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Advocacy Groups Question Logic of Stage 3 Proposals to CMS

May 28, 2015
by Gabriel Perna
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Patient-generated data, care coordination objectives targeted by advocacy groups

Healthcare advocacy groups and other stakeholders are turning a critical eye towards the proposed rule for Stage 3 of meaningful use.

Comments for the Stage 3 proposed rule, released in March, are due at the end of the week. Major groups, such as the American Hospital Association (AHA) and the College for Healthcare Information Management Executives (CHIME), have begun to release their overall thoughts. The early consensus is a negative outlook on the Stage 3 proposals.

CHIME called the sum of all Stage 3 proposals by the Centers for Medicare and Medicaid Services (CMS) “unworkable.” Specifically, CHIME mentioned the requirement that would establish a single set of objectives and measure, tailored to eligible providers (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs), by 2018. They said that most providers wouldn’t be able to participate by 2018.

“And with so few providers having demonstrated Stage 2 capabilities, we question the underlying feasibility of many requirements and question the logic of building on deficient measures,” CHIME wrote in its letter to Andy Slavitt, Acting Administrator for CMS.

CHIME offered specific suggestions including a 90-day reporting period for the first year of Stage 3, the elimination of patient action thresholds for the care coordination objectives, reduce the view, download or transmit requirement from 25 percent to five percent, reduce the number of measures in multi-measure objectives, and allowing paper-based means to achieve measure thresholds. They specifically targeted the patient action requirements to care coordination, saying it was “unrealistic.”

"We question the value of setting thresholds for technology and process not yet invented, let alone widely deployed in healthcare," CHIME Board Chair Charles E. Christian, Vice President of Technology and Engagement with the Indiana Health Information Exchange, said in a statement. "From the heavy reliance on APIs to an assumption that patient-generated health data will flow in standardized ways, our industry has a long way to go if it is going to catch-up with this rule by 2018."

The AHA had an even more critical tone with the patient-generated data element. They called it “premature” in their comments. They said the readiness of standards to support the validation of the data and the ability to match the data to the correct patient are record are “unknown at this time.” They also say that the concept of using APIs to share data also lacks maturity and the security risks are too significant to be a requirement. Like CHIME, they said the lack of a patient matching solution is a huge issue to accelerating health information exchange.

Both the AHA and CHIME were not certain over the health information exchange objectives outlined in the proposed rule. CHIME said the thresholds for the three HIE measures were unrealistic while AHA said that the standards and exchange infrastructure were not mature.

Moreover, the AHA said that CMS should avoid doing anything at all with Stage 3 until Stage 2 is all settled.  “While the Stage 3 proposals offer promising ideas that could further health information exchange and support greater patient engagement, we do not yet have sufficient experience at Stage 2 to be confident that the proposals for Stage 3 are feasible and appropriate,” AHA Executive Vice President Rick Pollack wrote.

Healthcare Informatics will add more to this story as published comments from stakeholders roll in. Once the commenting period ends, CMS will use that feedback to create the Stage 3 final rule. Potentially adding to the confusion is a requirement in newly minted legislation repealing the Sustainable Growth Rate that sunsets penalties for meaningul use by 2019.