CMS shares thought behind MU Stage 3 final rule

The November Health IT Policy Committee meeting included a discussion on the reasoning behind the Meaningful Use Stage 3 final rule.

Rob Anthony of the Centers for Medicare & Medicaid Services’ Quality Measurement and Value-Based Incentives Group, said the rule is aligned with a single set of overall goals for the program. The focus on reducing the burden for providers meant getting to a smaller set of objectives and focusing on high-priority policy drivers for health IT.

The goal with the modifications to Stages 1 and 2 was to get everybody aligned to a set of objectives. By 2018, everybody on Medicare will be on full calendar year reporting.  

Large practices, for example, have a more revolving door of people who come and go, “which can be particularly challenging when you have providers at multiple stages,” Anthony said.

The team behind the rule looked at high-priority areas of health IT usage and tried to focus on patient safety objectives, interoperability and patient engagement using health IT or the ability to engage with their electronic data.

The difference between the stages is higher thresholds for certain objectives, said Anthony, as well as added objectives that utilize the new certified EHR edition. “It isn’t a one-to-one match between Stages 2 and 3 objectives because some are combined," said Anthony. "We removed objectives that were redundant, duplicative of more advanced measures or used similar technical functions.”

Anthony said it is important to understand the numbers behind Stage 2 attestation. A little over 60,000 or slightly more than 49 percent of Medicare eligible professionals (EPs), have achieved Stage 2. That is 49 percent of those eligible, he noted. There was about a 50-50 split of those EPs eligible to participate in Stage 2 or stay at the Stage 1 requirements for 2014. “When we give people the flexibility to stay at the lower bar, they almost always take it.”

The rule focuses on eight advanced use objectives, many of which have two or three measures to provide for choice and flexibility. Providers can select those most relevant to their workflow.

The eight objectives are:

• Protect patient health information
• Electronic prescribing
• Clinical decision support
• CPOE
• Patient electronic access to health information
• Care coordination through patient engagement
• HIE
• Public health reporting

The first four fall into the broad category of patient safety and HIE is “the beating heart of interoperability,” said Anthony.

The new element with HIE is closing the loop. The emphasis in Stage 2 was sending summary of care records to the next provider electronically. “Here, the focus is on thinking of us as a whole healthcare system where we’re not only sending information but someone else is receiving the information and incorporating it into the patient’s record and doing reconciliation of some of that information.”

By matching up Stage 1 and 2 modifications with Stage 3, providers do not need to upgrade to the next edition of certified EHR. They have the flexibility to upgrade in portions. “We want to encourage people to customize their EHR in a way that works best for them.”

Clinical quality measures remain the same because “it was very important to us not to impose new requirements on providers.”

CMS is “aware there is an onboarding process” to the patient engagement objectives, Anthony said. “There’s no doubt that there are challenges for providers in getting patients to use [the tools].”

When asked about the rate of providers dropping out of the program altogether because the requirements aren’t worth the time and money, Anthony said more than half of the providers who faced a reimbursement penalty have Medicare claims of less than $2,000. “So that’s a $40 hit. They’re probably willing to take that then spend the money to implement an EHR. There’s a large number of providers making an ROI decision.”

The 60-day comment period on the final rule ends on Dec. 12. Anthony said that submitting comments electronically "is the easiest way for us to sort through and make sure we’re addressing them."