MU3 walks the line between increased flexibility, heightened requirements

On Friday, CMS released the proposed rule for meaningful use stage 3 requirements outlining changes to reporting structures, attestation requirements and alignment with other CMS quality measurement programs.

Reactions to the proposed rules are still being gauged, but are likely to be mixed. CMS introduced several areas of flexibility in certain regards, but upped the ante of requirements in others.

For example, every provider, hospital and critical access hospital will be required to attest to stage 3 in 2018, a solid, universal deadline. However, the rule offers flexibility in that providers can start to attest to stage 3 in 2017 if they choose to do so.

"It's not the level of flexibility the industry was asking for," says Chuck Christian, vice president and CIO of St. Francis Hospital in Columbus, Ga., and board chairman of CHIME.

For example, the proposed rule maintains the "all or nothing" provision, requiring those attesting to meet all requirements to qualify for incentive payments. Additionally, providers attesting for the first time have to adhere to a 365-day reporting period, though for previous stages they only had to attest for a 90-day reporting period. (Eligible providers and hospitals attesting for the first time to the Medicaid EHR Incentive Program are exempt from this.)

However, the proposed rule does seek to reduce some of MU's administrative burden.

"They're trying to do some harmonization related to the quality of reporting [programs], which will be really good, getting us all on the reporting cycle of the calendar year rather than physicians being on the calendar year and providers being on a fiscal year," Mr. Christian says.

Erik Dahl, IT audit director for CHAN Healthcare, a subsidiary of public accounting and consulting firm Crowe Horwath LLP, says some of the percentages providers will have to meet may present a challenge, such as the percentage of patients who access their health information, which jumps from 50 percent to 80 percent.

"They do say for some of these measure increases they're looking at stage 2 data and feel that these percentage increases will be reasonable; however, the concern I have in taking that approach is that really the adoption of stage 2 is still ongoing, so to take that data from what I'll call the 'early adopters' and base percents on stage 3 may be a little premature," Mr. Dahl says.

He agrees with Mr. Christian on the quality program reporting schedule changes. "I think there is hopefully sufficient time to move those from the report and attestation to truly implementing the PQRS program and the IQR program for hospitals," Mr. Dahl says.

Regarding the mandatory 2018 attestation, Mr. Dahl says it has positive intentions, but it will "make the climb to being a meaningful user a little steeper" for late adopters.

More articles on meaningful use:

Epic defends its interoperability at Senate hearing
AHA to Congress: Be flexible with MU, but forge ahead with ICD-10
Who are the EHR non-adopters?


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