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MU Stage 3- Did the CMS finally get it right?
© CureMD Healthcare
Meaningful Use stage 3 Strategy
• Stage 3 of Meaningful Use is expected to be the final
stage. It incorporates major portions of the prior stages
as well as introduces many new challenges. What else
does this 300-page document entail and its fine print?
• CureMD investigates to make it simple for you
• The March 20th announcement of the proposed
Meaningful Use Stage 3 rule by the Centers for
Medicare & Medicaid Services (CMS) is still being
dissected, analyzed, and reanalyzed by healthcare
experts
• While we can spend our time going through 300-page
long documents, physicians might not find it the
easiest thing to read. For your convenience, we have
compiled a list of things you should know about
Meaningful Use stage 3. You can also read the
complete proposed rule here
• Remember
CMS is open to public comments and will be taking
your feedback before finalizing the rule in the third
quarter of this year. This feedback period will end May
29, 2015
Meaningful Use stage 3 Strategy
Meaningful Use stage 3 Strategy
1. Reporting in 2017 isn’t compulsory – Phew!
– Instead of 2017, the compulsion for all providers to report for
Stage 3 would be 2018
– In 2017, providers expected to move from Stage 2 to Stage 3
could choose to stay on Stage 2; and make the ‘more
convenient’ transition in 2018
– To attest to Stage 3, you will require a 2015 ONC certified EHR
Meaningful Use stage 3 Strategy
2. Every provider must attest to Stage 3 in 2018 – No
training wheels for New Providers
– Irrespective of your first year of reporting, you will have to
attest to MU Stage 3 in 2018. Group practices will benefit
from this change as they will have to focus on a single set
of measures for everyone
– However, critics are of the view that startup practices or
people using the EHR technology for the first time will find
it difficult
– They will have to adjust their workflows for such advanced
level of reporting from the get go
Meaningful Use stage 3 Strategy
3. You must report for one whole calendar year
unless you are a Medicaid EP – Unfair much?
– Starting from 2017, all providers will report according to a
full calendar year period.
– This step is being taken to align MU closer to other CMS
quality-reporting initiatives such as the Physician Quality
Reporting System (PQRS)
– In the past CMS has shortened reporting periods based on
provider feedback and would probably be doing the same
this year due to the poor implementation rates of MU
Stage 2
Meaningful Use stage 3 Strategy
– But beyond that, we highly doubt there would be any
further flexibility. There will not be a 90-day reporting
period for new provider-registrants of the MU program
either
– The only exemption, which is garnering a lot of criticism
from some quarters, is that Medicaid Eligible Professionals
(EPs) and hospitals can report for 90 days in their first year
– We agree with this criticism and think that the playing field
should be leveled for all new entrants into the program.
We would definitely like to get your feedback on this
Meaningful Use stage 3 Strategy
4. Eight specific objectives, but higher thresholds –
Interoperability and Patient Engagement returns
with a bang
– The number of specific objectives have been reduced to
eight so that providers maximize their attention towards
the “advanced usage” of EHRs
– Patient engagement and interoperability are the areas of
maximum focus; Stage 3 will require an excess of 35 % of
patients to be sent a secure message via the provider’s
EHR, or in response to a secure message sent by the
former
Meaningful Use stage 3 Strategy
Meaningful Use stage 3 Strategy
– More than 25% of patients who visit an EP (or are
discharged by a hospital) must electronically obtain their
health information is another addition that many will find
difficult to implement, given the low levels of patient
engagement (electronically) at most practices
– After this, you might want to read How to Succeed with
Patient Portals for Meaningful Use Stage 2
– There is some fine-print though. Contained within many of
the objectives are multiple measures
Meaningful Use stage 3 Strategy
– Depending on which option one chooses, and whether you
are a provider or a hospital, the total number of MU
measures could range from 15 to 20, and that’s NOT
INCLUDING the clinical quality measures
– Which have always been like a MU menu all of their own,
and which are now going to be determined through a
different process and won’t be defined until later in 2015
Meaningful Use stage 3 Strategy
5. Meaningful Use concludes at Stage 3, but the
mission continues
– While the MU program will conclude with Stage 3, the
CMS expects technology and quality care to improve with
time
– So a significant proportion of healthcare experts including
myself are of the view that CMS will build on the base set
by the MU program through other government-backed
quality and technology programs in the future
Meaningful Use stage 3 Strategy
• Our two cents
– We think that for a first draft, the CMS is definitely on the
right track. They’ve addressed and rectified many of the
issues that providers faced in the earlier stages of the
program; however, they might have been too ambitious in
certain areas
– A year long reporting period for example, is asking
physicians too much. This data helps to improve healthcare
in US, agreed
– But seriously can’t a subset of this information be enough
to monitor disease patterns?
Meaningful Use stage 3 Strategy
– If a clinician has 12 minutes to see a patient, be
empathetic, document the entire visit with sufficient
granularity to justify an ICD-10 code, achieve 140 quality
measures, never commit malpractice, and broadly
communicate among the care team,
– It’s not clear how the provider has time to perform a
“clinical information reconciliation” that includes not only
medications and allergies, but also problem lists 80
percent of the time
Meaningful Use stage 3 Strategy
– Maybe we need to reduce patient volumes to 10 per day?
Maybe we need more scribes or team-based care? And
who is going to pay for all that increased effort in an era
with declining reimbursements/payment reform?
– Boiling the Frog, each incremental proposal is tolerable,
but the collective burden is making practice impossible
Read more on blog.curemd.com
• To read more on this topic, visit:
• http://blog.curemd.com/mu-stage-3-did-the-cms-
finally-get-it-right/
CureMD Healthcare
120 Broad Street, New York, NY 10271
Ph: 212.509.6200
www.curemd.com
Thank you!

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Mu stage 3 did the cms finally get it right

  • 1. MU Stage 3- Did the CMS finally get it right? © CureMD Healthcare
  • 2. Meaningful Use stage 3 Strategy • Stage 3 of Meaningful Use is expected to be the final stage. It incorporates major portions of the prior stages as well as introduces many new challenges. What else does this 300-page document entail and its fine print? • CureMD investigates to make it simple for you • The March 20th announcement of the proposed Meaningful Use Stage 3 rule by the Centers for Medicare & Medicaid Services (CMS) is still being dissected, analyzed, and reanalyzed by healthcare experts
  • 3. • While we can spend our time going through 300-page long documents, physicians might not find it the easiest thing to read. For your convenience, we have compiled a list of things you should know about Meaningful Use stage 3. You can also read the complete proposed rule here • Remember CMS is open to public comments and will be taking your feedback before finalizing the rule in the third quarter of this year. This feedback period will end May 29, 2015 Meaningful Use stage 3 Strategy
  • 4. Meaningful Use stage 3 Strategy 1. Reporting in 2017 isn’t compulsory – Phew! – Instead of 2017, the compulsion for all providers to report for Stage 3 would be 2018 – In 2017, providers expected to move from Stage 2 to Stage 3 could choose to stay on Stage 2; and make the ‘more convenient’ transition in 2018 – To attest to Stage 3, you will require a 2015 ONC certified EHR
  • 5. Meaningful Use stage 3 Strategy 2. Every provider must attest to Stage 3 in 2018 – No training wheels for New Providers – Irrespective of your first year of reporting, you will have to attest to MU Stage 3 in 2018. Group practices will benefit from this change as they will have to focus on a single set of measures for everyone – However, critics are of the view that startup practices or people using the EHR technology for the first time will find it difficult – They will have to adjust their workflows for such advanced level of reporting from the get go
  • 6. Meaningful Use stage 3 Strategy 3. You must report for one whole calendar year unless you are a Medicaid EP – Unfair much? – Starting from 2017, all providers will report according to a full calendar year period. – This step is being taken to align MU closer to other CMS quality-reporting initiatives such as the Physician Quality Reporting System (PQRS) – In the past CMS has shortened reporting periods based on provider feedback and would probably be doing the same this year due to the poor implementation rates of MU Stage 2
  • 7. Meaningful Use stage 3 Strategy – But beyond that, we highly doubt there would be any further flexibility. There will not be a 90-day reporting period for new provider-registrants of the MU program either – The only exemption, which is garnering a lot of criticism from some quarters, is that Medicaid Eligible Professionals (EPs) and hospitals can report for 90 days in their first year – We agree with this criticism and think that the playing field should be leveled for all new entrants into the program. We would definitely like to get your feedback on this
  • 8. Meaningful Use stage 3 Strategy 4. Eight specific objectives, but higher thresholds – Interoperability and Patient Engagement returns with a bang – The number of specific objectives have been reduced to eight so that providers maximize their attention towards the “advanced usage” of EHRs – Patient engagement and interoperability are the areas of maximum focus; Stage 3 will require an excess of 35 % of patients to be sent a secure message via the provider’s EHR, or in response to a secure message sent by the former
  • 9. Meaningful Use stage 3 Strategy
  • 10. Meaningful Use stage 3 Strategy – More than 25% of patients who visit an EP (or are discharged by a hospital) must electronically obtain their health information is another addition that many will find difficult to implement, given the low levels of patient engagement (electronically) at most practices – After this, you might want to read How to Succeed with Patient Portals for Meaningful Use Stage 2 – There is some fine-print though. Contained within many of the objectives are multiple measures
  • 11. Meaningful Use stage 3 Strategy – Depending on which option one chooses, and whether you are a provider or a hospital, the total number of MU measures could range from 15 to 20, and that’s NOT INCLUDING the clinical quality measures – Which have always been like a MU menu all of their own, and which are now going to be determined through a different process and won’t be defined until later in 2015
  • 12. Meaningful Use stage 3 Strategy 5. Meaningful Use concludes at Stage 3, but the mission continues – While the MU program will conclude with Stage 3, the CMS expects technology and quality care to improve with time – So a significant proportion of healthcare experts including myself are of the view that CMS will build on the base set by the MU program through other government-backed quality and technology programs in the future
  • 13. Meaningful Use stage 3 Strategy • Our two cents – We think that for a first draft, the CMS is definitely on the right track. They’ve addressed and rectified many of the issues that providers faced in the earlier stages of the program; however, they might have been too ambitious in certain areas – A year long reporting period for example, is asking physicians too much. This data helps to improve healthcare in US, agreed – But seriously can’t a subset of this information be enough to monitor disease patterns?
  • 14. Meaningful Use stage 3 Strategy – If a clinician has 12 minutes to see a patient, be empathetic, document the entire visit with sufficient granularity to justify an ICD-10 code, achieve 140 quality measures, never commit malpractice, and broadly communicate among the care team, – It’s not clear how the provider has time to perform a “clinical information reconciliation” that includes not only medications and allergies, but also problem lists 80 percent of the time
  • 15. Meaningful Use stage 3 Strategy – Maybe we need to reduce patient volumes to 10 per day? Maybe we need more scribes or team-based care? And who is going to pay for all that increased effort in an era with declining reimbursements/payment reform? – Boiling the Frog, each incremental proposal is tolerable, but the collective burden is making practice impossible
  • 16. Read more on blog.curemd.com • To read more on this topic, visit: • http://blog.curemd.com/mu-stage-3-did-the-cms- finally-get-it-right/
  • 17. CureMD Healthcare 120 Broad Street, New York, NY 10271 Ph: 212.509.6200 www.curemd.com Thank you!