Halamka on Stage 3: Time to move from regulation to merit

The Meaningful Use Stage 3 final rule includes welcome revisions to Stage 2 but presents several challenges to providers and vendors, according to Beth Israel Deaconess CIO John D. Halamka, MD, writing in his blog, Life as Healthcare CIO.

The rule establishes eight goals for eligible professionals (EPs) and hospitals (EHs) with optional participation in 2017 and required participation in 2018 to gain stimulus and avoid penalties. That leaves vendors just one year to make software changes and get certified which “could be very difficult, especially for the application program interface (API) requirements,” Halamka wrote.

One of the eight goals in the rule is patient electronic access which says 80 percent of patients must be given access to view/download/transmit and API capabilities. Thirty-five percent of patients must receive tailored educational resources electronically.   
This API requirement “may be among the most controversial aspects of the final rule,” Halamka wrote. He strongly supports the use of the APIs as a means to enhance interoperability but currently “there are few patient-facing applications that use APIs. Maybe in the future, the problem of multiple PHRs will be addressed by moving patients from portals to apps that consolidate data from multiple EHRs, i.e., the patient’s PCP, specialists, urgent care clinicians, and hospital care team.” 

Halamka questions whether regulation is the “best approach to accelerate the move to consumer-facing mobile apps and APIs for downloading EHR data and uploading patient-generated data. Regulation alone cannot change consumer behavior since APIs are not so much a technology but a market ecosystem to support the technology. One of the lessons of Direct is that such challenges are profound and cannot be created overnight based on federal regulation.”

He suggests a payment model such as risk-based pay for outcomes approaches which incentivize patients and providers to collaboratively share data using novel applications. He advocates removing the API requirement from Meaningful use Stage 3 and moving it to the merit-based incentive programs (MIPS), “enabling the marketplace to evolve innovative technologies after there is increased consumer and provider demand.”

Overall, Halamka said the collective burden of all the workflow changes the rule encompasses will make it hard to clinicians to spent time on direct patient care.

Also, he reiterated his opinion that it may be time to move beyond Meaningful Use. Merit-based payment might be the better option “because, at this point, it is more effective and efficient for [providers] to focus on achieving better outcomes for value-based care than being told exactly how they should get there.”

Read the entire blog post.