 Meaningful Use proposed ruling states. “It also allows the pharmacy or a third party to automatically compare the medication order to others they have received for the patient that works in conjunction with clinical decision support interventions enabled at the generation of the prescription.”

Currently, there is a comment period in which providers, vendors, and other stakeholders can offer their perspective on some of these meaningful use requirements and state which objectives are not achievable.

Once the final ruling for Stage 3 Meaningful Use requirements is established, however, providers who are unable to meet the objectives will need to file a hardship exemption and ensure there is evidence of their burden. Otherwise, these healthcare providers will receive a payment penalty from the Centers for Medicare & Medicaid Services (CMS).

The healthcare providers who do meet Stage 3 Meaningful Use objectives, on the other hand, will receive payment incentives from CMS. While some hospitals and practices have seen financial incentives from the Medicare and Medicaid EHR Incentive Programs, others have been burdened with payment penalties as well as the major financial investment from implementing EHR systems, according to the JD Supra publication.

With around half of healthcare providers not meeting Stage 2 Meaningful Use requirements, it remains to be seen whether the federal government will ease its restrictions and allow more time for struggling healthcare professionals to catch up.

Some are concerned over the set objectives in the Stage 3 Meaningful Use proposed ruling such as the goal of ensuring 25 percent of patients view and download their health information through portals.

Another major complication that CMS set forth is the requirement of all eligible hospitals and providers to attest to Stage 3 Meaningful Use by 2018 regardless of prior attainments. There will also be an optional period in 2017 to attest to Stage 3 Meaningful Use requirements. Those who feel incapable of meeting Stage 3 within the next three years should send comments to CMS and the Office of the National Coordinator for Health IT (ONC) before the May 29 deadline.

Others are concerned with the EHR reporting period beginning in 2017, which will require providers to report on a full calendar year. However, this system is meant to align the Medicare and Medicaid EHR Incentive Programs with other CMS initiatives such as the Physician Quality Reporting System.

Even with the many issues surrounding reaching Stage 3 Meaningful Use requirements, the proposed ruling aims to improve quality of care by expanding health information exchange, EHR interoperability, and patient engagement efforts.

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Breaking Down the Health IT Impacts of Stage 3 Meaningful Use

Breaking Down the Health IT Impacts of Stage 3 Meaningful Use | EHR and Health IT Consulting | Scoop.it

The Centers for Medicare and Medicaid Services (CMS) released its proposed rule for Stage 3 meaningful use on March 20, revealing the hotly anticipated provisions for the final phase of the EHR Incentive Programs.


Raising the bar on some of the toughest aspects of Stage 2 while requiring healthcare providers to make some significant leaps in EHR adoption and care delivery by 2018, the Stage 3 meaningful use framework poses some difficult questions for eligible providers and hospitals struggling with interoperability and the burdens of leveraging EHRs for patient care.


From health IT interoperability to privacy and security to big data analytics, the impacts of Stage 3 will touch nearly every aspect of the healthcare industry in the next few years.

What are some of the key issues providers must keep in mind as 2018 approaches and the EHR Incentive Programs eventually come to an end?


Top 8 goals of the Stage 3 meaningful use proposed rule


The objectives and thresholds in Stage 3 urge providers to new heights in patient care by encouraging more extensive use of health information exchange, e-prescribing, clinical decision support, and computerized provider order entry (CPOE).  CMS also hopes to increase patient engagement substantially over Stage 2 levels and promote the coordination of care through expanding access to personal health information.  Read a summary of the eight major objectives included in CMS’ plan for the industry.


Interoperability key to Stage 3 meaningful use requirements


Industry-wide EHR interoperability is the ultimate goal of the EHR Incentive Programs, and Stage 3 hopes to bring providers closer to widespread health information exchange than ever before.  “The flow of information is fundamental” to better care, healthier patients, and reduced costs, says HHS Secretary Sylvia Burwell, but the path towards meaningful interoperability has been a difficult one.  Stage 3 intends to address some of the major barriers to interoperability by raising thresholds and benchmarks for health information exchange.


Can Stage 3 meaningful use CEHRT bring on big data analytics?


Stage 3 brings some major changes to the way EHR technology is certified and designed in accordance with the EHR Incentive Programs’ growing emphasis on healthcare analytics and population health management.  With the newly-named “health IT modules” presenting opportunities and challenges for providers seeking to gear up for the optional 2015 Edition Certified EHR Technology (CEHRT) criteria, how will the new provisions for EHR development allow the technology evolve into meaningful tools for big data analytics and effective care coordination?


How does Stage 3 meaningful use affect health data privacy?


As CMS turns its attention to interoperability and increased data exchange, patient privacy and security measures will become ever more important to the industry.  Continued confusion over meaningful use and the HIPAA Security Rule has left many providers asking questions about how they can protect their patients’ electronic personal health information (ePHI) in the face of data breach after data breach.  Learn how Stage 3 hopes to simplify patient data privacy and security measures for providers in this breakdown of the Stage 3 proposal from HealthITSecurity.com.


What does the Stage 3 meaningful use rule mean for analytics?


How will Stage 3 build on existing infrastructure to encourage healthcare analytics to thrive?  By leveling the playing field and requiring providers to meet all the same measures in 2018.  This controversial proposal may leave some lagging organizations in the lurch, but with the help of the ONC’s Common Clinical Data Set, it would create rich opportunities for informaticist and population health managers.  Will Stage 3 be the push the industry needs to expand its budding analytics capabilities?


ONC proposes 2015 health IT certification criteria rules


The 2015 CEHRT criteria, released in conjunction with the Stage 3 rule, have significant implications for healthcare privacy and security.  By opening up the certification program to include new types of health IT, and therefore new types of patient data, the ONC plans to achieve widespread interoperability.  How will federal rule makers ensure that personal health information is sufficiently protected without overburdening providers and EHR developers?



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Preparation, Patient Engagement Key to Meaningful Use

Preparation, Patient Engagement Key to Meaningful Use | EHR and Health IT Consulting | Scoop.it

As the industry awaits the next set of objectives and measures for the Stage 3 rules of meaningful use next month, practices are still facing the challenge of meeting Stage 2 requirements for 2015.

Last month, CMS gave assurances of redefined Stage 2 rulemaking to help ease the reporting burden on providers. The forthcoming communication from CMS is intended to be responsive to concerns about software implementation, information exchange readiness, and other related concerns.

Despite the uncertainty, physicians will have to prepare for the Stage 2 rules of meaningful use for the calendar year.

In 2015, CMS data indicate more than 260,000 physicians will have to meet Stage 2 requirements. CMS estimates that more than 257,000 eligible professionals will receive payment penalties in 2015, which casts further doubt about the likelihood of high levels of physician participation.

Shaun Conrad, a manager in Ernst & Young's Americas Health Care Practice, said physicians have been having difficulty with some of the specific objectives of Stage 2.

"The biggest challenge is probably the electronic transmission and the patient portal," said Conrad. "Getting patients to engage can be very difficult and since the measure itself is reliant on the patient being engaged by logging into the portal, but they still need to view, download, or transmit that data in order for the provider to get credit ... there's a lot of changes there where you have to change your culture internally."

"Physician practices should look at having dedicated administrative staff help physicians manage meaningful use, Physician Quality Reporting System (PQRS), and other … quality-related incentive programs," said Rafi Tabib, managing consultant within Navigant's healthcare practice. "If possible, a well-rounded team with knowledge of the EHR functionality, reporting/data analytics, and program requirements, should be put together. The amount of dollars at stake in incentives and penalties warrants such a team."

Get the Data Moving

Mary Griskewicz, senior director of health information systems for the Healthcare Information and Management Systems Society, said she has seen work flow changes affecting her local family physician's office since it implemented an EHR.

"Since they've implemented EHRs they are much more thorough upon entry into the practice," Griskewicz said. "Now on the back-end, they should be giving the patient the information and follow-up instructions and, if they haven't signed up for your portal, let's get them signed up. That's the change in thinking and culture that's needed."

Naomi Levinthal, senior consultant and healthcare IT adviser for The Advisory Board Company, warns that transitions of care measures are incredibly complex and will require practices to know in advance how they will send summary of care records both internally and outside of their offices.

"Practices with a robust patient engagement initiative that includes clinician involvement may be able to meet the secure messaging [requirement] and view, download, and transmit measures of Stage 2 with greater ease," Levinthal said.

Levinthal said providers would be wise to focus on three key actions this year.

• Assign a practice staff person the responsibility to keep on top of meaningful use-related news, and determine whether there are any impacts to current plans.

• Be well-prepared for audits with a comprehensive book of evidence and an internal policy on how the practice would respond to an audit notice.

• Identify ways to align meaningful use with other practice initiatives, for example, electronic quality reporting or population health management.

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Stage 3 Meaningful Use proposals at White House for final review

Stage 3 Meaningful Use proposals at White House for final review | EHR and Health IT Consulting | Scoop.it

Why do these things always seem to happen late on Friday afternoons? At least this time it’s not right before a holiday. Actually, with a bit more inspection, I see that it did happen right before a holiday.

HIMSS is reporting today that the White House’s Office of Management and Budget is “in its final stages of review” of the proposed rules for Stage 3 of the Meaningful Use EHR incentive program. OMB always goes over proposed and final regulations to measure the fiscal — and, presumably, political — impact before allowing executive-branch agencies to make public releases.

A peek at OMB’s reginfo.gov site indicates that the MU Stage 3 proposal from CMS and related ONC plan for certification of EHRs are indeed at OMB for final review.

“We are proposing the Stage 3 criteria that [eligible professionals], eligible hospitals, and [Critical Access Hospitals] must meet in order to successfully demonstrate meaningful use under the Medicare and Medicaid EHR Incentive Programs, focusing on advanced use of EHR technology to promote improved outcomes for patients. Stage 3 will also propose changes to the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements,” CMS states in a rule summary on the OMB site.

A placeholder date (“02/00/2015 “) on the same page suggests that the proposal will be published in February. However, a placeholder date on the page for the forthcoming ONC certification standards indicates that the plan was supposed to come out in November.

And the date the two notices appeared on the reginfo.gov? Dec. 31, when pretty much everyone was already checked out for the extended New Year’s weekend.

Stage 3 is scheduled to start no earlier than Oct. 1, 2016, for hospitals and Jan. 1, 2017, for individual providers.


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OMB Reviewing Proposed Stage 3 Meaningful Use Requirements | EHRintelligence.com

OMB Reviewing Proposed Stage 3 Meaningful Use Requirements | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it

The Centers for Medicare & Medicaid Services is one step closer to issuing a notice of proposed rulemaking (NRPM) for the next stage of meaningful use requirements for the Medicare EHR Incentive Program.

The Office of Management and Budget (OMB) is currently reviewing the proposed rule for Stage 3 Meaningful Use that is expected to be published in February.

Few details about the requirements for Stage 3 appear in the rule submitted to the OMB by the Department of Health & Human Services as part of the Unified Agenda — that is, with the exception of the following:

In this proposed rule, CMS will implement Stage 3, another stage of the Medicare and Medicaid EHR Incentive Program as required by ARRA. We are proposing the Stage 3 criteria that EP’s, eligible hospitals, and CAHs must meet in order to successfully demonstrate meaningful use under the Medicare and Medicaid EHR Incentive Programs, focusing on advanced use of EHR technology to promote improved outcomes for patients.  Stage 3 will also propose changes to the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements.

The rule before the OMG also indicates that CMS will coordinate with the Office of the National Coordinator for Health Information Technology to ensure that EHR certification criteria and certified EHR technology will be in place when Stage 3 goes into effect no earlier than 2017.

During a Health IT Policy Committee meeting in March, the group voted to approve 19 objectives recommended by the Meaningful Use Workgroup. Those recommendations fall into four categories of care improvements:

Improving Quality of Care and Safety
1. Clinical decision support
2. Order tracking
3. Demographics/patient information
4. Care planning — advance directive
5. Electronic notes
6. Hospital labs
7. Unique device identifiers

Engaging Patients and Families in their Care
8. View, download, transmit
9. Patient generated health data
10. Secure messaging
11. Visit Summary/clinical summary
12. Patient education

Improving Care Coordination
13. Summary of care at transitions
14. Notifications
15. Medication reconciliation

Improving Population and Public Health
16. Immunization history
17. Registries
18. Electronic lab reporting
19. Syndromic surveillance

Before any of the proposed rule’s requirements for Stage 3 Meaningful Use are enacted, the NPRM must made available for public comment which has the potential to influence the requirements of the final rule. Given the resistance CMS has faced as a result of Stage 2 Meaningful Use, the federal agency is likely to receive requests for greater flexibility and timing from healthcare organizations and industry groups.


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