Proposed Stage 3 Meaningful Use Rule Released

Ken Terry

March 20, 2015

The notice of proposed rulemaking for stage 3 meaningful use of electronic health records (EHRs) was announced today by the US Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS).

Concurrently, the Office of the National Coordinator for Health Information Technology (ONC) unveiled its proposed 2015 edition for EHR certification criteria, which are tied to ONC's previously announced nationwide interoperability roadmap.

The two proposed rules are scheduled to be published on Monday, March 30. The comment period on the proposed stage 3 meaningful use rule ends May 29, and comments will be received on the certification criteria proposal until June 30.

The stage 3 meaningful use proposed rule specifies new criteria that eligible professionals (EPs), eligible hospitals, and critical access hospitals will have to meet to qualify for Medicaid incentive payments. The rule also proposes criteria that providers must meet to avoid Medicare payment adjustments, based on program performance starting in 2018.

The 2015 edition EHR certification criteria "includes new and updated IT functionality and provisions that support the EHR incentive programs," states an HHS press release.

While the stage 3 proposed rule addresses meaningful use in 2017 and subsequent years, the news announcement said, "CMS is considering additional changes to meaningful use beginning in 2015 through separate rulemaking." This apparently refers to CMS' decision to change the 2015 reporting period from a full year to 90 days.

The proposed rule specifies that the meaningful use reporting period will be a full calendar year for both physicians and hospitals from 2017 onward. The only exceptions will be Medicaid EPs and hospitals that are attesting to meaningful use for the first time. These providers will have a 90-day period.

CMS will encourage electronic quality reporting from now on, and will require it for providers in the Medicare incentive program, starting in 2018.

In 2017, providers can remain in stage 1 or stage 2 or can attest in stage 3. But in 2018, all Medicare and Medicaid EPs and eligible hospitals will have to attest in stage 3, regardless of what stage they were in previously.

All providers can use 2014 edition certified EHRs through 2017, but they must adopt 2015 edition technology by 2018.

According to the proposed rule, stage 3 has a "simplified reporting structure," in which its objectives and measures will replace all stage 1 and stage 2 criteria.

But the stage 3 criteria will not necessarily be easy to meet. Despite the loud complaints of physicians about the difficulty of satisfying the stage 2 requirements for care summary exchange at transitions of care and patient record sharing, CMS is doubling down on those criteria in stage 3. It is also adding new objectives that some clinicians might find onerous.

Here are a few highlights of the stage 3 requirements:

  • More than 25% of patients seen by an EP or discharged from a hospital or emergency department (ED) must "actively engage" with their electronic records.

  • For more than 35% 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% 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% of transitions of care and referrals.

  • In more than 40% 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% of transitions of care, the provider has to perform a "clinical information reconciliation" that includes not only medications and allergies, but also problem lists.

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