While the Centers for Medicare & Medicaid Services' proposed rule for Stage 3 of Meaningful Use represents an ambitious attempt to jumpstart interoperability in the healthcare industry, there are concerns that it could be a difficult row to hoe for providers.
For instance, John Halamka, CIO of Beth Israel Deaconess Medical Center in Boston, in a conversation with FierceEMR, said that his concern is that the thresholds proposed are not aligned with what is achievable in the marketplace today.
Specifically, Halamka (pictured right), who also serves on FierceHealthIT's Editorial Advisory Board, called the following "stretch goals:"
- More than 25 percent of patients seen by an eligible professional (EP) or discharged from a hospital or emergency department (ED) must "actively engage" with their electronic records
- For more than 35 percent of patients seen by an EP or discharged from a hospital or ED, a secure message must be sent using the EHR's secure messaging function or in response to a secure message sent by the patient
- Patient-generated data from a nonclinical setting must be incorporated into the EHR for more than 15 percent of patients seen by the EP or discharged from a hospital or ED
- EPs and hospitals must use their EHR to 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
- 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
"If Meaningful Use was converted from a stimulus/penalty program to a pay-for-performance program without penalty, then these thresholds would be more appropriate," Halamka said.
He also called the certification rule released by the Office of the National Coordinator for Health IT too broad in scope, criticizing an attempt to cover all health information technology.
"It is no longer coupled/constrained by Meaningful Use goals," Halamka said. "That scope increase has the potential to create market confusion, vendor/developer burden, and a lack of focus that could impede our progress. Overregulation could also stifle innovation and the global competitiveness of the health IT industry."
Meanwhile, Jeff Smith (pictured left), vice president of public policy at the College of Healthcare Information Management Executives, told FierceEMR that a good number of providers likely will take issue with the CMS rule's mandate of Stage 3 participation beginning in 2018, regardless of historical participation.
"There are a percentage of providers who have not engaged with the program yet, or who have only started to engage with the program, who are probably looking at what's being required in three years with a fair amount of disbelief," Smith said.
While at the macro level, he said, it's good that CMS decided to require only eight objectives, "peeling the onion back" reveals that there's not as much difference between total required overall measures.
"It's more a framing issue if you take the government at its word that this is a more streamlined regulation," Smith said. "I think in many ways, it still is a more streamlined rule, but at the same time, if you're looking at just measures and objectives, then you kind of have to say 'you still have to be successful in 18 measures, which is not that different from Stage 1 or Stage 2.' I wonder what other approaches were considered, because the industry overwhelmingly said 'you need to be focused; you need to have a very limited number of measures and objectives.' The industry was hoping for a little bit less."
Like Halamka, Smith took issue with the patient engagement requirements in Stage 3.
"The jump from 5 percent to 25 percent is incredibly high," he said.
Smith said perhaps CMS was taking into account incorporation of application programming interfaces (APIs) as a method for transmitting information.
"That's information we're going to try to get from a policy perspective," he said. "What is the impetus and what is the mechanism through which CMS expects providers to be at such a high level of engagement with patients on something that's outside of their control? That will be a very heavy sticking point as the conversation moves along. The provider community is just kind of beside itself in the fact that there are things like more transmit that are outside of their control."
Linda Fishman, senior vice president of public policy analysis and development at the American Hospital Association, said the new rules seem to "pile additional requirements onto providers," in a statement released last Friday.
"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," Fishman said. "We urge CMS to release the 2015 flexibility rules immediately."
To learn more:
- here's Fishman's statement