CMS Proposals for Stage 3 Meaningful Use

 In Articles, Meaningful Use, Policy Updates

CMS has published proposed rules for Stage 3. They are accepting comments until mid-May and will revise the rules based on this feedback. While it’s interesting to take a look at what CMS is proposing, it’s important to understand that there are likely to be changes in the final rules, which are expected in Fall 2015.

CMS proposes to make Stage 3 criteria optional for all providers in 2017 and required for all providers in 2018. CMS published a companion proposed rule for EHR vendors that specify what will be required to attain “2015-certification”. In order to attest to Stage 3 criteria, providers will have to have a 2015 certified system.

The proposed rule does away with Core vs. Menu measures, reduces the overall number of measures, and allows some flexibility to choose which measures you will attest to:

  • A security risk assessment must be completed during the reporting year but will be required to focus only on the data that is stored in the EHR system. A full security risk assessment covering all electronic data is still a requirement of HIPAA but would no longer be a MU requirement.
  • Over 80% of permissible prescriptions must be e-prescribed. Controlled substance prescriptions can be included if allowed by the state, but it is not required to include them. MU 2 was 55%.
  • 5 Clinical Decision Support Tools must be implemented for the full reporting period (same as MU Stage 2).
  • CPOE: Criteria regarding physician order entry for medications (80%), labs (60%) and radiology (60%) are continued from MU Stage 2 but with higher thresholds.
  • Over 80% of patients must have access to online healthcare information. MU 2 was 50%.
  • Over 35% of patients must have electronic access to patient education material – new in MU 3.
  • The provider must meet 2 of the following 3 measures:
    • Over 25% of patients view, download or transmit data from the portal. MU 2 was 5%.
    • Over 35% of patients are SENT a secure clinical message by the provider or practice. MU2 required that 5% of patients send a message to the provider, so this is the opposite.
    • 15% of patient records include data that was electronically provided by the patient or a healthcare provider who is not a physician (PT, MSW, etc.) – new in MU 3.
  • The provider must meet 2 of the following 3 measures:
    • Over 50% of referrals out have a Summary of Care document sent electronically. MU 2 was 10%.
    • Over 40% of referrals in or new patients have an electronic Summary of Care document incorporated into their medical record; counts if the record is requested and not received – new in MU 3.
    • Over 80% of referrals in or new patients have a reconciliation performed on problem list, medications and allergies. MU 2 required 50% on medications only.
  • The provider must attest to ongoing electronic submission or active engagement with 3 different registries (CMS will provide a central repository of registries by the beginning of 2017):
    • State Immunization registry – same as MU 2 Core measure.
    • State Syndromic Surveillance registry – same as MU 2 Menu measure.
    • State Registry of Reportable Disease Cases – new in MU 3.
    • State, National or Local Public Health Registry (includes Cancer Registry). If a provider reports to more than one public health registry, each will count up to a total of 3 – MU 2 had cancer registry and public health registry as Menu measures.
    • Clinical Data Repository operated by a non-public entity (usually a specialty association). If a provider reports to more than one CDR, each will count up to a total of 3 – new in MU 3.

Want more details? Read the proposed rule here.

Need help with adapting your workflows to meet the MU requirements? MSOC Health can help. Contact Jeanne Chamberlin at 919-442-2422 or j.chamberlin@msochealth.com to discuss a customized consulting engagement focused on your specific needs.

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