The Centers for Medicare & Medicaid Services (CMS) recently released the latest rules for Meaningful Use Stage 3 (MU3). In these updated rules, CMS restructured the program to open MU3 to different solution vendors. The updated rules also allow the program to include providers such as skilled nursing facilities, inpatient rehabilitation facilities and home health agencies.
Although CMS made this change by expanding the definition of certified solutions beyond electronic health records (EHRs), structural challenges in the program will continue to impede participation by post-acute care settings.
This latest rule also defines transitions of care and includes a number of key elements that directly impact transitions of care. For hospitals, the definition includes all inpatient discharges and emergency room admissions, where follow-up care is ordered by an authorized provider, regardless of how much information is available to the receiving provider.
The Summary of Care, however, is still sent and required, because it is tailored to the needs of the clinicians at the next level of care, and accessing the EHR does not support the workflow of those clinicians. This last point about workflow addresses challenges observed in the market around portal access to patient records that do not support the critical workflow needs of the receiving provider.
What to expect for the rest of “Modified” Stage 2
Participating hospitals will now attest in 2015 and 2016 under the “modified” rules for Stage 2. In the modified version, there are a few changes for the transitions of care measure (Core Measure 12). The first change is that the attestation timing period shifted from the CMS fiscal year to the calendar year starting in 2016, and the second is the removal of Measure 1, the Summary of Care Record for 50 percent of all transitions. Because most hospitals are compliant with that measure reporting on it is no longer unnecessary.
Measure 2, the electronic transmission of the summary of care document, will remain at greater than 10 percent for the remainder of Stage 2.
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.
Moving to Stage 3
So where does that leave MU3? For Objective 7: Health Information Exchange (previously Core Measure 12: Transitions of Care), there are now three measures:
- Measure 1 (Previously Measure 2): With the latest rules, CMS requires participants to share a Continuity of Care Document (CCDs) for more than 50 percent of all care transitions, and add measures to support the use of CCDs. Under Objective 7, CMS has added two new measures, including a “clinical information reconciliation process” (modeled after medications reconciliation) for new patients received by the hospital.
- Measure 2: Core information (problems, allergies, medications) is reviewed for more than 80 percent of all transitions or referrals received by the hospital.
- Measure 3: 40 percent of new patient transitions have the CCD information incorporated into the EHR.
Hospitals only need to meet two of the three measures listed above in order to achieve Meaningful Use.
The new CCDA R. 2.1, which is a new version of the CCD in MU3, adds a number of key data elements intended to address care coordination needs, including immunizations, assessment/plan of treatment, patient goals, health concerns and identifiers for implantable devices.
What Can You Do?
Hospitals will have the ability to “try” Stage 3 in 2017 (for 90 days) before attesting for a full year in 2018. Hospitals should work with vendors, care management teams and partners to target 2017 for MU3 as it will provide time to work out issues.
Hospitals currently using manual processes for sending CCDs to post-acute providers should look at more automated processes for care transitions.
Think through the process of receiving and incorporating CCDs from providers when a new patient is sent to the hospital. Who will conduct the reconciliation and insure that information is incorporated into the EHR? This should be considered for both inpatients and ED patients.
With proper preparations, hospitals can ensure the transition to MU3 is as streamlined as possible.
