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Final Rule for Stage 3 Meaningful Use Comes Closer to Publication

- The final rule for Stage 3 Meaningful Use is now under review by the Office of Management and Budget (OMB), bringing the hotly anticipated guidelines one step closer to publication and the opportunity for industrywide scrutiny. 

Stage 3 meaningful use

Intense calls for a delay to the last formal stage of the EHR Incentive Programs have been echoing across Congress and private industry as stakeholders debate the feasibility of certain provisions included in the proposed ruling.  With only 20 percent of providers managing to attest to Stage 2, healthcare organizations are wary of Stage 3’s increased interoperability, population health management, patient engagement and e-prescribing, and data exchange expectations, which may not be attainable with current EHR and health IT technology.

The final rule may or may not contain modifications to the proposed document, which aims to level the playing field for all providers participating in the EHR Incentive Programs.  Stage 3 eliminates the staggered structure of previous years, requiring all providers to meet the same set of standards by 2018, regardless of how long they have been enrolled in the program. 

By 2018, providers will also be required to upgrade their EHR infrastructure yet again to meet 2015 CEHRT standards, which encourage a more module take on health IT development while upping the ante for health data interoperability.

Critics of the Stage 3 rule note that demanding more from provider EHR use without drastically improving EHR usability may cause provider satisfaction rates to plummet even further than they have during Stage 2, leaving clinicians with the same sense of dread and dismay that has kept attestation numbers disappointingly low.

READ MORE: Stage 3 MU Steadily Loses Favor as EHR Usability Concerns Rise

“We’ve been hearing from our members that EHRs have become cumbersome, that there are so many screens and boxes to check that it’s almost mind-numbing as they try to go through all of the requirements of these programs while trying to treat the patient,” Robert Tennant, Senior Policy Advisor at the Medical Group Management Association (MGMA) said to HealthITAnalytics.com when the Stage 3 proposed rule was released.  “It’s becoming a situation where they’re required to meet these government mandates, but the interaction between the physician and the patient is being lost.”

Other major stakeholder groups have agreed that EHRs remain at the root of the industry’s inability to meet the high bar of interoperability and health information exchange set by CMS and the ONC.  CHIME and the AHA have both called on CMS to slow down the breakneck pace of the meaningful use program to give interoperability standards and API technologies the chance to sufficiently mature.

"Hospitals and health systems report that EHRs purchased during the past five years do not easily share information, and we lack efficient and affordable networks to connect providers," said AHA Executive Vice President Rick Pollack in a letter to CMS. "The cost of the many interfaces needed to connect systems and new transaction fees for information exchange do not represent a sustainable model for widespread sharing of health information."

"CHIME believes this objective fails to recognize the limited capabilities of many PHAs and CDRs," added CHIME President and CEO Russell P. Branzell and Board Chair Charles E. Christian in a separate missive. "Even in the arena of immunization reporting, bidirectional communication is far from an established capability. At this time, we are uncertain about the industry’s ability to support full bidirectionality."

Whether CMS will consider these comments in the final rule for Stage 3 meaningful use remains uncertain – historically, federal rule makers have tried to push the industry to its limits with initial guidance and then provided exemptions and modifications later on.  The Stage 3 rule, final or not, may also be subject to significant revision when the Obama Administration hands over the White House to its eventual successor, bringing unforeseeable changes to the EHR Incentive Programs and any number of other health IT initiatives.

READ MORE: Carequality Releases New Health IT Interoperability Framework

“I can’t emphasize enough that all bets are off when a new administration comes in,” Tennant reminded stakeholders.  “All of these programs that we’ve sort of taken for granted, from PQRS to patient-centered medical homes to ACOs…all of those were, for the most part, the brainchildren of the Obama Administration.” 

“Regardless of what president comes in during the next election, they’re going to make changes according to his or her vision.  Things will be different, and the healthcare industry will have to adjust, because that’s the nature of politics.”

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