On March 30, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator of Health Information Technology (ONC) published proposed rules to outline what they are thinking for U.S. Meaningful Use (MU) Stage 3 and to invite public comment. If finalized as proposed, the Stage 3 CMS rules would be available as an option for 2017 MU attestations and then mandatory beginning January 1, 2018.
Public comments are due by May 29. We encourage our MU customers to engage in review of the proposed rules with local associations and professional societies. We're already working with the HIMSS EHR Association to analyze these proposed rules and deliver detailed comments to CMS and ONC.
You're invited to share your thoughts about the impacts of the proposed rules with our Director of Regulatory Affairs, Rich Landen. We'll be sure to consider them in our own comments to federal regulators.
CMS Stage 3 Proposed Rule
The CMS Stage 3 proposed rule makes major modifications in the MU program:
- Stages—Stage 3 would be the final stage of MU and the only stage after 2017. Stage 1 and Stage 2 would be eliminated, even for new entrants to MU.
- Objectives—Although the number of objectives would decrease, the data demands on workflow would slightly increase.
- Reporting—Reporting burdens would decrease. Public health reporting would require bi-directional data flow.
- Clinical Quality Measures—CQM requirements are being decoupled from the MU rulemaking process. All CQM requirements would be updated annually by CMS in the In-patient and Physician Fee Schedule rule makings.
- Code Sets—Many of the code sets required in Stage 2 have been updated to more current versions, and many more code set requirements have been added.
- Patient Access—Patients would be given more direct access into QCPR using third-party applications over the Internet. In addition to their continued ability to view and download, patients would have a new ability to upload data into QCPR.
ONC Proposed Rule
In its certification rule, ONC proposes to eliminate the direct ties between EHR certification and the Meaningful Use program. Instead wants to adopt a philosophy that EHR certification should be foundational to other unspecified needs of CMS, federal, state, and private hospital and ambulatory programs, as well as Long Term and Post-acute Care organizations.
This rule proposes some new requirements on QuadraMed and all EHR developers. It eliminates the concept of "a complete EHR" in favor of an expansion of the number of EHR "modules" that can be optionally certified.
ONC also proposes to implement major changes in interoperability requirements. Such changes include requiring EHRs to support third-party applications, and establishing a large set of data elements that must be available for patient access. Privacy and security controls are becoming more complex, and more documentation of safety and usability design testing would be required.
Federal Field Audits
The ONC rule proposes federal field audits of all certified EHRs. This means some of our QCPR customers would be visited by federal auditors to review how QCPR is working in a live environment. Since QCPR is a highly configurable EHR and CMS allows customers to configure EHRs differently than how developers configured them for the MU testing laboratory, it is unclear what the impacts of such field audits might be.