This post is sponsored by Revenue XL
By now, most physicians know about Meaningful Use (MU)—the government program that provides incentive payments to eligible providers that meet specific criteria when implementing certified electronic health records (EHR). Providers currently meet either Stage 1 or Stage 2 criteria, depending on their implementation timeline.
However, on March 20, 2015, the Department of Health and Human Services (HHS) announced a notice of proposed rulemaking for Stage 3. At the same time, the Office of the National Coordinator for Health Information Technology (ONC) also released its proposed 2015 edition for EHR certification criteria. The comment period for the proposed MU Stage 3 rule ends May 29, and comments will be received on the certification criteria proposal until June 30.
This article addresses the proposed Stage 3 criteria and answers common questions about how this new stage could affect physician practices.
When will Stage 3 go into effect? Stage 3 pertains to MU in 2017 and subsequent years.
Is Stage 3 the final stage of MU? Yes, Stage 3 is expected to be the final stage. Stage 3 would incorporate portions of the prior stages into its requirements. Notable is the fact that beginning in 2018, all participants in the EHR Incentive Programs must attest to Stage 3 criteria regardless of their previous stage.
What’s the focus of the proposed Stage 3 requirements? Stage 3 includes the following priorities:
– Increase interoperable health data sharing among providers
– Promote advanced use of EHR technology to improve patient outcomes and health information exchange
– Improve program efficiency, effectiveness, and flexibility by making changes to the Medicare and Medicaid EHR Incentive Programs that simplify reporting requirements and reduce program complexity
How will the proposed Stage 3 hopefully reduce the reporting burden on providers? Stage 3 will align the EHR Incentive Programs with other CMS quality reporting programs that use certified EHR technology, such as the Hospital Inpatient Quality Reporting and Physician Quality Reporting System programs.
What is the timeframe for attestation in 2017 and beyond? According to the proposed rule, providers must report on MU measures for a full calendar year beginning in 2017. The only exceptions will be Medicaid eligible professional (EP) and hospitals that are attesting to MU for the first time. These providers will have a 90-day period.
Will providers still be able to claim a hardship exemption? Yes; however, the exception is subject to annual renewal. In no case may an EP be granted an exception for more than five years. The proposed rule includes the following reasons why a hardship exemption may be granted:
– The lack of availability of internet access or barriers to obtain IT infrastructure.
– A time-limited exception for newly practicing EPs or new hospitals that would not otherwise be able to avoid payment adjustments.
– Unforeseen circumstances such as natural disasters that would be handled on a case-by-case basis.
– (EP only) exceptions due to a combination of clinical features limiting a provider’s interaction with patients or, if the EP practices at multiple locations, lack of control over the availability of CEHRT at practice locations constituting 50% or more of their encounters
What does the proposed rule require regarding patient engagement? The proposed rule would require EPs to comply with two of these three requirements:
– Provide more than 25% of patients with access to their own records
– Collect patient-generated health data for more than 15% of patients
– Offer secure messaging between patients and providers for more than 35% of patients
What does the proposed rule require regarding lab and imaging orders? The proposed rule would require EPs to submit 60% of lab and imaging orders electronically. Notable is the fact that 80% of prescriptions would be required to be sent electronically.
What does the proposed rule require regarding information exchange with other providers? The proposed rule would require EPs to create a summary of care and electronically exchange it with other providers for more than 50% of transitions of care and referrals.
Work with your EHR vendor to ensure compliance
Now that the proposed rule for Stage 3 has been announced, practices should contact their EHR vendor to better understand how the vendor is preparing for these changes, some of which require significant increased compliance as compared with Stage 2. What changes will your vendor make to ensure compliance? How might these changes affect the workflow within your practice? Work collaboratively to ensure success with Stage 3.
RevenueXL’s PrognoCIS EMR v3.0 is compliant with the ONC 2014 Edition criteria and is committed to meeting the stage 3 criteria when they become applicable in 2017. Request your FREE demo today and learn more about PrognoCIS Meaningful Use EHR Software.
