Many in Medical Industry Urge Delay of Meaningful Use Stage 3

Ken Terry

June 03, 2015

Associations representing hospitals and physicians are expressing near unanimous opposition to the seemingly fast-approaching finalization of the government's proposed meaningful use stage 3 rules.

The final phase of the Centers for Medicare and Medicaid Services (CMS) electronic health records (EHR) incentive program is viewed by much of organized medicine as an unworkable example of government overreach that would saddle providers with burdensome requirements and impede their progress in using health information technology (IT) to improve quality and efficiency.

Among the few exceptions to this attitude was the Health Information Management and Systems Society (HIMSS), which represents health IT professionals and EHR vendors, among others. Although HIMSS had serious reservations about the CMS proposal, it did not call for a delay in the implementation of stage 3.

The Medical Group Management Association (MGMA) took perhaps the strongest stance against the proposal. The relatively small number of eligible professionals (EPs) who have successfully attested to meaningful use stage 2 — about 54,000, compared with the 305,000 who had previously attested — shows that "the government has overstepped its charge," Halee Fischer Wright, MD, president and chief executive officer (CEO) of MGMA, said in a 23-page statement. Stage 3 should not be finalized until more EPs have participated in stage 2, the association declared.

MGMA also called on CMS to delay stage 3 finalization until there has been time to evaluate the impact of the new legislation replacing the sustainable growth rate with a new Medicare payment method that includes meaningful use. Between now and 2019, when the law's merit-based incentive payment system (MIPS) is scheduled to go into effect, CMS should keep the latest stage 2 rules in place, MGMA suggests.

In addition, MGMA wants major changes in the proposed stage 3 criteria, including the elimination of objectives that depend on the actions of patients or other third parties. That would effectively gut the stage 3 objectives related to patient engagement and the exchange of care summaries at transitions of care. Like the other associations, MGMA wants CMS to continue 90-day reporting periods, rather than require all EPs and hospitals to collect data for a full calendar year, starting in 2017.

"Save" Physicians From the Heavy Lifting

The American Medical Association (AMA) also asked CMS not to finalize the stage 3 proposal yet, but for somewhat different reasons than MGMA. The AMA pointed out in their own 23-page statement that more information is needed on how the stage 3 criteria might affect patient safety; more time is needed to measure how the industry has responded to the first two stages of meaningful use; privacy and security issues must be better addressed; and the infrastructure to handle the next generation of quality reporting must be put in place.

The AMA agreed with MGMA that CMS should consider new meaningful use requirements as it implements MIPS. "This will save physicians from the heavy lift of a new program that is subsequently altered again in future rule making," James L. Madara, MD, executive vice president and CEO of he association, said in the statement.

In the event that CMS moves ahead with stage 3, the AMA made a number of suggestions for change, including these:

  • Require e-prescribing of 60%, not 80%, of permissible medications

  • Let EPs share the latest information with patients within 4 business days, instead of requiring a 24-hour turnaround, and reduce the percentage of patients who must have this access

  • Reduce the percentages of patients who must view, download, or transmit their records and exchange secure messages with EPs

  • Revise the information exchange criteria, because "CMS/ONC still hasn't resolved key interoperability barriers"

  • Eliminate the patient-generated data requirement, because not enough is known yet about how to handle this information

  • Don't move from attestation of quality data to electronic quality reporting by 2018, as proposed, because the infrastructure isn't ready yet

The American Hospital Association (AHA) and the College of Health Information Management Executives (CHIME) also slammed the stage 3 proposal. The AHA said CMS should refrain from finalizing the stage 3 criteria until it has had more experience with stage 2. Meanwhile, the AHA said, CMS should also focus on developing the standards and infrastructure needed for effective health information exchange.

CHIME termed the CMS proposal "unworkable" and said it doubted providers could successfully participate in stage 3 by 2018. The college called on CMS to wait until 2017 to finalize the proposal.

All About the Timing

HIMSS ― although offering some recommendations of its own ― was much more supportive of the proposal. Its strongest objection was that the start of stage 3 in 2017, when it will be optional for EPs, provides insufficient time for vendors to rewrite their applications to the required specifications. Timing will also be tight in 2018, the first year of mandatory compliance with stage 3, HIMSS noted. Therefore, it said, the reporting period should be 90 days rather than a full year in 2018.

Jeff Coughlin, senior director of federal and state affairs for HIMSS, told Medscape Medical News that making stage 3 optional in 2017 is "overall a good idea," because it allows time for providers to "work out the kinks in the transition to be fully up and running in 2018. The optional year is a good idea; we're just concerned about the timing."

HIMSS believes that stage 3 is needed and should not be postponed, Coughlin said. "What we tried to say is we want a less complex, less prescriptive stage 3. And we tried to offer some constructive ideas to make that happen. I don't think our approach is much different from what a lot of other stakeholders were saying."

One point that HIMSS emphasized in its comments — not surprisingly, because it includes EHR vendors — is that electronic clinical quality measures should be thoroughly field tested before being used by providers.

"The need to get this done is important, given the changes coming in the next few years related to the physician payment fix and the coordination that's going to be required between all the quality reporting programs," Coughlin pointed out.

CMS is very aware of this issue, "and I think they're heading in the right direction," he added.


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