A popular adage dictates that if something isn’t broken, you shouldn’t try to fix it. Chances are, no one has ever said that about the meaningful use program. On March 20, 2015, CMS released the proposed rule for Stage 3 of meaningful use. Now in its fifth year, the well-intentioned but controversial program is often criticized for being overly complicated, burdensome, and reliant on EHR technology not yet in production. As we continue to sift through the new rule’s 300+ pages, two key questions come to mind:
- Will this final stage of meaningful use make it easier for providers to participate?
- Does Stage 3 get closer to CMS’s original goal of encouraging providers to use technology to improve outcomes?
The answer to the first question is yes. And no.
At first glance, Stage 3 seems to dramatically simplify the program. Reporting periods and measure sets are standardized for all participants. The number of objectives is cut in half. Updated reporting requirements allow flexibility in meeting measure thresholds.
But a closer look shows that these benefits are overshadowed by changes in the program that do little to address some of the challenges providers are struggling with. For example, as in Stage 2, patient engagement is measured by patient actions. This has proved frustrating for providers because, while they can encourage online patient engagement, they cannot compel it. The Stage 3 proposed rule calls for 25% of patients to view, download, or transmit their health information – a substantial jump from the current requirement of 5%. Even if the reporting requirements for this measure are modified for Stages 1 and 2, as outlined in the proposed rule CMS released today, and those changes are applied in some way to Stage 3, the fundamental issue with this measure persists – providers are evaluated on their patients’ behavior, not their own.1
Also, providers will be required to make visit information electronically available to patients within 24 hours, as opposed to 3 or 4 days. This tight timeline may call for changes in clinical processes that are difficult for physicians to implement and maintain.
The second question may have a clearer answer – but not necessarily a better one. While Stage 3 certainly endeavors to improve the structure of the meaningful use program, its focus remains on technology instead of outcomes.
Truly improving outcomes begins with increasing the number of patients who are healthy and engaged in their own care. The proposed measure set does not directly support this because it lacks a requirement for providers to demonstrate improvements in care. While it will motivate providers to use technology to improve care, Stage 3 establishes no baseline for actually measuring clinical outcomes.
Establishing such a standard – for example, by setting thresholds for numerators in reported clinical quality measures – would support CMS’s original goal for the final stage of meaningful use by placing the provision of improved care at the forefront of the program. But for now, a gap remains between technology and quality.
Meaningful use is broken, that much is clear. What’s not clear is whether the proposed Stage 3 changes will be enough to fix it.
This post was written by Andrea C. Pettiford and Jake F. Fochetta.
1 The proposed change for the earlier-stage patient electronic access measure lowers the threshold from 5% to “equal to or greater than 1%.”