March 26, 2015
On Friday, CMS released the long awaited Meaningful Use / MIPS stage 3 draft rule. In this blog post, we summarize key elements of the 300-page long draft rule and highlight areas of major change. The document substantially reorganizes the Meaningful Use / MIPS standards into 8 program areas. These standards are focused on promoting more data interchange between providers, and in general to meet the goal of “interoperability” between different patient record systems. Overall, they represent substantially higher goals than in the past.
This post focuses on the stage 3 measures that providers will need to consider when making strategic decisions that may be impacted by the Meaningful Use / MIPS program’s future direction.
As succinctly as I could manage (considering the size of the document!), following are the proposed standards, and how they would change the Meaningful Use / MIPS future for providers if finalized as written. I have italicized major potential impacts.
THE PROPOSED STANDARDS
1. Protect electronic protected health information (ePHI) would remain essentially unchanged in its requirement that providers conduct or review a security risk analysis annually. The standard specifies that such an analysis would also have to be done upon installation of new systems and upon upgrades to new certified editions.
2. ePrescribing. This standard would require more than 25 percent of hospital discharge medication orders for permissible prescriptions (for new and changed prescriptions) to be queried for a drug formulary, and transmitted electronically using CEHRT. While this is the same functionality currently required in a menu item for stage 2, it significantly raises the volume threshold from 10% to 25%.
3. The requirement that providers implement clinical decision support (CDS) interventions remains essentially unchanged. It focuses on improving performance on high-priority health conditions, and using drug-drug interaction and drug-allergy checking on medication orders.
4. The stage 3 requirements for computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders would increase thresholds with the medication standard at 80%, and laboratory and diagnostic imaging at 60%. Also of note is that the previous definition of radiology has been expanded to comprise the complete array of diagnostic imaging modalities, including ultrasound, MRI, and CT.
5. The requirement for patient electronic access to health information would still be measured by the number of patients who have their information available online, but the threshold would be increased to 80% from the current 50%, and the time window shortened to within 24 hours of the patient visit.
Under this goal, a second measure is that the provider would have to use clinically relevant information from CEHRT to identify patient-specific educational resources, and provide electronic access to this material to more than 35 percent of unique patients. This is an increase from the current 10 per cent threshold. Further, the electronic access requirement to these documents is new.
In either case, the patient access can be provided directly via the CEHRT (certified EHR technology) through a patient portal module or via access to an application-program interface (API). APIs are used to provide patients access to their health information through third-party applications and devices. In many cases, the API option would provide providers and their patients with more flexibility than currently available in many patient portals.
6. To enable coordination of care through patient engagement, CMS has identiied 3 measures, but providers would only need to meet the threshold for two:
7. The program goal for Health Information Exchange (HIE) is related to the old electronic summary of care requirements, but also includes new requirements for the recipient of a summary of care. Specifically, the new rule would require incorporation and reconciliation of received data. The provider would have to meet two of the following three measures:
8. The final program goal, Public Health and Clinical Data Registry Reporting identifies six exchanges that qualify for this measure (5 for physicians) and would require that the provider be actively engaged (this includes being in the testing phase) with four (3 for physicians). The six options:
Watch for future posts in a series on the future of Meaningful Use / MIPS. We will discuss details regarding other proposed changes in the new rule, and lessons extracted from the certification standards for vendors.
Phoenix consultants know Meaningful Use / MIPS.