On May 29, the comment period for Stage 3 Meaningful Use will end leaving healthcare providers with a single final set of objectives and measures for Meaningful Use. To their credit, the Centers for Medicare and Medicaid (CMS) has tried to simplify the rules by combining measures and attestation periods for all participants, meaning eligible hospitals (EHs) and critical access hospitals (CAHs) would no longer have to attest under different rules than eligible physicians (EPs). In addition to this change, there are also modifications to the requirements for transitions of care—here is a brief overview of the amendments:
Re-defined: Transitions of Care
The Centers for Medicare and Medicaid (CMS) have added new points to the definition of the term “transition of care.” A transition of care is still defined as the “movement of a patient from one care setting to another with the expectation of follow-up care.” However, referrals will now also be included under the rule. Referrals happen when a patient sees a provider other than their normal provider, but still receives care from both the normal provider and the additional provider. As long as this other provider exists as a separate billing entity, CMS will consider the referral a transition of care.
Clarification: Summary of Care
To ensure a new provider has access to information from a patients’ previous care setting, CMS requires a transition summary statement be sent to the follow-up care provider. The rationale for this is that the information contained in the summary of care document benefits clinicians working in the next level of care because accessing a patient’s EMR does not support the workflow of these clinicians.
Stage 3: New Requirements
Here’s a look at the proposed changes to the transition of care requirement for Stage 3:
A Deep-dive Into Specialty Pharma
A specialty drug is a class of prescription medications used to treat complex, chronic or rare medical conditions. Although this classification was originally intended to define the treatment of rare, also termed “orphan” diseases, affecting fewer than 200,000 people in the US, more recently, specialty drugs have emerged as the cornerstone of treatment for chronic and complex diseases such as cancer, autoimmune conditions, diabetes, hepatitis C, and HIV/AIDS.
- Participants no longer need to provide a paper-based Summary of Care document for 50% of patient transitions. CMS still recommends offering this service to patients, but it will no longer count towards attestation.
- 50% of patients must receive electronic transfers for Summary of Care records, versus the 10% required previously.
CMS has also added two requirements:
- Providers must incorporate new patients’ electronic records into the provider’s certified electronic health record technology (CEHRT) for 40% of inbound transitions/referrals.
- For more than 80% of transitions of care, the provider must conduct a “clinical information reconciliation” that includes a list of the patients’ medications, allergies and current diagnoses.
Expanded: ONC Technical Requirements
The transitions of care requirements for the proposed rule have increased in difficulty. The ONC is seeking to expand the technical requirements as well, including the expansion of the consolidated clinical document architecture (CCDA) to CCDA R2. The new CCDA includes elements important to post-acute care providers, including:
- Care plan
- Referral notes
- Transfer summary
- Mental status
- Physical findings
- Finding of skin
- Wound observation
Combining measures and time periods in the new rule will streamline Meaningful Use programs for participants. However, the industry is still struggling with the care transition measures set in Stage 2.
Increasing transitions of care requirements in Stage 3 seems very optimistic, even with a 2018 deadline. Furthermore, post-acute care providers are still omitted from meaningful use, despite the ONC’s updated CCDA rules that aim to provide better support for post-acute care providers.
Are the proposals feasible? Only time will tell. Please let us know your thoughts in the comments!
