Criteria for Stage 3 of Meaningful Use was announced and published at the end of March, detailing benchmarks that eligible providers and hospitals will have to meet to qualify for certain incentive payments and avoid reimbursement penalties. The proposed ruling by the US Department of Health & Human Services and the Centers for Medicare & Medicaid Services (CMS) outlines a framework that is in some ways more flexible and in others more rigid than Stage 1 and Stage 2.
“These changes…support our broader efforts to increase simplicity and flexibility in the program while driving interoperability and a focus on patient outcomes in the meaningful use program,” according to a summary of the proposed rule.
As part of Stage 3, providers will need to attest to 2 of 3 measures associated with each of the main categories of Meaningful Use: coordination of care through patient engagement, health information exchange, and public health reporting. Providers may continue to use 2014 edition electronic health record (EHR) technology through 2017. There are still exceptions for providers in rural areas or who practice at more than 1 location, as well as for lack of availability of internet access, newly practicing providers and hospitals, and unforeseen circumstances such as natural disasters.
In addition, the thresholds of most measures have been increased, such as having to use computerized provider order entry (CPOE) systems for >80% of all prescriptions (up from 50% in Stage 2), >60% of all laboratory test orders, and >60% of diagnostic imaging orders. Furthermore, Stage 3 also requires that >80% of all patients seen by a provider or discharged from a hospital or emergency department have access to their health information within 24 hours of its availability to the provider.
Compliance with Stage 3 requirements will be optional for providers in 2017, but mandatory for all eligible providers starting in 2018 regardless of previous participation in Stage 1 or Stage 2. CMS also intends Stage 3 to be the last stage of Meaningful Use.
“The incorporation of the requirements into one stage for all providers is intended to respond to stakeholder input regarding the complexity of the program, the success of certain measures which are part of the meaningful use program to date, and the need to set a long-term, sustainable foundation based on a consolidated set of key advanced use objectives for the Medicare and Medicaid EHR Incentive Programs,” according to the executive summary.
Other key conditions in Stage 3, in addition to the raised thresholds described previously, include the following:
- Reporting for a full calendar year starting in 2017 for nearly all providers instead of 90 days
- Successfully meeting the criteria associated with each of 8 specified program objectives (protect patient health information, electronic prescribing, clinical decision support, CPOE, patient electronic access to their health information, coordination of care through patient engagement, health information exchange, and public health and clinical data registry reporting); in measures with 3 subsets, achieving at least 2 of the 3
- Using secure messages via the electronic messaging function of EHRs to communicate with more than 35% of patients
- For more than 40% of new patients and for more than 50% of existing patients being transitioned to other care facilities or providers, creating a summary of the care record in the EHR and sending it electronically to the new providers/facilities.
The executive summary states that the “stage 3 proposed rule would…focus on the advanced use of EHR technology to promote improved patient outcomes and health information exchange.…[It also] would further support efforts to align the EHR Incentive Programs with other CMS quality reporting programs that use certified EHR technology, such as the Hospital Inpatient Quality Reporting (IQR) and Physician Quality Reporting System (PQRS) programs, as well as continue alignment across care settings for providers demonstrating meaningful use.”
CMS has given providers and other stakeholders 2 months to submit comments regarding this rule from the date the rule was published. Comments and feedback are due by May 29 and can be submitted by visiting www.regulations.gov and referring to file code CMS-3310-P.