The Good, the Bad and the Ugly of Meaningful Use Stage 3: Objective 4 – CPOE

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Jun 23, 2015

The Good, the Bad and the Ugly of Meaningful Use Stage 3: Objective 4 – CPOE

Written by Dan Golder

Category: Regulatory

Today we’ll address the fourth of our proposed Stage 3 objectives, “CPOE” (Computerized Provider/Physician Order Entry). As a reminder, the complete Stage 3 proposed rule can be downloaded here.

CPOE (Page 81)

Objective Specifics:

  • 3 Measures; All three must be met
    • Medication Orders
    • Laboratory Orders
    • Diagnostic Imaging Orders
  • Thresholds: 80% Med Orders; 60% Lab Orders; 60% Imaging Orders

This objective includes additional metrics (and higher thresholds) when compared to the similar Stage 2 metric (which did not include diagnostic imaging orders).

Initial Thoughts:

  • CMS defers to the provider’s discretion to determine which staff members are appropriate to enter the three order types. They do note that staff entering orders must have the requisite clinical training and knowledge required, and that providers should ensure they (and their staff) are complying with all appropriate Federal and State statutes when determining who is qualified to enter orders.
  • However, CMS further elaborates by stating that a layperson is not qualified to perform order entry, and that if the individual entering the order is not licensed, that they must receive direct supervision by a licensed professional.

The Good:

  • Once again, this should be a very familiar and “comfortable” metric for all EPs and EHs.
  • Exclusions are still available for EPs ordering <100 orders of each type during the reporting period.
  • “Protocol” or “Standing” orders may be excluded from this objective (this is an option for the provider), although this may not be a “blanket” exclusion for patients presenting with a specific diagnosis or symptom.

The Bad:

  • There are 3 measures, each with different thresholds, and all three must be met in order to satisfy the objective:
    • Medication Orders (80% threshold)
    • Laboratory Orders (60% threshold)
    • Diagnostic Imaging Orders (60% threshold)
  • Paper orders do not count for CPOE, even if they are transferred to CEHRT at a later time.
  • Thresholds have been increased from those of Stage 2

The Ugly:

  • Similar to our concerns with how CMS has calculated thresholds for ePrescribing, CMS has relied on reported results for Stage 2 in order to set new thresholds for this Stage 3 Objective. Given that these results only sample those 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?

Objective 5–Patient Electronic Access to Health Information.

Thanks for reading, and see you next time!