A not-so-new phenomenon on the internet is the "reaction video." Go to youtube.com and look up "trailer reaction" to enter the world of millennials trying to gain fame from freaking out on a web cam over a movie preview of the latest installment of a Hollywood franchise. Granted I am rather excited about some upcoming movies too, but not enough to record my reaction because, my cynicism is in direct correlation with my age.
In Healthcare IT (HIT) the most highly anticipated coming attraction of the next few years is Meaningful Use stage 3 (MU), and we now have our first glimpse into what the final installment will be in the form of a proposed rule. Not only was this proposal dropped before the HIT super-conference, HIMSS, but it comes at a time when the program is in an especially advanced state of confusion. I assume this was a strategic maneuver from CMS to put their spin on the stage 2 rule change and get ahead of the inevitable criticisms of stage 3. While the nerd in me reacted with child-like excitement when Chewbacca let out his trademark roar at the end of the new Star Wars Episode 7 trailer, I knew my reaction would be far, far away from pleased as I dove in to the 300 pages that comprise this proposed final MU stage.
Admittedly, it took me less than 4 pages to glaze over and nearly pass out from boredom, because these proposals are complex and contain obscene amounts of legal language. At a high level view the proposal contains definitions of acronyms (over three pages), the standard timetables of participation, overarching objectives of the program, and other high level points that are not applicable to the clinical workflows that will need to be developed in the next few years.
Yet, after 220 pages of rambling legal jargon will take the reader to the main point of the proposal; the definition of objectives and measures that are displayed in, the reader friendly, Table 6: Burden Estimates. The estimate is what CMS has figured it will take an eligible provider or hospital to complete each objective. The estimate is 6 hours 52 minutes. I am guessing that CMS does not factor in the administrative compliance checks, stakeholder meetings, workflow adjustments, and the actual attestation time into this estimate. Last time I assisted in attestations for a 6 doctor practice it took about 45 minutes per doctor, a pretty decent percentage of that estimate. I am not sure all of the factors they put into this equation, so maybe they are right, but my educated guess is it may be much higher.
Enough with the semantics and math and back to the main point. I want to highlight some of the elevated requirements to watch out for moving into 2017 and beyond.
1. The thresholds for CPOE and ERX have gone up to 80%. If you aren't doing this every applicable time already, you better start getting in the habit now.
2. View, Download and Transmit goes up to 25% and Secure Messaging goes to 35%. Also a new measure regarding 15% of patients have their "non-clinical setting data" incorporated into the EHR. Since stage 2 is already rolling back requirements for patient engagement, who knows if these stiffer measures will stand?
3. While there was no exclusion listed, it appears CMS is going to make EPs engage with some form of registry in stage 3. Many specialists who do not submit to syndromatic or immunization registry may not have that handy exclusion to rely on in 2017. Definitely keep your eye on this one.
While any good trailer makes you excited to see the movie, this proposed rule does its job, as it gives us an idea of the hurdles yet to come. As long as CMS does not decide to change the rules mid-game, I see all of this as achievable with the right mentality and a properly executed plan.