Outdated as of May 2021.
This article is outdated. Please find our updated resource that explains the current MACRA / MIPS / Meaningful Use regulations.
Guest post by Zach Watson, marketing operations analyst at TechnologyAdvice.
After much ado, the Centers for Medicare and Medicaid Services (CMS) released the proposal for the final rules of Meaningful Use Stage 3 earlier this month. Unsurprisingly, the healthcare industry has spent the subsequent weeks sifting through the document to get a better understanding of what the government’s end game is for the program.
After the final rules were released, CMS announced there would be a 60-day period for public feedback on the proposal, so calling it the “final rules” is a bit misleading.
Regardless, there are numerous initiatives to prepare for in Stage 3, as well as significant changes to the criteria for Stage 1 and Stage 2.
The Stage 3 rules are a mixed bag for the application of patient portal software — most of the objectives and their accompanying measures seem quite attainable, but one patient engagement measure in particular could prove a significant challenge for providers.
Here’s what you need to know.
Stage 2 Attestation is Much More Manageable
Much of the analysis regarding Stage 3 has focused on streamlining the program. CMS narrowed the core objective list to 10, and the requirements to attest for Stage 2 have been significantly lightened.
In fact, if a provider hasn’t attested for Stage 1 yet, they can automatically begin participating in Meaningful Use at a modified version of Stage 2 this year. This only requires a 90-day attestation period for 2015, though the following years require that providers attest for a full year.
Additionally, the patient engagement requirements for Stage 2 have been radically altered. The much-maligned “View-Download-Transmit” measure requiring five percent of patients to actively engage with their health record has been all but eliminated.
The new rule simply says, “at least one patient during the reporting period” must actively engage with their health information during the reporting period. Similarly, the Stage 2 requirement for secure messaging has essentially been reduced to a yes or no scenario.
All of these changes to Stage 2 indicate that CMS understands the need to move the needle forward in terms of where the majority of providers are in the Meaningful Use program before Stage 3 begins to take full effect in 2017.
It’s intriguing that two of the major changes in the final rule proposal deal with Stage 2 measures that directly relate to patient portal usage. In no uncertain terms, this is a win for eligible providers.
Stage 3 Brings Back Tough Patient Engagement Requirements
The proposed rules for Stage 3 attempt to follow the theme of simplification applied to modify the Stage 2 rules. But just because something is easily understood doesn’t mean that it’s easily performed.
In terms of patient portals and patient engagement, the most important objective for physicians to examine is the Coordination of Care Through Patient Engagement. As the name implies, this objective focuses on patient engagement, which has nearly always been manifested as a view, transmit, or download threshold in the context of Meaningful Use.
Stage 3 is no different, and this objective comes with three accompanying measures, of which eligible professionals must meet two.
Let’s start with most difficult. Though its teeth were pulled for Stage 2, View-Download-Transmit is back for Stage 3, and this time it’s going to take a whopping 25 percent of patients actively engaging with their health information to meet the threshold. However, there’s also the option of using an API to automatically push this information to another platform in order to meet this goal.
Secondly, the Patient Engagement objective requires 35 percent of patients to receive a secure message during the reporting period. In the past, this would mean that patients had to send the message, but CMS has mercifully included messages sent first from a provider in this measure.
Lastly, patient-generated health data or data from a non-clinical setting must be incorporated into the EHR record for more than 15 percent of patients during the reporting period. An API can also be used to meet this measure instead of tasking patients and providers with manually entering the data.
The addition of APIs is very interesting in the proposal by CMS, but the practicality of this approach — at least in the short term — is questionable.
Developing APIs will be out of reach for many smaller practices because they simply don’t have the resources. This puts the onus clearly on vendors, with an advantage going to standalone patient portals that aren’t tethered to a particular EHR.
These platforms likely have a more open architecture and may be in a better position to integrate with multiple EHRs and serve as an all access point for patient records from multiple providers.
Additionally, APIs could significantly reduce the administrative workload of incorporating patient-generated health data — Apple’s HealthKit is a prime example of this technology in action.
The silver lining is that providers can choose two of the three measures in the Patient Engagement objective, skirting the difficult undertaking of driving one out of every four patients to engage with their health records online.
All in all, Stage 3 isn’t overwhelming from a patient portal view, though providers must choose which difficult measure to tackle: View-Download-Transmit, or integrating patient-generated health data.
About the Author: Zach Watson is a marketing operations analyst at TechnologyAdvice. He covers marketing automation, healthcare IT, business intelligence, HR, and other emerging technology. Connect with him on LinkedIn.