Stage 3

Several groups have offered recommendations for CMS' proposed rule for Stage 3 of the meaningful use program, Clinical Innovation & Technology reports (Walsh, Clinical Innovation & Technology, 5/29).

Background

Under the 2009 economic stimulus package, providers who demonstrate meaningful use of certified electronic health records can qualify for Medicaid and Medicare incentive payments.

The comment period for the Stage 3 proposed rule closed on Friday.

Under the proposed rule, all eligible professionals beginning in 2018 would report on Stage 3 of the meaningful use program regardless of their previous participation. Providers would have the option to move to Stage 3 starting in 2017 (iHealthBeat, 5/28).

AMA's Comments

In a letter, the American Medical Association called on CMS to address current program issues before moving on to the next stage.

The association made several recommendations should CMS choose to continue with the Stage 3 transition in 2018, including:

• Allowing quality measures that are reported to clinical registries to satisfy meaningful use reporting requirements;
• Establishing a reporting period that is less than one year;
• Seeking physician and vendor feedback before implementing or retracting measures; and
• Setting 2017 as a transitional year for providers and vendors to adapt to system and workflow changes (AMA release, 5/29).

AMIA's Comments

Meanwhile, the American Medical Informatics Association said that the transition to the Merit-based Incentive Payment System established by the repeal of Medicare's Sustainable Growth Rate formula would be "highly burdensome while offering only modest gains" under the proposed Stage 3 rule (Pittman et al., "Morning eHealth," Politico, 6/1).

HIMSS' Comments

In comments submitted last week, the Healthcare Information and Management Systems Society emphasized the importance of interoperability and the meaningful use program's role as a "critical tool for enabling health care transformation."

HIMSS also said that it supported CMS' efforts to align the meaningful use program with other CMS quality reporting programs that use certified EHR technology, citing the proposal's potential to ease the burden on providers.

However, HIMSS recommended that CMS:

• Allow 18 months between the finalization of relevant rules and the transition to Stage 3 for providers to prepare; and
• Lessen the "prescriptive nature" of the meaningful use program.

MGMA's Comments

In its own comments, the Medical Group Management Association also expressed concerns over the current state of the proposed rule.

MGMA said that the meaningful use "program has become a significant administrative burden and is proving to be counterproductive."

The group recommended that the proposed rule be "substantially modified" and urged CMS to delay finalizing the Stage 3 rule until:

• The effect of the Medicare Access and Children's Health Insurance Program Reauthorization Act of 2015 and its meaningful use provisions are determined; and
• Useful data on eligible professionals' participation in Stage 2 is made available.

MGMA also encouraged CMS to:

• Create additional categories for qualifying for hardship exceptions;
• Establish a 90-day reporting period for the entire program; and
• Set objectives and measures that are reasonable and do not discourage EPs from participating (Clinical Innovation & Technology, 5/29).

AHA's 2015 Health IT Certification Criteria Comments

Meanwhile, the American Hospital Association in a letter to National Coordinator for Health IT Karen DeSalvo applauded the 2015 Edition Health IT Certification Criteria proposed rule for its provisions to:

• Create a health information exchange infrastructure; and
• Improve interoperability.

However, AHA also urged the Office of the National Coordinator for Health IT to increase transparency and the reliability of certified health IT through:

• Surveillance of products being used "in the field";
• More disclosure requirements for vendors; and
• Testing (Dvorak, FierceHealthIT, 5/29).

Linda Fishman, senior vice president of public policy analysis and development at AHA, wrote, "While this may narrow the scope of a final 2015 Edition rule," it also could "improve both the ability of vendors to develop technology in conformance with certification requirements and the ability of providers to successfully implement technology to meet regulatory requirements" (AHA News, 5/29).