Meaningful Use Stage 3 Recommendations Advance to CMS Where Public and Provider Input is Welcome Now, Before Becoming Regulations In Fall 2014

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May 7, 2014
Moses Suarez
SmithAmundsen Health Care Alert

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The HITECH Act was created to improve health care quality and efficiency through the exchange of electronic health information using health information technology (HIT). Financial incentives are given by Medicare and Medicaid EHR Incentive Programs for the “meaningful use” (MU) of certified EHR technology. Providers obtain incentives by evidence they are “meaningfully using” their EHRs by meeting thresholds for a number of objectives. The EHR Incentive Programs are staged in three steps with increasing requirements for participation. Meaningful use includes both a core set and a menu set of objectives that are specific to eligible professionals (EPs) or eligible hospitals (EHs) and critical access hospitals (CAHs). Under Stage 1, EPs must complete 15 core objectives, 5 out of 10 menu set objectives, and 6 clinical quality measures1. EHs and CAHs must complete 14 core objectives, 5 out of 10 menu set objectives, and 15 clinical quality measures2.

Beginning this year, EHR Incentive Program participants who met Stage 1 must meet MU Stage 2 criteria, which include new objectives. Under Stage 2, EPs must now report on 17 core objectives and 3 out of 6 menu objectives. EHs and CAHs must now report 16 core objectives and 3 out of 6 menu objectives. In addition to meeting the new objectives of Stage 2, this stage also required upgrading previously certified EHR technology to new certification standards3. As all providers must upgrade or adopt newly certified EHRs in 2014, all providers regardless of their stage of MU are only required to demonstrate MU for a 90-day EHR reporting period in 2014.

More recently on March 11th, the Health IT Policy Committee (HIPTC) voted to approve the Meaningful Use Workgroup’s recommendations for Stage 3. The proposed regulations for meaningful use Stage 3 are expected to be released by CMS in the fall of 2014. Approving Stage 3 recommendations is significant because of the issues that providers are experiencing with Stage 2 implementation. Still, the workgroup believed that advancing Stage 3 will maintain the pace of full HIT implementation. Stage 3 recommendations included 19 objectives in four categories: improving quality of care and safety, patient engagement, care coordination, and population management:

Improving Quality of Care and Safety Engaging Patients and Families in their Care
  • Clinical decision support
  • View, download, transmit
  • Order tracking
  • Patient generated health data
  • Demographics/patient information
  • Secure messaging
  • Care planning – advance directive
  • Visit Summary/clinical summary
  • Electronic notes
  • Patient education
  • Hospital labs
 
  • Unique device identifiers
 
Improving Care Coordination Improving Population and Public Health
  • Summary of Care at Transitions
  • Immunization history
  • Notifications
  • Registries
  • Medication Reconciliation
  • Electronic lab reporting
 
  • Syndromic surveillance

These recommendations essentially enhance Stage 2 measures, reclassify certain Stage 2 menu objectives to core objectives, introduce new core and menu objectives, and require more EHR technology certification criteria, which include:

Enhanced Stage 2 Measures:

Reclassified Menu to Core Objectives:

New Core Objective:

New Menu Objectives:

Additional EHR Technology Certification includes:

Since the MU workgroup recognizes provider concerns for advancing MU Stage 3 recommendations while providers are encountering difficulty in Stage 2 implementation, the workgroup is planning listening sessions every month this year for the public and HIT stakeholders to share their feedback. For a list of scheduled MU workgroup sessions visit http://www.healthit.gov/FACAS/meetings/18.

1 EPs must report on 6 total clinical quality measures: 3 required core measures (or 3 alternate core measures) and 3 additional measures (selected from a set of 38 clinical quality measures).

2 Eligible hospitals and CAHs must report on all 15 of their clinical quality measures.

3 45 C.F.R. 170.314; Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology, 2014 Edition, 45 Fed. Reg. 54163 (Sept. 4, 2012).