By Pamela Lewis Dolan

Despite Stage 3 of the meaningful use incentive program being delayed until 2017, rule-making for the program is under way. And the Meaningful Use Workgroup of the Health IT Policy Committee, which advises federal officials on the program, recently released its first set of draft recommendations.

The first draft of recommendations had a definite focus on patient engagement, coordinating care and measuring outcomes. It also included seven new objectives and several carry-over objectives from Stage 2.

“The leap from Stage 1 to Stage 2 was a shock to the industry and physicians,” said Dr. Robert Hitchcock, a Dallas-based emergency physician.

“I think if Stage 3 is implemented the way the Health IT Policy Committee is proposing it, at least from a conceptual level, will be exponentially more difficult on the healthcare industry than Stage 1 to Stage 2 was. It’s a massive leap,” said Hitchcock, who is also the CMIO of T-System, a health IT vendor.

The seven proposed new objectives include:

1. Order and referral tracking by eligible professionals. This would require that the EHR be capable of following orders so that results can be managed. It also requires EHRs be capable of reporting the results of a consult request to the ordering physician.

2. Recording of unique device identifier for all implantable devices. Physicians would have to record the FDA Unique Device Identifier each time a patient has a device implanted.

3. Medication adherence. This is a new EHR certification requirement that would ensure systems are capable of accessing prescription fill information from the pharmacy benefit manager and be able to access the prescription drug monitoring database in a streamlined way.

4. Amendment capability. This would require all certified EHRs to allow patients to easily request an amendment or correction to their medical records.

5. Patient-generated health data. This would allow the eligible provider or hospital to receive patient-generated data in a structured way.

6. Notification of significant healthcare events. This would require the ability to send everyone on a patient’s care team a notice of a significant health event, such as arrival at an emergency department, hospital admission, hospital discharge or death.

7. Case reports. This would require that certified EHRs have the ability to alert system users when they have a case that meets the criteria for reporting to agencies such as the Centers for Disease Control and Prevention or the Council of State and Territorial Epidemiologists. The system would then prepare the report for submission.

Some of the areas Hitchcock thinks will be among the most challenging in Stage 3 include interoperability with external touch points, such as reporting to multiple registries and the reporting of clinical quality measures. He said preparing for Stage 3 will not only be a challenge for vendors, but a massive administrative burden for physicians.

The first draft of proposed recommendations for the workgroup provides a hint at the direction the Health IT Policy Committee will go with Stage 3, but it’s unlikely the final rules will closely resemble the first draft proposal, said Jason Fortin, senior advisor with Impact Advisors, a Naperville, Ill.-based healthcare information consulting firm.

The workgroup has met since the first draft was published and has already indicated several of the proposed objectives in the initial draft will not make it into the final recommendations. The workgroup plans to present its final recommendations to the full Health IT Policy Committee on March 11. The Health IT Policy Committee will then send the final recommendations to the Centers for Medicare and Medicaid Services, which will likely have a proposed rule in the fall.

What happens during Stage 2 of the program will have a lot of influence over what is included in the final rules, Fortin said. Many of the eligible providers who will be attesting to Stage 2 will likely wait until later in the year to do so, which means CMS won’t issue final rules until they have received feedback from them.

“CMS needs that experience to really inform Stage 3,” Fortin said.

Two areas CMS will likely be watching in Stage 2 are those surrounding patient engagement and transitions of care, according to Fortin. These are the areas that are proving to be the most challenging for providers.

The workgroup is encouraging stakeholders to offer feedback. Hitchcock said it’s important for physicians to be involved with this process.

“Physicians, either individually or through their professional societies, need to read the proposed rules and respond to them,” Hitchcock said. “And really honestly open up to [the Office of the National Coordinator] about where some of the challenges are going to be and what the impact is going to be either administratively or financially.”



abeo Management Corporation (abeo) serves as a leading source of revenue cycle management and practice management with a specialization in anesthesia. The company leverages its people, processes, and software to serve independent practices, surgery centers, hospitals and healthcare systems with a scope of services that include billing, coding, transcription, practice management, and business consulting.

Join Our Newsletter