Pros and cons: What 3 IT experts have to say about the MU Stage 3 proposal

The HHS touts the proposed rules for Stage 3 of Meaningful Use as adding flexibility and simplicity in the effort to implement interoperability and increase the focus on patient outcomes—but the proposal isn't without its pros and cons. 

One of the most important aspects of the rules may be the announcement in itself; David Muntz, CIO at the patient engagement software company GetWellNetwork and former principal deputy director of the ONC notes it was released in advance of the largest meeting of HIT professionals—HIMSS in Chicago in April— the opportunity for more meaningful conversation. "Hopefully, the discussions will yield better criticism to help shape the final rules," he says.

Several experts spoke with Healthcare Dive to share their perspectives on the proposed rules' specific advantages and drawbacks.

Erik Dahl, IT Audit Director for CHAN Healthcare, a subsidiary of Crowe Horwath

Dahl audits IT systems in hospitals, health systems and physician practices, including doing comprehensive Meaningful Use audits.

He suggests the positives include the flexibility in 2017 for organizations to attest to one of the earlier stages, along with allowing flexibility on either the 2014 or 2015 code. "That gives more time for providers, so that's always a positive," he says.

"I think the continued alignment for clinical quality measures with the PQRS and IQR Programs is definitely positive as well, and going to a 365 day reporting period will be good," he adds.

With regards to the patient engagement measure, Dahl believes providers will appreciate that the secure messaging component shifts focus to provider-initiated messages vs. messages that a patient puts in. However, Dahl also believes that the percentage increase required on patient engagement will be one of the biggest challenges in these proposed rules.

"Summary care is the other percentage-based increase of concern," he says. "Many providers are still struggling with this for their Stage 2 implementation and actually getting the interoperability to work… Will the technology support meeting that measure all the way up to 50%?"

Under the new rules, 80% of patients must be able to access their records either through either the View/Download/Transmit function or through an ONC-certified API. Another concern in Dahl's professional circle is that while the API piece sounds positive, there may be some challenges to the technology for it and for accurately reporting on it. 

"That increase is probably the topic that will get the most feedback," Dahl said.

His greatest concern: that some of the percentage increases are based on the current Stage 2 attestation data. "Many of the providers that attested to Stage 2 were early adopters, and were probably ahead of a few of the measures like summary care and patient engagement," Dahl says. "I'm not positive that basing off the initial Stage 2 attestations is going to be fair for some providers; I don't know if it's going to be reflective of the population."

Shaun Conrad, manager in Americas Health Care Advisory practice at EY

Conrad, a nationally known Meaningful Use expert through EY, sees similar pros and cons to ncreasing patient engagement requirements. 

Conrad sees it as a positive based on the fact that increased engagement is shown to increase the quality of outcomes, can potentially reduce costs and provides the opportunity to increase communication.

However, he notes, "The third measure of patient engagement requires collecting patient-generated data from 15% of unique patients. This will be difficult and calls into question the accuracy of such data. Should the provider base clinical decisions on patient entered data that is incorporated into the EHR?"

Conrad is also hearing concerns about the increased threshold for patient engagement.

"Providers are acutely aware of the difficulties of requirements to make discharge information available within 24 hours of discharge,: Conrad said. "Also raising the threshold to 25% from 5% for requiring the patient to view, download, or transmit their health information could be a significant issue. The latter represents a significant increase when the majority of the industry is struggling to surpass the current 5% threshold."

He suggests that since this requirement can only be met through patient action, efforts to meet this threshold will require cultural and organizational change, and a new patient engagement strategy.

Another pro, in Conrad's view, is the proposed rules regarding Health Information Exchange (HIE). "The increase in the thresholds may be a cause for concern but will ultimately drive the industry toward better communication and outcomes, lower costs and an increase in quality."

Conrad's next concern: That the incorporation and reconciliation of the transitions of care in the certified EHR will create a need for manual reconciliation, impacting clinical work flow.

"There are still fears about the vendors being ready to support the new technology requirements and the time frame of the certification process," he says. "The fact that CMS is publicly saying it is looking to address this is being well received. A plan for flexibility for hardships, however, will be important to not slow down the progression of providers moving to the new 2015 certified EHR technology." He suggests this would address the issue of an "all-or-nothing approach" in the industry which causes further delays.

David Muntz, CIO at GetWellNetwork, former ONC principal deputy director

Muntz, like the others, agrees there is still concern being expressed by those who are struggling with Stage 1 and Stage 2. "Hurried implementations with what some see as stretch goals can be disheartening," he notes.

Here are Muntz's top considerations:

  • The limit on adding new elements is a positive, though some of the thresholds that need to be met will be a concern to many, particularly those that require a provider to affect behaviors in the patients. 
  • Standardizing quality measures and adjusting the reporting period are good moves, but the possibility of requiring all vendors to have a complete set could delay release dates, negatively affecting the providers who must make the upgrades.
  • The encouragement to add APIs to encourage data exchange is a positive. More thought, however, needs to be given to the areas where open APIs can prove beneficial. CCDA or the new Common Clinical Data Set is a good start, but there are so many other integration opportunities that can help purchasers and the patients, families and providers they represent.
  • There is an emphasis on patient and family engagement, and while the features and functions required are a good start, many fall short of real-time interactions. Patients and families could be far more activated if they received the data as it was generated. The question in the NPRM on the use of real-time formulary is a good way to stimulate discussion about whether real-time capabilities should be utilized elsewhere.
  • Secure messaging is a great idea, but the threshold for usage is really based on patient preference and may be a bit aggressive.
  • Patient Generated Data is an important topic to address and deserves attention. The "who, how, what, and when" questions will need to be appropriately answered. This topic was a challenge in the paper-based world and the digital world answer is not any easier.
  • The greatest disappointment was the continued use of specific features and functions without an alternative to deem features and functions based on a combination of appropriate process and outcome measures. A deeming approach would have given the users a great deal of latitude in how to implement features and functions that would have produced favorable outcomes.

As Muntz concludes, it will be important for stakeholders to share their feedback on these proposed rules.

"I hope that everyone who reads the regulations will respond with what they like as well as what they don't like," he says. "Only with the broadest possible input can we get what's best for the patients, families, providers and payers."

Filed Under: Health IT Policy & Regulation
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