New Meaningful Use Stage 3 Proposed Rule Focuses on Advanced Use of Electronic Health Record Systems

On Friday, March 30, 2015, the Centers for Medicare & Medicaid Services (CMS) announced their proposed rule for Stage 3 of the Meaningful Use (MU) Incentive Program. The proposal was published in the Federal Register and is available online. CMS is accepting public comments on the proposal until May 29^th.

Meaningful Use Stage 3, the last stage of the Meaningful Use Program, comes with some potentially exciting improvements for patients and gives providers more flexibility regarding how they meet many of the Meaningful Use Program objectives. The proposed rule incorporates learnings from Stages 1 and 2. In addition to giving healthcare providers (HCPs) further flexibility, it makes the program simpler, drives interoperability among EHRs and increases focus on improved outcomes for patients. Importantly, Stage 3 also relies on more advanced use of electronic health record (EHR) systems.

The proposed Stage 3 Meaningful Use Program objectives fall into four general groupings:

1. Stricter security processes to protect patient health information
2. Increased electronic prescribing
3. Use of clinical decision support
4. Enhanced sharing of data with patients and other healthcare providers

Following is a summary of the eight program objectives:

Objective 1: Protect Patient Health Information

• The Stage 3 ruling proposes enhancing attestation for HIPAA compliance by adding administrative requirements. Specifically, it would require that a security risk analysis be conducted and submitted with each reporting period.
• You can find broad scale guidance on security risk analysis requirements from The Office for Civil Rights (OCR).

Objective 2: Electronic Prescribing (EP)

• CMS recommends increasing the threshold among eligible hospitals and clinics.
• The proposal requests that eligible providers send more than 80 percent of their drug/treatment prescriptions electronically through certified EHR systems.
• More than 25 percent of hospital discharge medication orders may need to be electronically prescribed.

Objective 3: Clinical Decision Support (CDS)

• This objective seeks to improve performance on high-priority health conditions by incorporating clinical decision support tools (CDS) and strategies through certified EHR technology.
• CMS suggests that eligible providers implement five interventions that adhere to at least four clinical quality measures (CQMs) at certain points in patient care for the whole EHR reporting period.
• The second measure is for eligible hospitals and providers to incorporate tools for drug-drug and drug-allergy interaction alerts for the entire EHR reporting period.

Objective 4: Computerized Provider Order Entry (CPOE)

• Stage 3 continues to emphasize the importance of using CPOE for medication, laboratory, and diagnostic imaging orders.
• Three specific measures are outlined in the proposed ruling for implementation during the EHR reporting period:
  • Eligible providers will need to use CPOE for more than 80 percent of medication orders.
  • More than 60 percent of laboratory orders created by the eligible providers will need to be recorded through the CPOE.
  • Asks for eligible providers to use CPOE for more than 60 percent of diagnostic imaging orders.

Objective 5: Patient Electronic Access to Health Information

• This objective calls for eligible hospitals and providers to offer patients electronic access to view, download, and transmit (in other words, share) their health information within 24 hours of its availability.
• More than 25 percent of patients seen or discharged from a hospital or emergency department (ED) must “actively engage” with their electronic records.
• This requirement must be met using electronic, certified EHR technology and can be done either through patient portals or through the use of an application-program interface (API). APIs are technical protocols that enable third-party software programs to interact with an application. A good example of an API is what Apple provides to developers who develop apps that are in the App store. APIs are an exciting development as they have the potential to further facilitate patient electronic access by improving data sharing efforts and giving patients more flexibility to receive their data in patient portals, engagement applications and other services.

Objective 6: Coordination of Care through Patient Engagement

• Specifically, the initiatives focus on improving the communication channels between healthcare providers and patients and improving health literacy among the patient population.
• The goal is for healthcare professionals to increase utilization of the secure and private communication capabilities of certified EHR technology (i.e. secure messaging) to work with patients or authorized caregivers regarding the patient’s care.
• Additionally, CMS recommends expanding the number of communications options including the use of APIs (see the previous objective).

Objective 7: Health Information Exchange (HIE)

• This objective relates to sharing health information among various providers quickly and efficiently to decrease medical errors and improve patient safety.
• It calls for physicians to deliver summary of care records when transitioning patients among different healthcare settings, accessing summary of care records during the first meeting with a new patient and integrating these records from other providers into their certified EHR technology.
• Eligible providers and hospitals must create a summary of care and electronically exchange it with other providers for more than 50 percent of transitions of care and referrals.
• In more than 40 percent of these transitions of care, the provider has to incorporate in its EHR a summary of care from an EHR used by a different provider.

Objective 8: Public Health and Clinical Data Registry Reporting

• The proposal calls for Healthcare providers to be actively engaged with a Public Health Agency or Clinical Data Registry to submit electronic public health data in a meaningful way using certified EHR technology.
• For Stage 3, they are proposing to remove the prior “ongoing submission” requirement and replace it with an “active engagement” requirement.
• In more than 80 percent of transitions of care, the provider has to perform a “clinical information reconciliation” that includes not only medications and allergies, but also problem lists.

Meaningful Use Stage 3 would not begin until January of 2017 (“optional year”) and would be required beginning in January of 2018 (regardless of prior participation). It would also require reporting on a calendar-year basis starting in 2017. Even though Stage 3 won’t go into effect for another couple years, it’s important to start thinking about the requirements now, to ensure that practice IT investments, workflow designs, and vendor selections align with this future direction.

Navigating Cancer Can Help

As the patient care and engagement solution for cancer care, Navigating Cancer is committed to meeting all the patient centered care requirements of HITECH and the Commission on Cancer, and helping you prepare for value based care. Navigating Cancer has achieved the ONC HIT 2014 Edition Modular EHR Certification and will continue to help you meet the requirements of Meaningful Use today, and Stage 3 requirements in the not-too-distant future.

In addition to helping practices efficiently meet these patient centered care requirements, we’re focused on providing a friendly, intuitive, and simple solution that patients want to use to participate, engage and better manage their care.

If we can help you with your patient-centered care technology and establish your plan to meet Stage 3 requirements, please contact Navigating Cancer here.

To read the Stage 3 Meaningful Use rule proposal, click here.