Have you had a chance to read through the proposed rule for the Stage 3 rules of the government's EHR incentive program? If not, we've got you covered.
Here are six things to know about the proposed rule:
1. The rule proposes a significant change to the structure of the meaningful use program by establishing a single stage for meaningful use (Stage 3) starting in 2018. This means that in 2018 and following years, all providers (regardless of prior participation in the program) would need to meet the Stage 3 rules. In 2017, providers could participate in Stage 1, Stage 2, or Stage 3, but in 2018, all would need to attest to Stage 3. The proposed rule notes that the program requirements may change slightly in future years, but Stage 3 would remain the final stage moving forward.
For more on what this single stage for meaningful use would mean for physicians, click here.
2. The proposed rule indicates that Stage 3 would continue to "build on the groundwork" established in Stage 1 and Stage 2. Many of the measures included in the proposed rule focus on increasing interoperability, information exchange, and patient engagement. Though many of the measures associated with these initiatives are similar to the measures in Stage 2 (but with higher thresholds), there are also some new measures associated with them.
For more on these new measures, click here.
3. The proposed rule establishes a full-year reporting period. The proposed rule specifies that the meaningful use reporting period would be a full year for both physicians and hospitals starting in 2017 and in future years. The only exceptions would be Medicaid eligible providers and hospitals attesting to meaningful use for the first time (they would have a 90-day period).
4. The proposed rule requires electronic quality reporting. Starting in 2018, CMS would require electronic quality reporting for providers who would need to implement five clinical decision support interventions related to four or more quality measures.
5. The proposed rule includes fewer objectives in Stage 3, but many of the measures associated with these objectives may be more challenging. Providers would only need to meet eight objectives in Stage 3 (though some of these objectives have multiple measures associated with them). The proposed rule also includes new requirements that may be difficult for providers.
For more on the challenging objectives and measures, click here.
6. The proposed rule includes some flexibility when it comes to the requirements. The proposed Stage 3 objectives include some flexibility, which could make it easier for providers to successfully attest. For instance, for the "coordination of care through patient engagement" objective, providers would only need to meet thresholds of two of three measures and attest to the numerators and denominators of all three measures. And, for the "health information exchange" objective, providers would need to meet the thresholds of two of three measures and attest to the numerators and denominators of all three measures.