The Health IT Policy Committee received an update from its Meaningful Use Workgroup with preliminary recommendations on what should be included in Meaningful Use Stage 3. The Committee’s plan was to discuss the draft recommendations on February 4, but wait until the March 2014 meeting to approve the Stage 3 recommendations that would be formally submitted by the full Committee to Office of the National Coordinator for Health IT (ONC) and the Centers for Medicare and Medicaid Services (CMS.) The draft recommendations from the Workgroup are available here.
The Committee believes that this plan allows the Department of Health and Human Services (HHS) to keep to the schedule that they published late in 2013, where the Stage 3 Notice of Proposed Rulemaking would be released in the fall of 2014, and the final rule would be made public in the first half of 2015, with an effective date for Stage 3 of 2017.
The Workgroup emphasized that they have been working hard to develop these recommendations and discussed how they have conducted a total of 112 workgroup and subgroup calls deliberating Stage 3.
The principles that the Workgroup used to guide the development of its Meaningful Use recommendations include how they: support new models of care (e.g., team‐based, outcomes‐oriented, population management); address national health priorities; have broad applicability to provider specialties, patient health needs, and regions of the country (since MU is a floor); address key gaps in EHR functionality that the market will not drive alone, but are essential for all providers; and, they are not “topped out” or not already driven by market forces.
Clinical decision support (CDS) was an area emphasized by the Workgroup for Stage 3 given that most of the evidence for improving outcomes associated with EHRs has been derived from CDS. The Workgroup also wants to emphasize patient engagement in Stage 3 since they see it as an inadequately addressed opportunity. Other emphasis areas include care coordination and population management as both of these practices are required for advanced care models.
One of the specific issues that the Committee discussed was the recommendation that eligible hospitals (EHs) and eligible professionals (EPs) provide patients with the ability to view online, download, and transmit (VDT) their health information within 24 hours if generated during the course of a visit. Some Committee members thought that the 24-hour time limit was too stringent given that Stage 2 requirement is set at 4 days.
The Stage 3 recommendations also include several places where the Workgroup wanted the future certification criteria to allow certified EHRs to perform additional functions that may or not be used by the provider but should nevertheless be enabled in the EHR. For example, under the proposed electronic medication administration record (eMAR) measure, the recommendation states that a certified EHR provide “the ability to generate and report on discrepancies between what was ordered and what/when/how the medication was actually administered to use for quality improvement.” Some Committee members argued that these functions would be tough for developers to create and may never be used. Others pressed the point that all these functions need to be included in the next iteration of EHRs because they will be required eventually as providers move to new care models.
In addition, the Committee continued the discussion from past meetings on the idea of “deeming” in EHRs and the desire to shift from specifying EHR functional objectives to “deeming” partial fulfillment of meaningful use incentive qualifications by achieving good outcomes. Although potential elements of deeming framework were discussed, some challenges to deeming were also identified including the difficulties that would be encountered before outcomes‐oriented electronic clinical quality measures are available.
