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On October 6, 2015, the Centers for Medicare & Medicaid Services and Office of the National Coordinator for Health Information Technology released Meaningful Use-Stage 2 modifications and Stage 3 final rules.
On October 6, 2015, the Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC) released Meaningful Use (MU)-Stage 2 modifications and Stage 3 final rules.
The final rules will simplify requirements and add new flexibilities for providers to make electronic health information available when and where it matters most and for healthcare providers and consumers to be able to readily, safely, and securely exchange that information, according to CMS.
Here are three things you should know about the new MU final rules.
#1.CMS believes the goals of its Medicare and Medicaid EHR Incentive Program are real and attainable-but the organization is willing to be flexible.
“Yes, in its current form the EHR incentive program will sunset in 2019 as Medicare begins to pay physicians on its new Merit-Based Incentive Payment System [MIPS], created under legislation that replaces the much-maligned sustainable growth rate formula,” says Anwesha Dutta, director, Healthcare Advisory, PwC. “How much the program changes, however, is still an open question-and one CMS is willing to work with the industry to determine. The new rule, released earlier this week, takes steps to gather more of the health industry’s insights into how much participation in the EHR incentive program should count towards performance scores under MIPS.”
That said, according to Dutta, the agency nevertheless is taking steps to show greater flexibility under the program’s current structure and timeline. The just-released rule gives providers an additional year, until January 1, 2018, to meet the new meaningful use requirements. At the same time it drops more than a dozen objectives that eligible professionals (EPs) and hospitals must meet.
“Among those objectives and standards that remain, some will have lower thresholds than before,” Dutta says. “For instance, the requirement that hospitals demonstrate patient engagement using an electronic record changed considerably. Now, a hospital only needs to show that one patient has viewed, downloaded or transferred his or her medical record to meet the requirement. That will increase to 5% under Stage 3, however.”
There’s another sign that CMS is being flexible, according to Dutta: The agency greatly shortened its reporting period.
“While the Stage 3 requirements are optional in 2017, those providers who choose to report will have a 90-day period to do so, not a full-year as originally described,” she says.
However, this may not be enough to satisfy critics of the program, according to Dutta. “The American Hospital Association points out that more than 60% of hospitals, and about 90% of doctors, have yet to attest to Stage 2,” she says.
#2. The ability to share data is now a priority.
“Health system executives will tell you that one of the biggest problems with investing in expensive EHR technology is that the systems are rarely truly interoperable to follow the patient’s story and major events across the care continuum,” Dutta says.
In other words, they are unable to exchange data in a meaningful way to improve care coordination, reduce duplication, errors, and inefficiencies beyond the four walls of a health system/ambulatory practices, she says.
“Stage 3 begins to tackle that challenge,” Dutta says. “More than 60% of the remaining measures providers can choose from require interoperability to further the goals of patient centered team-based care. Under Stage 2, that number was only 33%. The renewed focus on interoperability should sit favorably with health system chief executives. The ability to share data from multiple health IT platforms and devices is the foundation to success in an era where reimbursement is increasingly based on value and quality.”
Stanley M. Goldstein, president and CEO of Patient Engagement Systems, a healthcare services company, shares a similar viewpoint.
“One might make the case that achieving the lofty goals of meaningful use will be impossible without the ability of doctors, hospitals, patients, and other parties to effectively and securely communicate and share clinical information,” Goldstein says. “Ensuring that all parties have access to the right information at the right time to make the right decision should be fundamental to any electronic health record [EHR] technology. Without this, the goals of meaningful use cannot and will not be achieved.”
The government, providers and patients should get together and adopt a set of standards by which all EHR’s will be developed, according to Goldstein. “Patients should own and control their medical record and be able to choose who does and does not have access to it,” he says. “All certified EHRs should be able to communicate with each other and share appropriate clinical and patient generated information. This kind of approach will result in real meaningful use.”
#3.Prepare for payment reform.
“Get ready for more changes and the move to a value-based payment system in mid-2017 (a form of capitation payment with all kinds of measurements),” says Jimmy Burnett, managing director with Navigant Healthcare, a healthcare consulting firm. Practice leadership and health system executives will now need to ask: "Is my physician enterprise ready for payment changes? Can I do bundled payments? Am I tracking quality measures? Do I have my overhead at the lowest performing levels? Are my providers as efficient and productive as possible? Is my care team engaged-a well-functioning integrated delivery vehicle? It’s a wake-up call!”