The Good, the Bad and the Ugly of Meaningful Use Stage 3: Objective 2 – ePrescribing

Doctor with RX prescription
May 20, 2015

The Good, the Bad and the Ugly of Meaningful Use Stage 3: Objective 2 – ePrescribing

Written by Dan Golder

Category: Regulatory

Today we’ll address the second of the proposed Stage 3 objectives, “ePrescribing”. As a reminder, the Stage 3 proposed rule can be downloaded here.

ePrescribing (Page 67)

Objective Specifics:

  • 1 EP Measure; 1 EH/CAH Measure
    • Prescriptions written by the EP (or hospital discharge medication orders for EHs) must be queried for a drug formulary and transmitted electronically using CEHRT.
  • Thresholds: 80% EP; 25% EH

This objective is essentially a continuation of the Stage 2 ePrescribing measure, only with higher thresholds (and a few other minor changes).

Initial Thoughts:

  • Controlled substances (EPCS) can now be included, but only if allowed by your state of practice.
  • Over the Counter (OTC) meds continue to be excluded.
  • Meds must be queried for a drug formulary, and electronically transmitted using CEHRT.
  • Exclusions are still included for this objective for low volume providers (<100 prescriptions) or those with no pharmacies within 10 miles that accept electronic prescriptions.

The Good:

  • Most organizations have already implemented ePrescribing, and it is one of the easier measures to meet, especially given the robust infrastructure from SureScripts already in place.

The Bad:

  • The threshold is increased (significantly) over the Stage 2 threshold, and ePrescribing is now mandatory for EHs (as well as for EPs)–it was optional for EHs in Stage 2.
  • The 80% threshold may be difficult for some EPs to meet.

The Ugly:

  • CMS has taken previous attestation rates for Stage 1 and Stage 2 as a way to gauge EP performance, and has used this as a way to set proposed Stage 3 thresholdsu2026

However, these results may be artificially inflated, as EPs who were unable to meet the existing S1/S2 thresholds did not report (i.e. did not attest for MU), and were therefore excluded from CMS’ statistics. Consequently, an 80% threshold as in this example may prove difficult for some providers to achieve.

Unfortunately CMS relies on similar reported results for Stage 2 in order to set new proposed thresholds throughout Stage 3. Given that these results only sample those EPs who have attested, using Stage 2 results may not be an appropriate harbinger for Stage 3 performance, and may result in thresholds that are set inappropriately high for Stage 3.

What’s next?

Clinical Decision Support-an objective that is interesting as it demonstrates some of the “consolidation” concepts that CMS has advocated with Stage 3.

Thanks for reading, and see you next time!