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Meaningful Use – Stage 3 Trouble

In 2009 the government rolled out one of its centerpiece healthcare legislations, HITECH, the Health Information Technology for Economic and Clinical Healthcare Act of 2009. It was to be implemented in three stages in multi-year increments, with each stage relying more and more on electronic media.  Branded “meaningful use attestation,” its initial stage was to be implemented between 2009 and 2011, followed by two more stages in a carefully choreographed sequence.

As the CMS (Centers for Medicare and Medicaid Services) continues to release new meaningful use rules and clarifications, the process is bogging down under the weight of these new directives. According to a March 2015 article on Modern Medicine, Linda E. Fishman, senior vice president of public policy and development for the American Hospital Association (AHA) gets right to the heart of the problem.

“The release of (this) rule” (referring to new Stage 3 Meaningful Use rules), “demonstrates that the agency continues to create policies for the future without fixing the problems the program faces today.” Fishman added that “in January, CMS promised to provide much-needed flexibility for the 2015 reporting year, which is almost over. Instead CMS released Stage 3 rules that pile additional requirements onto providers. It is difficult to understand the rush to raise the bar yet again, when only 35% of hospitals and a small fraction of physicians have met the Stage 2 requirements.”

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With time running out to meet the Stage 1 and Stage 2 qualifications, and Stage 3 looming, hospitals and physician’s offices are being forced to prepare for the requirements of Stage 3 for 2017. The entire process is both costly and complicated, and apparently CMS doesn’t expect them to succeed. The same article implies that CMS apparently believes it has set unattainable goals because it expects that physicians, alone, who fail to comply with Stage 3 mandates will have to pay approximately $500 million in Medicare penalties between 2018 and 2020.

CMS further expects that physicians will have to spend $54,000 to upgrade their systems and an additional $10,000 yearly to maintain them. Hospitals face an even greater burden with an initial outlay of five million dollars and a yearly maintenance fee of another one million dollars.

On October 7, 2015, CMS released its Stage 3 – 2015 Certification of Final Rules. Another article on the Modernmedicine.com website outlines some of the many changes to the final rule.

One of the changes impacts the timeline for reporting. There will be a 90 day reporting period for 2015 with a full year reporting for each following year. Another change revised the Patient Electronic Access Messaging Access View, Download, Transmit measures from 5% to “equal to or greater than one patient.” Others consolidated all public health reporting, providing a menu of five choices, two of which must be met. Additional requirements increased the required percentage of compliance for multiple issues.

2018 promises even more specific compliance measures and matrices to gauge progress. Areas under consideration include changes to

  • Protected Patient Health Information
  • Electronic Prescribing (eRx) Clinical Decision Support (CDS)
  • Coordination of Care through Patient Engagement
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    Many healthcare professionals feel that HITECH is in need of repair and not in the form of additional rules and regulations to enforce an already bloated process. What may have started out with the best of intentions – to improve our healthcare system – has evolved to proportions where a concerted effort of government and the healthcare industry is necessary to repair it.

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