Proposed rules for Stage 3 of meaningful use offer hospitals some flexibility in hitting required objectives, but hospital CIOs find some challenging targets in their initial review of the regulation.
The notice of proposed rule-making (NPRM), released late Friday afternoon by the Centers for Medicare & Medicaid Services, details the agencys initial proposal for criteria that hospitals and physician organizations will need to achieve to qualify for incentive funding for Stage 3 of the EHR Incentive Program. The rule will officially be published on March 30, and organizations will have 60 days after that to file comments on the proposed rule.
Hospital executives who reviewed the rule this past weekend were encouraged by CMSs approach in developing the proposed rule.
The new MU Stage 3 rule, along with its companion rule addressing specifics on many standards and criteria, seem to hit all the right buttons, said George Buddy Hickman, executive vice president and CIO for Albany (N.Y.) Medical Center. Its focus on continuous improvement to quality and adoption measures, increased privacy and security management, standards-based data exchange and other features are all things that we can support.
The Stage 3 proposed rule appears to be crafted to elicit provider feedback and responses to provisions, believes Charles Christian, vice president and CIO at St. Francis Hospital in Columbus, Ga. There are many requests for comments on a variety of approaches and options, which leads me to believe that CMS is wanting to create the flexibility they mentioned over the course of the next year or so.
However, proposed rules set some challenges for hospitals and physician organizations. Christian said the requirement in the rule for secure messaging will be challenging for healthcare organizations, especially in situations where chronically ill patients obtain most of their care on an outpatient basis. Stage 3 rules only cover secure messaging by inpatient and emergency departments.
Proposed rules also raise the percentage of patients accessing their healthcare information online to 25 percent, from 5 percent in Stage 2. We were able to get to just a little above 10 percent, but Ive spoken to many other facilities that struggled to reach the 5 percent mark, Christian said. We need to work at getting our patients engaged in their care; however, Im unsure, given the amount of effort required to hit the 5 percent mark, that most organizations will be able to reach the new goal.
While the new rule has only eight objectives, less than half as many as included in Stages 1 and 2, more than 15 measures are associated with the objectives, noted Jeff Smith, vice president of public policy for the College of Healthcare Information Management Executives. That lessens the streamlined nature of the regulation, he said. Overall, I think CMS is attempting to respond to historic criticisms while moving the needle on patient engagement, interoperability and care coordination.
Hickman worries about the overall approach being used to achieve change within the industry. We are apparently attempting to transform our industry through federal and state regulations, which arent always in alignment or dont consider impacts relative to one another, he said. We have meaningful use, ICD-10, cybersecurity and interoperability expectations, to name a few. These bear heavily on our people and other resources, and the same resource challenge is borne by our key EHR vendors.
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