MU3 awakens ghosts of MU past

The fervor surrounding the release of CMS' proposed rule for meaningful use stage 3 has slowly settled, but analysis of the rule has, for some, awakened memories of previous meaningful use rule releases.

The combined 301 pages of the proposed meaningful use stage 3 rule, along with the 431-page health IT certification criteria document, outline the next steps, rules, regulations and requirements the healthcare industry will face as it continues its evolution into a digital industry.

Jason Fortin, senior advisor at health IT consulting firm Impact Advisors, says the proposed rule, more than anything, is shrouded in uncertainty. "I say that because I don't know that we're going to know what the most challenging measures will be," Mr. Fortin says.

"I think back to when the stage 2 rule came out and the now infamous 10 percent of summary care record and transitions of care [measure] was by far the hardest part," Mr. Fortin continues. "That didn't look so bad when it first came out. It wasn't until hospitals and physicians started to understand the technical requirements behind it — what it meant in terms of workflow — that people were like, 'This is going to be really hard.'"

Some of the proposed measures in the new rule seem likely to follow the same path of meaningful use stage 2's transitions of care and summary care record provisions, Mr. Fortin says. For example, the proposed rules would require eligible hospitals and professionals to incorporate patient-generated health data from nonclinical settings for more than 15 percent of unique patients. At first glance, the task doesn't appear too overbearing, but the background preparation needed to support this measure paints a different picture.

"It's hard to say how hard that [measure] is going to be because vendors have to get their products certified, providers have to implement those capabilities and then they have to redesign their workflows," Mr. Fortin says.

Compare measures like that to measures pertaining to computerized physician order entries requiring 80 percent of medication orders to move through a CPOE. Mr. Fortin says such a measure outlines a known quantity, and hospitals already have a sense of how to achieve that measure.

"I'm not saying 80 percent medication orders is going to be easy, but it's a known quantity," he says. "A measure may look easy on paper, but you just don't know. I think that's a really big challenge."

Additionally, Mr. Fortin anticipates issues arising regarding the new timelines and reporting schedules in the proposed rule.

The proposed rule mandates all eligible hospitals and providers to attest to stage 3 in 2018 regardless of their prior attestation stages. However, hospitals and providers do have the option of attesting in 2017, a timeline which is not very practical, according to Mr. Fortin.

"The final rule wouldn't come out until fall of this year, based on previous iterations. If it comes out in fall 2015, the 2017 reporting year starts in January 2017. That's not much time," he says. "I could see a scenario which we went through in 2014 — certification issues and just a rush to get capabilities in place."

The year-long reporting requirement, too, may present obstacles that CMS has faced before. Mr. Fortin says he has heard anecdotal situations where CMS' website has crashed when a high volume of eligible professionals and hospitals were trying to attest and CMS' resources were spread rather thin.

"Having everyone attesting at the end of the year, there could very well be a possibility of sites crashing and a constraining of resources," Mr. Fortin says. "If people have to get questions answered from CMS, having everybody on the same timeline sounds simpler, but in practice might be more [difficult] than we realize at this point."

The mandatory 2018 transition to stage 3 also presents a unique challenge for providers who are required to attest. In theory, Mr. Fortin says having everybody on the same stage will reduce confusion, but it heightens the transition period for new providers who are joining the industry.

"There are always going to be new physicians coming into the healthcare systems, and having them start right out of the gates at stage 3, that's tough," Mr. Fortin says.

While the outlined processes are meant to streamline the attestation process and help the industry move more quickly toward digitization as a whole, players navigating the health IT game are bound to encounter some choppy waters — though they appear to be troubles previously encountered.

CMS can't offer hospitals and providers the full flexibilities they desire, but it profits all involved stakeholders to find a way to avoid the same issues the industry has previously faced.

Stage 3 is new, and with it will come new, unforeseen challenges. Alongside the future uncertainty lies the power of past experiences. In this regard, providers and hospitals have the opportunity to use past lessons learned to strategize their approach for future attestation. It still won't be easy, but it's a start.

"It's going to be a big jump. Stage 2 to stage 3 is a big jump, and going from stage 1 to stage 3, not to state the obvious, but that's going to be challenging," Mr. Fortin says.

More articles on meaningful use:

Harvard Public Health physician: MU stage 3 one step, but not enough
5 things to know about the ONC 2015 health IT certification criteria
A guidebook to MU stage 3's 8 objectives


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