My Hopes For Stage 3 MU

The ONC must ensure the MU criteria related to interoperability isn’t too vague or broad.

Rumor has it that the proposed rule for Stage 3 of the Meaningful Use (MU) program could be released prior to the HIMSS conference in mid-April. The proposed rule was sent to the Office of Management and Budget (OMB) for review in early January. While the OMB has its own timetable for review, speculation that the rule would be ready for public consumption by HIMSS escalated when a session titled “CMS Meaningful Use Stage 3 Requirements” was recently added to the HIMSS15 agenda.

Regardless of timing, there are several things I’d like to see in Stage 3 MU when the rule is ultimately released. I’ve outlined a few of these wishes in the following paragraphs:

1. A Clear Path To Interoperability — Most industry leaders agree that Stage 3 MU will focus on interoperability between disparate health IT systems. In fact, many believe that Stage 3 will solely address interoperability. The ONC must ensure the MU criteria related to interoperability isn’t too vague or broad. Stage 3 needs to provide a clear outline that shows providers how to achieve this goal. A focus on industry standards must be a focal point.

2. Narrow The Scope — Much of the criticism surrounding MU to date (especially Stage 2) has been the sheer number of objectives eligible providers have had to address in each stage in order to successfully attest for incentive funds. Many providers felt the MU effort to date has lacked focus as a result. Not only was this an administrative and managerial nightmare for providers, but it may have impeded overall progress. In other words, while incremental gains may have been made in a number of areas, the industry actually did little to move the health IT “Triple Aim” needle overall in the process. This needs to change with Stage 3. I hope to see fewer objectives and more focus with the new rule.

3. Measure Outcomes, Not Processes — One way to narrow the scope of MU would be for ONC to start rewarding incentive funds based on outcomes as opposed to following prescribed processes. In the end, who really cares how a provider achieves the end goal as long as they achieve it and maintain it? I would like to see the ONC start measuring outcomes in Stage 3 rather than continuing to force providers to check predefined boxes.

Stage 3 could be the last hurrah for the MU program. The incentive dollars are scheduled to disappear after the new rule takes effect. The ONC needs to ensure it capitalizes on this opportunity to not only drive provider adoption, but also produce some of the measurable results Congress is demanding to see.