Since hospitals won’t need to implement the 2015 Edition technology required in the Final Rule for MU Stage 3 until 2017, it would be easy to put planning on the back burner for a while. Especially given that Stage 3 will be optional in 2017 — not mandatory until 2018. Strategically, however, this would be a mistake. In addition, there still remains much to do regarding the final Stage 2 rules.
As we discussed last week, the recently published Meaningful Use / MIPS Final Rule includes final rules both for Stage 3 and Stage 2. A high level comparison shows that one third of Stage 3 requirements are essentially unchanged from Stage 2, one third are the same as Stage 2, but at a higher threshold, and one third are new requirements.
For the one third of the Stage 3 requirements that is unchanged from Stage 2, no action is required. However, you can’t stop taking action. Confusing? Here are two examples:
Protect Electronic Health Information – Hospitals need to perform risk assessments and risk management activities regularly. Whatever risk assessment/management your hospital attested to in 2015 will be out of date in 2016.
Clinical Decision Support – The fact that five interventions are required is unchanged. But this doesn’t mean that more measures aren’t needed to support the organizational goals, or that all of the previous measures will remain relevant. Creation and maintenance of clinical rules is an ongoing process, not a one-time attestation event.
For the one third of Stage 3 requirements that is essentially the same as Stage 2, but with increased thresholds, there is no reason that the move toward the higher thresholds should wait. Hospitals who are already having trouble getting 5% usage of their patient portals should craft a strong strategy to move toward the 10% required in Stage 3. Similarly, hospitals who just met the 10% eRx requirements may need all of 2016 and 2017 to increase their provider participation in this measure.
Regarding the one third of Stage 3 that is new, it would be very tempting to simply wait for your vendor to release the 2015 edition code before looking at the items. But hospitals have an opportunity now to get a head start. Consider these two examples:
The secure electronic messaging function is not new. The capacity for eligible providers to exchange secure messages with their patients was established in the 2014 Edition standards. Most hospitals will find that they have access to this functionality either natively in their current software, or as a component of their patient portal. Many hospitals, however, opted not to turn this functionality on.
Hospitals who expect resistance to electronic messaging from their physicians may wish to begin a plan to activate this functionality now, in order to jump start physician acceptance, and to increase patient satisfaction.
Similarly, the capability to reconcile and incorporate external provider data regarding medications, problems, and medication allergies is an existing requirement of the 2014 edition, found at 45 CFR 170.314(b). Because there was no corresponding requirement for providers to utilize the functionality, it sits unused in many hospitals. Hospitals can begin exploring that functionality now, as part of their preparations.
Do a Stage 3 assessment now. Because of the large scope of Meaningful Use / MIPS Stage 3, we recommend to our client hospitals that they begin an assessment now of their current capabilities. The knowledge gleaned will be critical in guiding short and long term Meaningful Use / MIPS activities, and will ensure that the hospital is best positioned to make other decisions that will impact the future of Meaningful Use / MIPS.
The table below summarizes the Stage 3 rule as compared with the Stage 2 rule, and would serve as a good starting point for such an assessment. After reviewing the table, if you determine that additional guidance would be of benefit, we can help. We are awesome.
Table: Stage 3 Changes Relative to Stage 2 Meaningful Use / MIPS Requirements (Summary)
Protect Electronic Health Information
Measure 1: Risk analysis: NO CHANGE. Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1)and implement security updates as necessary. Correct identified security deficiencies as part of the risk management process.
Electronic Prescribing (eRx)
Measure 1: INCREASE: At least 25% of hospital discharge prescriptions must be sent electronically. Note that the Stage 3 definition specifies “new and changed prescriptions.”
Clinical Decision Support
Measure 1: Clinical Decision Support: NO CHANGE. Five clinical decision support interventions.
Measure 2: Drug-drug and drug-allergy interaction checks. NO CHANGE.
Computerized Provider Order Entry (CPOE)
Measure 1: NO CHANGE: Use computerized provider order entry for 60% of medication orders.
Measure 2: INCREASE: Use computerized provider order entry for 60% of laboratory orders (previously 30%).
Measure 3: INCREASE: Use computerized provider order entry for 60% of diagnostic imaging orders (previously 30%).
Patient Electronic Access to Health Information
Measure 1: Timely Access: INCREASE. At least 80% of patients have access to visit information within 24 hours. This is up from 50% by 36 hours.
Measure 2: Education: NEW. Provide electronic access to education materials to 35% of patients. The Stage 2 requirement did not require electronic access.
Note that the use of an API (Application Program Interface) has been added as an option to meet both of these measures.
Coordination of Care through Patient Engagement
Measure 1: INCREASE. More than 10 percent of all patients engage with the electronic health record. This is up from 1 patient in 2015/16 and 5% in 2017. An API may be used.
Measure 2: NEW. For more than 25 percent of patients discharged, a secure message is sent, using the electronic messaging function of CEHRT to the patient or in response to a secure message sent by the patient.
Measure 3: NEW. Patient generated health data or data from a nonclinical setting is incorporated into the CEHRT for more than 5 percent of patients.
Health Information Exchange Hospitals must attest to all three measures, but must meet only two of three.
Measure 1: INCREASE. Create and electronically exchange a summary of care record for more than 50 percent of transitions of care and referrals.
Measure 2: NEW. Incorporate an electronic summary of care document for more than 40% of new patients into the EHR.
Measure 3: NEW. For more than 80 percent of inbound transitions and new patient encounters, perform clinical information reconciliation. The provider must implement clinical information reconciliation for the following three clinical information sets:
— Medication: Review of the patient’s medication, including the name, dosage, frequency, and route of each medication.
— Medication allergy: Review of the patient’s known medication allergies.
— Current problem list: Review of the patient’s current and active diagnoses.
Public Health Reporting
Hospitals must implement 4 reporting interfaces. The two registry reporting options may be used more than one time.
Immunization Registry Reporting: NEW. The transaction requiring bidirectional is new.
Syndromic Surveillance Reporting: NO CHANGE
Electronic Case Reporting: NEW
Public Health Registry Reporting: NEW
Clinical Data Registry Reporting: NEW – replaces “Specialized Registry.”
Electronic Reportable Laboratory Result Reporting: NO CHANGE