The Centers for Medicare and Medicaid Services (CMS) recently issued a 301 page proposed rule for establishing Stage 3 EHR Meaningful Use (MU) requirements. If you are a practicing physician, including those in the specialties of radiology or orthopedics, the new rule applies to you.
The Office of the National Coordinator for Health IT (ONC) new rule proposal, encompassing 431 pages, has its main focus on proposing a new EHR definition as well as changes to the ONC Health IT Certification Program so that it will be more accessible and support more types of medical practice settings.
The Stage 3 proposal maintains the payment adjustments and hardship exceptions. Changes are proposed in the reporting requirements. Beginning in 2017, all providers will report on the same calendar-year basis. The new rule will incorporate Stage 1 and Stage 2 MU requirements so that, beginning in 2018, all providers will be reporting according to Stage 3 whether or not they participated in other stages.
The goals of Stage 3 MU are three-fold:
- Reducing costs.
- Improving access to medical care.
- Improving the quality of medical care.
The reporting rules will be simplified so that several providers who are caring for the same patient will have immediate access to shared information and will more easily be able to coordinate their care to that patient. Methods for enhancing patient access to their health information are also part of Stage 3 MU.
The proposed rule lists eight objectives for Stage 3 EHR meaningful use:
- Protect Patient Health Information
- Electronic Prescribing
- Clinical Decision Support
- Computerized Provider Order Entry
- Patient Electronic Access to Health Information
- Coordination of Care through Patient Engagement
- Health Information Exchange (HIE)
- Public Health and Clinical Data Registry Reporting
One criticism of the rule is that under each objective, there may be several measures that must be met. Although each objective may seem straightforward and relatively easy to comply with, when taken as a whole, compliance seems overwhelming to some healthcare providers. According to HealthcareITNews: “If a clinician has 12 minutes to see a patient, be empathetic, document the entire visit with sufficient granularity to justify an ICD-10 code, achieve 140 quality measures, never commit malpractice, and broadly communicate among the care team, it's not clear how the provider has time to perform a "clinical information reconciliation" that includes not only medications and allergies, but also problem lists 80 percent of the time.”
Solutions, such as reducing the number of patients seen per day, or increasing the number of scribes, will be costly. Providers are being asked to increase their efforts at the same time reimbursement levels are decreasing.
HealthcareITNews strongly encourages providers to make comments by May 29, 2015 as allowed by both CMS and ONC. There needs to be a meaningful discussion between providers who are affected by the EHR MU requirements and those who make the rules.
The ultimate goal of both CMS and ONC for Stage 3 EHR meaningful use is, according to the Health and Human Services Secretary, is to “bring electronic health information to inform care and decision making, and support population health.”
Healthcare Information Services, LLC (HIS) manages radiology and orthopedic practices' revenue cycle maximizing reimbursement, increasing compliance, and boosting profitability.