Reaction to Stage 3? Guarded
The reaction to the long-anticipated Stage 3 meaningful use rules has been slow in coming – not surprising, given that the Centers for Medicare & Medicaid Services released them around 3:30 p.m. Eastern Time on Friday, March 20.
CHIME, the College of Health Information Management Executives, was the first to comment. Other organizations, such as the American Medical Association and the American Hospital Association, both vocal in asking the government for flexibility in the program, have not yet weighed in with statements.
"CHIME is closely evaluating both the CMS meaningful use rule and the ONC certification rule," the organization said in a Friday statement issued soon after the rules were released. "Based on our initial review, we are pleased to see flexibility built into the Stage 3 proposed objectives.
"While we and other stakeholders have been critical of the program over the last two years, we have always underscored how vital meaningful use is to modernizing our nation's healthcare system," CHIME added.
Many healthcare organizations, CIOs and policymakers were still wading through the more than 300 pages of rules this morning.
George T. Hickman, senior vice president and CIO at Albany Medical Center in Albany, N.Y., had a chance to give the rule a first pass.
As he sees it, "it hits all the right buttons."
"I agree that we need continuous improvement to quality and adoption measures, increased privacy and security management, standards-based data exchange and other related MU features," he said.
That does not mean Stage 3 does not raise concerns for him.
"We are apparently attempting to transform our industry through federal and state regulation – which aren't always in alignment or don't consider impacts relative one to the other as this creates, in the end, a transformational change management portfolio that includes Meaningful Use, DSRIP, ICD-10, cybersecurity, interoperability expectations and many other things," he noted.
There are competing technology goals within individual organizations, he pointed out, Those goals support the mission and include other "very significant factors," such as financial reform, mergers and acquisitions and population health management.
[See also: HHS calls Stage 3 rule 'flexible, clearer framework'.]
"The collective of the mandates, mission supporting interests, and environmental factors bear heavily on our people and other resources," Hickman said. "This same resource challenge is borne by our key EHR vendors as they must address fundamental workflow and other capability elements of their products while also reacting to government mandates.
"We encourage CMS to propose policy changes to the 'all-or-nothing' construct: Lengthen timing between required Stage upgrades and consider much-needed revisions to the hardship exception categories," he added. "These changes will enable far better participation among providers, which will in turn, keep them on a path towards improved care through health IT.
"It is my humble prayer that our federal and state HIT change advocates and policymakers invoke some 'systems thinking' so that we don't cause our U.S. healthcare system to fall out of balance and fail to fulfill its mission to our people."
In its statement CHIME said: "We understand the red tape is as thick for those inside government as it is for those outside. However, we urge CMS to quickly publish the proposed rule … "We were encouraged by the signals to shorten the 2015 EHR reporting period from 365 to 90 days and make other program improvements through a follow-on rule.
Pam McNutt, senior vice president and CIO at Methodist Health System in Dallas, is concerned about Stage 3, just as she was about Stage 2 – especially about the measures that require actions "on someone else's part."
Specifically, McNutt says she's worried about the requirement for 25 percent of patients to view, download or transmit their health information, and also the requirement for incorporating patient generated data for 15 percent.
"I am also concerned about the feasibility of having complete data sets available within 24 hours of discharge in a hospital setting as required," she said.
"Finally, I question the transitions of care requirements that one must incorporate the summary record into one's EHR and perform a clinical reconciliation of the data," she said. "The mechanics of this will require manual intervention and alter workflow substantially in both EP offices and hospitals."
Premier's Keith Figlioli, senior vice president of healthcare informatics, sees the rules taking the industry in the right direction for the advancement of interoperability.
"With interoperability standards, providers will be in a much better position to manage population health across the care continuum and support advanced payment initiatives such as shared savings and bundled payment," he said. "This is a necessary step to optimize HIT investments, improve the quality of care across settings and avoid the cost burdens associated with the work around solutions that are needed today for systems to 'talk' to one another."