Studies show that the majority of providers pursuing Meaningful Use (MU) have attested only to Stage 1, and many are questioning whether to proceed further. Yet, for those who have made the decision to invest in technology and make the effort to attest to Stage 2, there remains good reason to stay the course – provided that the Final Rules reflect provider concerns voiced during the commenting period.
When the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) released their proposed rules outlining the requirements for Meaningful Use Stage 3 in March 2015, CMS promised that Stage 3 would give providers more flexibility. On close examination, achieving the most expanded requirements in Stage 3 seems challenging, from both a timeline and technology perspective, as issues related to interoperability and data sharing are not entirely in the provider’s control.
Primary objectives of MU Stage 3
With the delays to Stage 2 due to vendors’ inability to meet timelines for 2014 Edition CEHRT, the earliest that health organizations can begin reporting against Stage 3 criteria is 2017 – and they must begin in 2018, regardless of prior participation or stage of Meaningful Use.
The eight Stage 3 advanced-use objectives to be met during that timeframe are:
- Protect electronic health information;
- Clinical decision support;
- Computerized provider order entry;
- Patient electronic access to their data;
- Coordination of care through patient engagement;
- Health information exchange; and
- Public health reporting.
Perhaps the most perplexing of the Stage 3 requirements concerns objective six from the above list: coordination of care through patient engagement. Stage 2 offers a reduction from a threshold of 5 percent of patients to just one patient. The idea is simply demonstrating that providers have built out certain capabilities, rather than having a percentage of patients take specific actions. Yet, in Stage 3 there is a proposed increase to a threshold of 25 percent of patients. Many providers are raising questions as to the reasons behind the seeming reversal in re-instating a threshold at a much higher level. There is real hope that the agencies will address this confusion, as many providers feel strongly that they cannot control their patients’ use (or lack of use) of technology.
Objective seven from the list above, health information exchange, poses potential issues for health organizations meeting Stage 3 due to technology lagging behind regulatory expectations. This objective calls for the electronic transfer of continuity of care documents (CCDs), an activity that has defaulted to the use of DirectTrust to satisfy security requirements. Yet DirectTrust has not become as prevalent as expected, largely due to its inability to fit into existing workflows. Satisfying this requirement will depend on DirectTrust becoming much more commonplace in advance of 2018.
Similarly, objective eight from the list above is intended to drive health reporting to public registries. State registries are not typically equipped to facilitate connections with providers at even modest levels today, let alone for the escalating number of connection requests they will likely receive as a result of this objective. Connectivity to these registries will need to become much more automated over the next couple of years to accommodate them, which is again out of provider control.
With the timeline and technical challenges that lie ahead in moving from Stage 1 (where most are today) to Stage 2 – and ultimately attesting to Stage 3 by 2018 – some in the industry are fervently hoping that truly sweeping changes will permanently alter the Meaningful Use landscape. Some larger organizations are quietly contemplating their options, leaving very expensive technology and infrastructure investments in limbo, at least for now.
Getting to Stage 3
From a high-level and timeline perspective, the entire Meaningful Use program has always had three primary goals:
- Provide an incentive for adoption of technology;
- Improve patient outcomes; and
- Share health data widely.
The program has undoubtedly achieved goal one. The jury remains out on goal two, if for no other reason than providers simply have not been able to complete Stage 2. Time will tell, but advanced features should begin to drive better outcomes, and those who strive for Stage 2 attestation will maintain a competitive advantage.
As far as goal three, the technology to fully meet interoperability requirements is still evolving and far from mature, as noted above. While there is widespread agreement that this is a worthy – and vital – objective for achieving the promise of better care coordination, improving outcomes, and reducing cost, overcoming the technical hurdles remains a challenge.
With the Final Rule for Stage 3 now here, the ultimate hope is that by 2018 these new rules will improve the broader care delivery system.