Get ready for interoperability, simplified meaningful use measures, and program alignment. These are the highlights of the proposed rule for Stage 3 of the incentive programs — with an estimated $1.6 billion in incentive payments for hospitals — for Medicare and Medicaid Electronic Health Records (EHRs) released by the Department of Health and Human Services (DHS), Centers for Medicare & Medicaid Services (CMS), and Office of the National Coordinator for Health Information Technology (ONC) in late March.
The proposals include criteria that will become final, if implemented as written, in 2018. However, the comment period is open through the end of May, and some changes may occur.
“For hospitals, the proposed rule focuses on three main issues,” says Kate Goodrich, MD, MHS, the director of the Quality Measurement and Health Assessment Group at CMS in Baltimore. Some organizations may be ready by 2017, but others may need another year to begin that reporting.”
In no case will organizations be given leeway to wait to report beyond 2018, however.
Second, meaningful use measures have been simplified and now focus on eight core goals that everyone has to achieve. Three of them have multiple measures within them, and organizations can choose among the measures within those core objectives, she says. Those objectives — health information exchange, patient engagement, and public health reporting — are viewed as the most difficult objectives to meet. “They focus on advanced use of EHRs,” Goodrich explains.
Other elements that change in meaningful use measures include removing some requirements that have “topped out” — measures with widespread adoption; organizations routinely score 100% on these — or they are paper based. These remain part of the base EHR, she says, and include data points like height and weight, or blood pressure readings. “They just no longer have to report these to us.”
Lastly, it features changes related to interoperable data sharing between organizations and advanced use of EHRs to improve outcomes, efficiency, and effectiveness, she says.
“We are not proposing any quality measures, but we are looking at electronic measures in the payment rules, the inpatient prospective payment system,” she says. “That will give us more flexibility to update measures each year and build them into the base quality programs.”
The proposal is 300 pages, but Goodrich says she hopes it is widely read by stakeholders like those in quality improvement and patient safety, and she hopes they comment. “We look at public feedback and read every comment. There will undoubtedly be changes based on what comes back to us.”
In addition, Goodrich would like hospitals to look through the rule and assess readiness for the changes to come. Even if there are tweaks, it is unlikely they will be wholesale to the document as it stands, she says. It was put together with people from throughout the healthcare world who have a vested interest in what’s in it, and she says it may be finalized much like it looks now.
Even if you are doing well on the advanced measures, take a look at the proposals, start working with your EHR vendors, and even consider submitting your electronic measures data to CMS now, Goodrich suggests. “It is voluntary, but if you do it now, you can benefit from one-to-one assistance that we are providing through the end of November.”
Those interested in that program can contact the CMS Quality Net help desk (http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/HelpDeskSupport.html) for assistance, she says. “We want you to get used to submitting this data, and we are standing by to assist you.”
The focus of the proposed Stage 3 rules for hospitals is the advanced objectives, and Goodrich stresses that most facilities will have some work to do to ensure success come 2017. “It is not that far away,” she says.
Getting it right is not just important for the potential $1.6 billion in incentives available that first year, either. Goodrich emphasizes that the rule all leads back to quality and safety: engaging patients, sharing information, improving communication. And it does that while striving to reduce the burden on providers and the administrative staff that supports them. “We want you to focus on the measures that really matter to patient safety and quality,” she notes. “We do not want you to be distracted by things you are already achieving but have to report, or multiple reporting periods. We want you to focus on the measures that matter to patient safety and quality of care. And also on engaging patients, because we know that when they are more engaged in their care, it can significantly improve outcomes.”
The complete proposed rule can be found at https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-06685.pdf.
For more information on this topic, contact Kate Goodrich, MD, MHS, Director, Quality Measurement and Health Assessment Group, Centers for Medicare & Medicaid Services, Baltimore, MD. Email: Kate.email@example.com.