Reactions among healthcare leaders were swift to the release of the final rule to Stage 3 of meaningful use under the HITECH (Health Information Technology for Economic and Clinical Health) Act, when that release was announced on Oct. 6. Generally, provider leaders were enthusiastic about the streamlining of elements of Stage 3 and the simplification and reduction of process measures required of them, based on first reads of the press release announcement by the Centers for Medicare & Medicaid Services on Tuesday afternoon, though they also expressed the desire to read all the details of the 752-page rule before making definitive judgments.
Healthcare associations respond
Representing the reaction of the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME), Charles E. (Chuck) Christian, chairman of CHIME’s board of trustees, released a statement Tuesday evening that included the following: “We are pleased that the Centers for Medicare & Medicaid Services today finalized modifications to the current stages of the Meaningful Use program and agreed to extend the comment period on Stage 3. CHIME and its 1,700-plus members agree with CMS that it is time to focus the Meaningful Use program on adoption of information technology systems that improve both the quality and safety of patient care. The 752-page rule grants flexibility for providers who are doing their best to not only meet the intent of the federal program, but also ensure the adoption of health information technology that improves patient care.”
The statement noted that, “Importantly, the rule adopts a 90-day reporting period for the current stages of the program, down from 365 days. CHIME has long called for a 90-day reporting period and applauds CMS for adopting this new standard. While several members are positioned to take advantage of this shorter period, others will be challenged to meet it since there are fewer than 90 days remaining in the year. We urge CMS to implement a hardship exemption for those unable to meet this timeframe.”
And it went on to say that “CHIME also applauds the agency for modifying requirements surrounding patient access to electronic records. The rule stipulates that for 2015 and 2016, one patient discharged from a hospital view, download or transmit their electronic record. With regard to Stage 3, the extra comment period will enable providers, CMS and other stakeholders to ensure that the next stage of Meaningful Use advances interoperability and takes into account new payment models being advanced by Medicare.” Christian’s statement noted that CHIME’s leaders were reviewing the rule in detail, and “will have more detailed comments in the coming days.”
A statement released by the Chicago-based Healthcare Information and Management Systems Society (HIMSS), and attributed to Carla Smith, executive vice president, HIMSS North America, said, “IT is a critical tool enabling positive transformation, value-based care models, and the delivery of better care, improved outcomes, and lower costs. In response to the new final regulations released today, HIMSS appreciates the continued efforts of CMS and ONC to simplify and provide flexibility for meeting the Meaningful Use program requirements. We support the confirmation of the 90-day reporting period for 2015. Further, we support the emphasis placed on January 1, 2018 - the start of the period where providers are required to meet Stage 3 objectives and measures.”
Ms. Smith’s statement went on to say that, “Consistently, HIMSS has called for at least 18 months between the publication of a new Meaningful Use rule and the start of a new Stage’s reporting period—the 27 months provided in this final rule appears to address this issue. HIMSS encourages reasonable Meaningful Use-related rules and timelines, as these enable providers to continue their participation in the program, thus supporting a positively transformed health system.”
The statement from the Chicago- and Washington, D.C.-based American Medical Association, attributed to Steven J. Stack, M.D., the AMA’s president, was more guarded in tone. Dr. Stack was quoted in the statement as saying, “While the American Medical Association (AMA) is still in the process of reviewing the Meaningful Use regulations published today, we are pleased that the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordination (ONC) listened to the AMA and the concerns of physicians in several key areas in the modifications rule. In particular, the agency addressed the delay in issuing the modifications rule by allowing a hardship exemption for physicians who are unable to attest this year, providing needed relief for those uncertain about the 2015 program requirements. We also acknowledge that the agency is working to improve patient engagement by ensuring that patients can access portals while still providing flexibility in the measure requirements.”
What’s more, Dr. Stack’s statement went on, “The AMA continues to believe that Stage 3 requires significant changes to ensure successful participation, and improve the usability and interoperability of electronic health record systems. We urge CMS to use the additional public comment period provided for Stage 3 to further improve the program and consider changes related to the Medicare Access and CHIP Reauthorization Act, which was signed into law earlier this year. We also want to make sure that EHR vendors have the time they need to further test products for interoperability, usability, safety and security. We hope that health IT certification is nimble enough to accommodate future technology innovations and that the program not seen as final at this time.”
And the statement concluded by stating that “The AMA recognizes that physicians continue to struggle with the Meaningful Use program, however, we hope the decision by CMS to leave Stage 3 open to additional comment will allow for further improvements in the program and promote technological innovation that supports patient care.”
Healthcare IT leaders cautiously optimistic, but want the details
Healthcare IT leaders gathered in Chicago for the Health IT Summit in Chicago, sponsored by the Institute for Health Technology Transformation (iHT2, a sister organization to Healthcare Informatics) on Wednesday, when given the outline of CMS’s announcement, expressed cautious optimism, though all said that they wanted to read the details of the 752-page final rule before offering final judgments.
John Lee, M.D., CMIO of Edward Hospital, based in the Chicago suburb of Naperville, Ill., said, “I want to preface my remarks by saying that I think that Stage 3 should be squashed altogether, and we should rely on MACRA [the Medicare Access and CHIP Reauthorization Act of 201] and MIPS [the new Merit-based Incentive Payment System, authorized under the MACRA legislation] for the changes that occur, because we can’t do MACRA and MIPS without the steps that will take place under meaningful use. I’d still like to see the specific details,” he added.
That said, Lee said, “It looks like they basically amputated large chunks of the measures. If this is them saying, we still have to do meaningful use Stage 3, but making the measures minimally onerous so that it would be essentially just like not doing Stage 3, I would be delighted. But,” he asked, “why do we still need clinical quality measures, when all that stuff is rolled into MIPS and MACRA anyway? We should just have quality metrics, and have the generation of the quality metrics dependent on your having a good data infrastructure and good data. But reducing the total number of metrics by two-thirds is good; but again, the devil’s in the details.”
Brian Patty, M.D., CMIO at Rush University Medical Center in Chicago, said, based on a preliminary read, that “It sounds like they’re simplifying it a lot, which is good, because it was just too much of a burden on folks. And I like the inclusion of a 90-day period, because that was so critical for us in Stages 1 and 2, to see if what we had built worked. Right out of the gate, if you have to report for a whole year, if what you did didn’t work, you’re collecting bad data for a very long time without the opportunity to course-correct,” he said.
Patty applauded the reduction in core measures .That is absolutely good,” he said. It takes the burden off these poor primary care docs, who have to make sure they’re hitting all the measures. So by simplifying it and focusing it on fewer measures, I think they’re doing a really good thing. I think the changes they’ve made will take the teeth out not moving forward on Stage 3. I think it will take some of that resistance away.
Bala Hota, M.D., chief research informatics officer at Rush, said, “It looks like the emphases are in the right place—interoperability, standardization of quality measurement, and then the API [focus]—so, you’ve got data access, and then standards around that. Whether it’s burdensome or not is in the details. So that’s where I think more information is critical,” he said. “It is interesting that they are trying to align this with MIPS, which just emphasizes that we’re moving to this value-based system of reimbursement in the ambulatory setting; and organizations really need to be looking at that. And they’ve announced an additional 60-day comment period, which is confusing.”
Hota went on to say that “The opportunities with APIs to access data in order to increase innovation, are enormous. I have my phone; I already have, through the EHR’s portal, access to data on my phone. If that data is liberated further, you could do so much. Each app could provide a rules engine for analytics or personalized medicine for me. So what’s my cardiovascular risk score? My phone will tell me. Now, based on activity, which my phone can track, how does that change? You can integrate those two phenomena.”
Cynthia Burghard, research director at IDC Health Insights, Framingham, Mass., agreed with all the other leaders attending the Health IT Summit in Chicago and who had spoken to HCI, saying, “The devil’s in the details. It sounds like there may be some flexibility around the definition of metrics, which is important, and the rationalization of existing metrics is critical. We so quickly end up with disconnects around what is important to measure. And the faster CMS can get to that, the more likely the vendors will actually be able to accommodate it.”