Proposed MU Stage 3 Rule Summary Released
On March 20th, 2015, the Centers for Medicare & Medicaid Services (CMS) released the EHR Incentive Program-Stage 3, and the Office of the National Coordinator (ONC) released the 2015 Edition Health Information Technology Certification Criteria. Stage 3 of the Meaningful Use (MU) program is expected to be the final stage and to incorporate portions of the prior stages into its requirements. While 2017 will be a transition year, 2018 and onward is expected to be Stage 3 only.
The proposed Stage 3 goals focus on:
- Patient Outcomes
Modifications to MU: 2015 Through 2017
The proposed rule intends to change the EHR reporting period in 2015 to a 90-day period that aligns with the calendar year, and to align the EHR reporting period in 2016 with the calendar year. There are changes to the Stage 2 patient action measures related to patient engagement. Also, reporting requirements are removed for measures considered redundant, duplicative, or topped out through advancements in EHR function and provider performance (i.e., recording demographics).
In Stage 3, CMS eliminates prior Stage 1 and 2 measures that no longer distinguish meaningful users from non-meaningful users. Instead, CMS focuses on measures that will move MU forward. Stage 3 contains only eight objectives, each with multiple measures. Beginning in 2018, all MU participants will attest to the same set of Stage 3 objectives in an attempt to make life easier for providers, vendors, and regulatory agencies. The figure below outlines Stage 3’s objectives:
- Protect Patient Health Information (PHI)
This objective expands on the MU Stage 2 criteria that require annual risk assessments. Stage 3 adds to the security requirements for technical, administrative, and physical safeguards of patient information.
- Electronic Prescribing
For eligible providers (EPs), 80% of all permissible prescriptions must be queried for a drug formulary and transmitted via EHR. For eligible hospitals (EHs) and critical access hospitals (CAHs), 25% of hospital discharge medication orders for permissible prescriptions must be queried for a drug formulary and transmitted via EHR.
- Clinical Decision Support
This objective contains two sub-measures: To implement five clinical decision support (CDS) interventions related to four or more clinical quality measurements (CQMs) at relevant points in patient care and to implement technology for drug/drug-allergy interactions. At least one of the CDS interventions should relate to improving healthcare efficiency. One of the measures involves diagnostic order appropriateness, which includes labs.
- Computerized Provider Order Entry (CPOE)
There are three sub-measures: Use CPOE for at least 80% of medication orders, 60% of lab orders, and 60% of diagnostic imaging orders. CPOE expands to include orders by any licensed healthcare professional or credentialed medical assistant.
- Patient Access
This objective intends to expand physician communication with patients through technology. Stage 3 requires the EP, EH, or CAH to provide health information access for patients to view online, download, or transmit, or to retrieve through an application program interface (API) within 24 hours of its availability.
- Patient Engagement
This objective has three sub-measures: 1) more than 25% of patients must actively engage with the EHR, 2) a secure message must be sent to 35% of patients through the EHR, and 3) more than 15% of patient-generated data or data from a non-clinical setting must be incorporated. EPs, EHs, and CAHs can meet the first objective by reporting that 25% of their patients viewed, downloaded, or transmitted their information to a third party through an ONC-certified API. CMS is seeking comments on this objective.
- Health Information Exchange
EPs, EHs, and CAHs must provide a summary of care (SoC) record when transitioning or referring a patient to another care setting. They must obtain an SoC document upon the first encounter with a patient, and incorporate SoC information from other providers into their EHR.
- Public Health & Clinical Data Reporting
EPs, EHs, and CAHs must be actively engaged in contributing to three of the six measures:
- Immunization Registry reporting
- Syndromic Surveillance reporting
- Case reporting
- Public health registry reporting
- Clinical data registry reporting
- Electronic reportable lab results
CMS plans to create a central public health repository for all national, state, and local public health agencies along with each entity’s ability to receive that data electronically.
- Objective 1 – Protect PHI: As part of your annual risk assessment, make sure you have a Business Associate Agreement (BAA) with Orchard Software.
- Objective 3 – CDS: Be involved in a test utilization management program that monitors the appropriateness of lab orders to support CDS objectives.
- Objective 4 – CPOE: Be involved in the oversight and setup of CPOE.
- Objective 8 – Public health and data registry reporting: Make sure LOINC codes are up to date to standardize result transmissions.
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Kim Futrell, MT (ASCP)
Products Marketing Manager
Orchard Software Corporation