To say that Meaningful Use has been controversial and difficult for medical practices to navigate would be vastly understating the situation. In early November, the American Medical Association (AMA) and 111 medical societies sent a letter to Congress expressing dismay over CMS’s decision to move ahead with Stage 3 of Meaningful Use, given the “widespread failure” of Stage 2.
The associations cite the fact that only 12% of physicians have been able to successfully participate in Stage 2, despite more than 80% of physicians having ERHs in their practice. They write that CMS has “continued to layer requirement upon requirement, usually without any real understanding of the way healthcare is delivered at the exam room level.”
Given the difficulties thus far and the low number of physicians participating in Stage 2, the level of frustration expressed by healthcare leaders over CMS’s release of the Final Rules for Stage 3 Meaningful Use was not surprising.“Many of the requirements for Stage 2 proved unattainable,” said Dr. Kim Williams, Sr., president of the American College of Cardiology. “Large numbers of providers either haven’t met them or, after trying and failing, have given up. That is why it is vital that CMS consider participation data from the current stage to see what is working and what isn’t before outlining an upcoming stage. We cannot establish a long-term health care program that does not take into account what we can feasibly attain in the short-term, transitional period.”
Several associations, including AMA and HIMSS North America, called for a delay in the implementation of Stage 3. “HIMSS encourages reasonable Meaningful Use-related rules and timelines, as these enable providers to continue their participation in the program, thus supporting a positively transformed health system,” said HIMSS Executive Vice President Carla Smith.
Usability has been, and continues to be, a major complicating factor in EHR adoption and Meaningful Use compliance, particularly for small and medium-sized medical practices. AMA and MedStar Health’s National Center for Human Factors conducted a study of 50 EHR vendors and determined that the Office of the National Coordinator for Health IT for the Meaningful Use program certified many vendors products that did not follow basic federal certification requirements around usability.
“Many EHRs have poor usability, leading to user frustration and safety risks,” write the authors. “Usability is the extent to which the technology helps users achieve their goals in a satisfying, effective, and efficient manner within the constraints and complexities of their work environment.”
Raj Ratwani, the center’s scientific director and lead study author, and his team have developed a new framework that examines user-centered design (UCD) compliance based on a 15-point scale. “Alignment with best practices for UCD and testing is a starting point that regulators and industry should meet and exceed,” said Ratwani.
AMA President Steven Stack agrees, saying “Our goal is to shine light on the low-bar of the certification process and how EHRs are designed and user-tested in order to drive improvements that respond to the urgent physician need for better designed EHR systems.”
As important as usability is, it takes a back seat to interoperability when it comes to attaining Stages 2 and 3. In Stage 2, 33% of the objectives require interoperability; in Stage 3, that figure jumps to 60%. And there’s not much time to get there. Although Stage 3 is optional for providers in 2017, it is mandatory in 2018.
Details about Stage 2 are available in this guide from CMS. In simplified form, here are the requirements pertaining to interoperability.
- Use CPOE for medication, lab, and radiology orders. More than 60% of medication, 30% of laboratory, and 30% of radiology orders creating during the reporting period must be recorded using CPOE.
- Generate and transmit permissible prescriptions electronically. More than 50% of prescriptions must be compared to at least one drug formulary and transmitted electronically using certified EHR technology.
- Provide patients the ability to view online, download, and transmit their health information.More than 50% of patients must be provided with online access to their health information within four business days of the information becoming available to the provider. At least one patient seen by the provider during the reporting period must view, download, or transmit to a third party their health information (as modified by the Stage 3 Final Rule).
- Protect electronic health information created or maintained by certified EHR technology. The provider must conduct a security risk analysis in accordance with CMS requirements.
- Submit electronic data to immunization registries. This requires successful ongoing submission for the entire reporting period.
- Use secure electronic messaging to communicate with patients on relevant health information. A secure message must be sent by more than 5% of patients seen by the provider during the reporting period.
On October 6, CMS released a 752-page document outlining Stage 3 and modifying Stage 2. EHR vendors are still parsing the document to determine the steps they must take to bring their products into compliance.
One thing is clear, however. Application program interfaces (APIs) will be required, and that presents a problem for many older systems. In Stage 2, patients had to be able to view, download, or transmit their information to a third party using a patient portal. In Stage 3, patients must be able to do this through an API (software-to-software interface) to allow greater flexibility than can be provided by a vendor-specific portal.
Head for the cloud
With usability issues continuing to plague EHRs and interoperability a critical factor in attaining Stage 2 and Stage 3, what is the answer for small and medium-sized practices? Sophisticated cloud-based systems provide both a high degree of usability and the means to meet both Stage 2 and Stage 3 requirements:
- Highly customizable. Cloud-based systems are designed to let practices customize a variety of items within the EHR to better suit the way their clinicians conduct patient visits.
- Built-in patient access. Cloud-based EHRs are designed to allow patients online access to their medical records, lab results, and more.
- Open architecture. Cloud-based systems are, by their nature, designed to exchange data with other systems. Rather than having to add these capabilities, as with closed legacy systems, they are part of the software’s fundamental structure.
Finally, cloud-based systems solve another problem facing independent practices. With breaches being reported weekly, healthcare data concerns are understandably on the rise, and cloud-based systems have built-in tools to ensure complete data security and HIPAA compliance.
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