By Cindy Barrett, LPN, Senior Consultant, and Leslie Madden, Consultant, The Camden Group
If achieving Meaningful Use is on your radar, the proposed rule for Stage 3 has been released and is open for public comment. For those who are already in the middle of their Meaningful Use (“MU”) journey, Stage 3 will hold its own share of challenges, as we’ve seen in the transition from Stage 1 to Stage 2. But if you’re looking at working toward attesting for the first time, consider the opportunity to do so sooner rather than later. Stage 3 builds upon the framework established in Stage1 and Stage 2, with further expansion proposed for Stage 3.
The Stage 3 objectives will eliminate some of the more easily attainable measures from Stage 1 and Stage 2, or increase the threshold requirements to meet those measures. Additionally, Stage 3 contains two major proposed reporting changes of note. First, in 2018, all providers must attest to Stage 3 Meaningful Use objectives, regardless of where they are on their MU journey. Secondly, everyone will attest for a 365-day reporting period in 2018, thus eliminating the 90-day reporting periods with which we are familiar for first time adopters. Expanded measure requirements for things such as patient engagement and data reporting will pose challenges for many providers and hospitals to meet all the objectives in Stage 3, and that includes many who have already completed successful attestations to MU Stages 1 and 2. And, if you are just starting on your MU journey, Stage 3 patient engagement, CPOE, and e-prescription requirements will be a drastic shift in process for you and/or your patient population.
The spirit of the proposed rule reportedly demonstrates an intended response to take into consideration the input received during Stages 1 and 2, while maintaining long term goals of the overall EHR incentive program like interoperability and enhanced use of EHR applications. The proposed Stage 3 rule is composed of 8 objectives- fewer in number than previous stages, but increasingly more difficult to achieve. Don’t let the lower number of objectives fool you. It’s a combination of higher thresholds for existing measures, enhanced system requirements, and increasing burdens for providers and hospitals to meet measures for patient engagement, care coordination and health information exchange. Once again, there will be challenges for vendors to meet timelines to comply with these requirements, and increasing costs to providers and hospitals in technology and resources to meet and sustain these objectives in your practice setting.
While Stage 3 is expected to be the final stage of the Federal EHR Incentive Program, MU is not going away. Currently in an incentive phase, there are penalties phases in the coming years, and the expected standard is that everyone will meet and maintain these objectives to help achieve improved clinical outcomes and efficiencies, as well as cost reductions across the care continuum for years to come.
MU is truly a journey, with winding paths, bumpy roads and a course that promises hurdles and obstacles along the way. Whether the trip will result in the anticipated destination…..we’ll have to wait and see. What we do know is that the expectations for participation are not going away, and those who choose not to take the journey will find the price to pay only getting steeper with each passing year.
Ms. Barrett is a senior consultant with The Camden Group, with over 30 years of clinical experience in the healthcare field. She specializes in collaborating with electronic medical record (“EMR”) implementation support teams to facilitate and build processes, workflows, post-implementation support, and optimization as it applies to EMR solutions. Ms. Barrett is recognized for her expertise in EMR clinical workflow analyses, technical EMR system builds, training oversight, and practice support during pre-implementation, implementation, go-live, and post go-live. Ms. Barrett has helped organizations achieve Meaningful Use and implement processes and care team models to support Patient-Centered Medical Home development. She may be reached at email@example.com or 512-795-5500.
Ms. Madden is a consultant with The Camden Group, with over 15 years of experience working with medical groups and physician practices. With strong knowledge of practice operations, Ms. Madden helps practices improve their billing/collections processes, assists with managed care contracting, establishes front office procedures, improves financial performance, and implements overall practice management approaches. She may be reached at firstname.lastname@example.org or 512-795-5500.