Stage 3 Rule Seeks to Simplify, Streamline Meaningful Use Program

As the final expected stage of the meaningful use program, a lot is riding on the Stage 3 proposed rule released by the Centers for Medicare and Medicaid Services.

Consequently, according to Elisabeth Myers, policy and outreach leader for the CMS Center for Clinical Standards and Quality, Stage 3 must serve as the “platform for the program over the long term.”

Among the goals is to provide a flexible, clearer framework that simplifies the MU program to reduce the complexity created by multiple stage requirements and to reduce provider burden, while ensuring the long-term sustainability of the program.

“The program does not sunset so there needs to be a strong foundation for sustainability,” Myers told a May 5 CMS eHealth provider webinar. Another goal of Stage 3 is to “advance the use of health IT to promote information exchange and improved outcomes for patients,” she said, adding that “we’ve always said Stage 3 was going to be largely focused on improved outcomes.”

Also See: Mixed Industry Response to Stage 3 Meaningful Use Rule

CMS in Stage 3 also is proposing changes to the reporting period, timelines, and structure of the MU program that include providing a single definition of meaningful use. “We have Stage 1, Stage 2 and Stage 3 and the current structure of the program would mean that essentially beginning in 2017 or 2018 we’d have six different versions of the program if you multiply three stages times [eligible professionals] plus [eligible hospitals]. And, really what it ends up being is about 12 versions of the program if you multiply that again times the Medicaid program and variations therein,” argued Myers.

Making matters worse, there are multiple reporting periods that only serve to add complexity to the MU program, she asserted. “And, while there may have been very good reasons to design it that way in the beginning in order to drive toward the adoption of a wide range of standards as well as technology and functions, the more complex the program the harder it is to be sustainable over the long term and the more it could potentially inhibit innovation and future growth.”

To streamline the MU program and achieve future sustainability, Myers said the Stage 3 proposal lays out a single stage and single reporting period for all providers. Specifically, the Stage 3 proposed rule would change the reporting period so that all providers would report under a full calendar year timeline with a limited exception under the Medicaid EHR Incentive Program for providers demonstrating meaningful use for the first time.

Following a proposed optional year in 2017, starting in 2018 all providers would report on the same definition of meaningful use at the Stage 3 level regardless of their prior participation, moving all participants in the EHR Incentive Programs to a single MU stage in 2018.

Myers also said that as part of its streamlining process CMS is proposing a set of eight core objectives with associated measures in Stage 3—about a 50 percent reduction compared to Stage 2.  She added that CMS analyzed the objectives and measures of meaningful use in Stage 1 and Stage 2 to determine measures that are redundant, duplicative, or have “topped out”—a term used to describe measures that have achieved widespread adoption at a high rate of performance and no longer represent a basis upon which provider performance may be differentiated.

Of the eight proposed objectives in Stage 3, Myers noted that the first four objectives—Protect Patient Health Information, Electronic Prescribing, Clinical Decision Support, and Computerized Provider Order Entry—are “legacy” objectives from Stage 1 and 2. The four remaining objectives—Patient Electronic Access to Health Information, Coordination of Care through Patient Engagement, Health Information Exchange, and Public Health and Clinical Data Registry Reporting—are “where you will see some differences in the proposed rule in Stage 3,” she concluded.

Myers said that the public comment period for the proposed Stage 3 rule closes on May 29.

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