- Since finalizing the Stage 3 Meaningful Use requirements, the Centers for Medicare & Medicaid Services (CMS) has received numerous calls for a pause in the program. Industry stakeholders argue that the program is too demanding and burdensome for providers to achieve meaningful use success.
Also, CMS issued a proposed rule for MACRA implementation that replaces meaningful use for Medicare physicians. As a result, Stage 3 Meaningful Use only applies to hospitals at this time.
As the third iteration of the EHR Incentive Programs moves closer, its looming requirements are still top of mind for many providers, with the most intrepid working to mitigate the difficulties that are causing the most apprehension.
Below, EHRIntelligence.com outlines some of the most challenging meaningful use requirements.
Health information exchange
Stage 3 Meaningful Use in large part aims to facilitate the secure and efficient movement of health information stored in certified EHR technology. A significant aspect of this is requiring more robust health information exchange (HIE).
Under Stage 3 Meaningful Use, CMS has included the follow HIE requirements:
- Provider to provider exchange through the transmission of an electronic summary of care document;
- Provider to patient exchange through the provision of electronic access to view, download, or transmit health information; and
- Provider to public health agency exchange through the public health reporting objectives.
Achieving three HIE measures requires providers to rely on the capabilities of their certified EHR systems as defined by the Office of the National Coordinator for Health Information Technology (ONC).
"The program leverages the ONC HIT Certification Program and the associated editions of certification criteria to ensure that eligible providers possess health IT that conforms with standards and the requirements for the capture and exchange of certain data in a structured format," the rule states. "This improves interoperability by ensuring that data within one system can be received and used by the recipient system."
The rule also calls for the increased use of application programming interfaces (APIs) which enable patients to view, download, and transmit (VDT) their health data across different EHRs. Providers are responsible for explaining to patients that these capabilities exist.
So long as providers make it clear to patients that they may view, download, and transmit this data, and the patient does so, providers may count these patients are a part of the meaningful use attestation process.
Patient engagement and access to data
As a part of the patient engagement requirements, meaningful users must use CEHRT to engage five percent of patients or caregivers in 2017 for those opting to begin Stage 3 Meaningful Use one year earlier. In 2018, meaningful users must engage 10 percent of patients or caregivers.
These requirements put an emphasis on using APIs to exchange data between the patient and the provider.
Providers will also have to step up their patient-provider communication game come 2017 by responding to five percent of secure patient messages. In 2018, meaningful users will need to respond to 25 percent of secure patient messages.
Prior to publication of the final rule, many industry stakeholders spoke out against the Stage 3 Meaningful Use patient engagement requirements.
“We think this 25 percent threshold is a showstopper that has to be changed,” stated Robert Tennant, Senior Policy Advisor at the Medical Group Management Association (MGMA). “And we’ll be pushing for that and working with our other colleagues in the provider community on that message.”
Katherine Downing, MA, RHIA, CHPS, PMP, from the American Health Information Management Association, agreed.
“The 25 percent threshold does seem pretty aggressive,” she said. “But it really is such an important step to patient engagement. We want our patients to catch errors. We want them to help ensure that providers who might not have access to health information exchange data aren’t repeating tests. We need them to engage.”
Clinical quality measures
Providers and hospitals are also proving to find clinical quality measure (CQM) reporting a daunting task, despite CMS efforts to streamline them.
According to a survey conducted in collaboration with the American Hospital Association (AHA) and the Federation of American Hospitals (FAH), 37 percent of hospitals have a considerable amount of work to do prior to reporting CQMs. Forty-one percent have at least some work to do.
The reason for these difficulties lay almost entirely in hospital EHRs. Respondents frequently listed an inadequate EHR or a newly implemented or optimized EHR as their primary concern for CQM reporting.
Under the final rule for Stage 3 Meaningful Use, CMS will address CQMs as part of the inpatient prospective payment system (IPPS).