Mical DeBrow, PhD RN
Director of Health Analytics and Business Intelligence
On March 20, 2015, the Centers for Medicare & Medicaid Services (CMS) announced the release of the proposed Meaningful Use Stage 3 rules for the Medicare and Medicaid Electronic Health Records (EHRs) Incentive Programs and 2015 Edition Health IT Certification Criteria.
…this proposed rule does not impose the costs cited as compliance costs, but rather as investments which health IT developers voluntarily take on and expect to recover with an appropriate rate of return.
The proposed rule aligns with the path toward interoperability. It includes new and updated IT functionality and provisions that support the EHR Incentive Program’s care improvement, cost reduction, and patient safety across the health system.
According to HHS, the new rules aim to deliver the following benefits:
- Improve interoperability among electronic health records
- Simplify the Meaningful Use program
- Give providers more flexibility
The rule includes several new proposals:
- A single set of MU objectives and measures. All eligible providers and eligible hospitals would report on the same measures, beginning in 2018.
- Reporting periods will be aligned to the calendar year.
- MU reporting will be aligned with other quality reporting programs to reduce administrative complexity; measures that are no longer deemed useful to gauge clinical quality and provider performance will be phased out.
But not everyone is happy with the proposed rules. For many hospitals still struggling to understand and attest to Stage 2 MU, the release of the Stage 3 proposed rule feels daunting. And with the proposed rule’s scope generally limited to the requirements and criteria for meaningful use in 2017 and subsequent years—it also feels somewhat premature.
“The release of [the] rule demonstrates that the agency continues to create policies for the future without fixing the problems the program faces today,” said Linda Fishman, the American Hospital Association senior vice president of public policy analysis and development. “It is difficult to understand the rush to raise the bar yet again, when only 35% of hospitals and a small fraction of physicians have met the Stage 2 requirements.”
The Stage 3 proposed rule also poses significant potential costs. According to HHS, the total development and preparation costs for health IT developers may be greater than $100 million in at least one year. HHS is quick to note, however, that “this proposed rule does not impose the costs cited as compliance costs, but rather as investments which health IT developers voluntarily take on and expect to recover with an appropriate rate of return.”
Industry reaction to the recent announcement is still coming in as stakeholders continue to mull over the 300-page Stage 3 document. The comment period for the proposed rule is now open and ends on May 29, 2015.