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Stage 3 of Meaningful Use Still Lacks Interoperability and Provider Groups Aren't Pleased

by Stephanie Zaremba, Director of Government and Regulatory Affairs

Last month, the Centers for Medicare and Medicaid Services (CMS) finalized changes to Stage 2 of Meaningful Use for 2015-2017 and new Stage 3 requirements to take effect in 2018. This final rule was largely consistent with what CMS proposed in April, aimed at reducing the complexity of program requirements. Yet despite CMS’s attempt to simplify the Meaningful Use program in response to years of stakeholder complaints, the final rule was again met with widespread criticism, particularly from providers.

For Meaningful Use in the rest of 2015 through 2017, the major changes include:

  • 10 objectives for eligible professionals, including one consolidated public health reporting objective, as opposed to 18 objectives in previous years.
  • 9 objectives for eligible hospitals and critical access hospitals, again including one consolidated public health reporting objective, down from 20 objectives in previous years.
  • A 90-day reporting period for 2015, a full-year reporting period for 2016, except for first-time participants in Meaningful Use, and a full-year reporting period for 2017, except for first-time participants or participants opting to implement Stage 3 a year earlier than required.
  • Providers need only to enable the capability for secure messaging with patients during the reporting period, dramatically scaling back the original requirement that 5% of patients must send providers a secure message.

Meaningful Use Stage 3 will begin for all providers in 2018. The major provisions of that rule include:

  • Providers have the option to begin Stage 3 in 2017 with a 90-day reporting period, as opposed to the full-year reporting period required for all non-first-time participants in 2018.
  • 8 objectives for eligible professionals, eligible hospitals, and critical access hospitals.
  • Clinical Quality Measure reporting aligned with other CMS quality reporting programs, such as the Physician Quality Reporting System (PQRS) and the Value-Based Modifier program.
  • An increased reliance on Application Programming Interfaces (APIs) for care coordination and patient engagement requirements. 

So why are providers in particular unhappy with the new rules? It comes down to interoperability, or the lack thereof. 110 state and national medical societies joined the American Medical Association this month in requesting Congressional action to “refocus” the Meaningful Use program, saying that,

“the success of the program hinges on a laser-like focus on promoting interoperability and allowing innovation to flourish as vendors respond to the demands of physicians and hospitals rather than … ill-informed check-the-box requirements of the current program.”  

Trinity Health, one of the largest Catholic health care delivery systems in the nation, wrote to the Administration with a similar request: either declare the Meaningful Use program a success in driving the adoption of health IT and terminate the program, or withdraw the recent rules and – again – refocus the program on interoperability.

Amen to that. 

At athenahealth, we think that it is high time that interoperation is achieved in health care the same way that it was achieved years ago in other sectors of the information economy: not through government mandates, but through private sector collaboration fueled by consumer demand for and a shared commitment to openness. Have you heard of the Office of the National Coordinator for the Internet to promote nationwide exchange of information over the World Wide Web? How about the federal advisory committee that recommends the technical standards for exchanging word documents? We didn’t think so. 

It takes more than technical standards and more than required Meaningful Use measures for sending care summaries to make interoperation in health care look like the ubiquitous information flow that we are accustomed to as consumers every time we book a flight on Kayak.com or use our Facebook account to log into another site. What it takes is the genuine sea change in the health care industry’s attitude toward interoperating that began over a year ago and continues today. Health IT vendors, providers, and health systems are collaborating on information exchange more than ever through initiatives like the CommonWell Health Alliance, Sequoia Project, Argonaut Project, and recent announcement from the KLAS Keystone Summit that EHR vendors will agree to objective measures of interoperability and ongoing reporting. 

Taxpayers have invested $30 billion to incentivize the adoption of electronic health records (EHRs), and providers and health systems have invested countless resources in the transition. If at the end of this process we are left with a healthcare system that, though digital, is still fragmented by IT platforms that cannot exchange critical patient health information, all of that investment will be wasted. However, from athenahealth’s perspective, policymakers interested in ensuring a truly interoperable health care industry would be best served by listening to providers, taking a step back, and observing how rapidly the environment around information exchange is evolving. 




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