CHIME members respond to Stage 3 requirements

With the proposed rule for Meaningful Use Stage 3, the Centers for Medicare & Medicaid Services (CMS) aims to provide a flexible, clear framework to simplify the program and reduce provider burden, said Elizabeth Holland, director of CMS’ Health IT Initiatives Group, speaking during a webinar presented by the College of Healthcare Information Management Executives (CHIME).

Reduced burden comes by removing redundant, duplicative objectives, she said. The rule streamlines provider requirements and makes MU a payment adjustment program instead of an incentive program.

The rule identifies eight advanced use objectives and makes them the same for both eligible providers and eligible hospitals. Simplified requirements will increase interoperability, she said. The requirement of providers to report on two of three health information exchange objectives will “increase the scale of participation and support growth in HIE and the patient engagement infrastructure.”

The big change, she acknowledged, was the move to full calendar year reporting beginning in 2017. That would have all providers attesting at the same time and is important because “that alignment will enable us to coordinate with quality reporting periods. Providers would only report once and have that count for multiple programs.” If the rule is finalized this year, then all providers would start reporting on the calendar year starting with 2016.

Holland said CMS is “really trying to keep our ear to the ground and be responsive to stakeholder concerns.”

After Holland’s presentation, three CHIME members shared their thoughts on the proposed rule.

“The measures that involve actions by someone else are the ones that are going to be difficult,” said Pam McNutt, Methodist Health System senior vice president and CIO. “I would like to see these requirements for other people to do things to go away and just have us held accountable for offering certain services or transactions to patients and other providers.”   

Albert Oriol, MBA, CIO of Rady Children’s Hospital-San Diego, said the full year of reporting will be challenging. “The concept of 365 days of data makes it very hard, particularly when you take into account the operational work all of us need to take in day in and day out with upgrades and system replacements. To not have a window to be able to do that makes it very hard on us.” He mentioned the possibility of a 90-day window during which providers don’t have to provide data. “At the very least, gives us an opportunity to manage our systems without having to worry about the impact on Meaningful Use attestation.”

While patient engagement and information sharing can be very value-added at times, “trying to get people to do things so we can reach a number feels very artificial to providers,” said Howard Landa, MD, CMIO of Alameda County Medical Center. “Patient engagement, in particular, is the single biggest benefit we can get from this but I’m concerned about exactly how it will be implemented and how it’s going to be measured.”

Landa said he sees healthcare getting to greater efficiencies in the long run. “Right now it’s painful but it has the potential to have real value.”

A big problem, he said, is change management. “If you don’t have people actively involved in doing the work this way, it’s going to be very difficult.”

Another challenge, according to McNutt, is whether organizations have really implemented all the components of the EMR to properly and accurately populate the fields of a patient portal. “We struggle with that. I think we will continue to struggle with that. Having the software and having the software accurately do what it’s supposed to do are really two different things.”

“Taking a population of patients from no involvement to the level of engagement Stage 3 requires--I don’t think that’s possible in one year. It’s going to be an incredible challenge.”

“The goal and what we’re trying to accomplish is the right thing to do,” said Oriol. “The question is the threshold. You can take the horse to the water but you can’t make them drink. It’s very hard for to engage certain populations in an electronic way. The question is how much can we control and how can we get there.”

Landa also said a secondary problem is how information will be delivered, how will it be reviewed or validated and how will it be integrated into other systems in a way that’s valid, accurate and consistent. He noted that patients often tell their doctor different stories so what will a provider do about any discrepancies? “There are a lot of pieces no one has looked at from what I can see.”

Population health is going to drive the smart adoption of technology rather than the forced adoption, said McNutt.

A unique identifier is “the single most important thing we can be doing to make sure that providers can connect with one another,” said Oriol. That would “raise the ability to take better care of our patients and to make sure that we know who are patients are to begin with.”

When providers start to see the value proposition, said Landa, “that’s when you’re going to get a lot less resistance from providers.  We need some flexibility in what we do so we can do appropriate things for the appropriate populations of providers and patients.”