Perhaps the most complex proposed objective of Stage 3 is next: Coordination of Care. This proposed objective has multiple parts, and is a consolidation and re-working of some of the more challenging Stage 2 objectives.
As a reminder, the complete Stage 3 proposed rule can be downloaded here.
Coordination of Care through Patient Engagement (Page 105)
- 3 Measures; Must meet any 2
- Patients must “actively engage” with the electronic health record made accessible by the provider. This can be met by patients either:
- Using view-download-transmit (VDT) functionality to interact with the EHR –or–
- Access their health information through the use of an API
- A secure message was sent to the patient (or a message was sent in response to a secure message sent by the patient)
- Patient-generated health data (or data from a non-clinical setting) is incorporated into the EHR
- Thresholds: 25% for measure 1 (view/download/transmit); 35% for measure 2 (secure messaging); 15% for measure 3 (patient-generated data)
- As discussed in our last Stage 3 blog post on “Patient Electronic Access”, this contains the “action” part of the Stage 2 objective of the same name. This “decoupling” of the “View – Download – Transmit” into two Stage 3 metrics seems counter-intuitive to CMS’ goal of administrative simplicity for Stage 3. Nevertheless, providers are encouraged to pay particular attention to how the two Stage 3 objectives, “Patient Electronic Access” and “Coordination of Care” are inter-related.
- Only two of the three measures need to be met to satisfy the objective.
- This is a consolidation of a number of familiar Stage 2 metrics (View-Download-Transmit, Patient Reminders and Secure Electronic Messaging)
- Exclusions are available if there are no office visits during the attestation period for the EP, and for limited broadband availability.
- Another potential use of the “API Option” is available here. Again, APIs are in their infancy with respect to EHRs, and it will be imperative to monitor how use of APIs evolves in future CMS and ONC rulemaking.
- Measure 3 (Incorporate data from a non-clinical setting) might prove to be problematic to implement (and CMS is seeking comment on how this might be achieved).
Fortunately, because a provider only needs to attest to 2 of the 3 measures to meet the overall Coordination of Care objective, providers may be able to ignore incorporation of patient-generated data if it proves to be excessively problematic to implement.
- Paper-based methodologies (permissible for Stage 2) are no longer acceptable.
- Thresholds for measure 1 have increased significantly from Stage 2 (from 5% to 25%). Given that this measure requires an “action” (active engagement) to be taken by patients, the 25% threshold may prove particularly challenging to meet.
- This metric also includes an API (Application Programming Interface) option. We commented quite a bit on APIs in our last post (and we plan on focusing on this topic in future blog posts). This is one of the more vague additions to the MU standards, and it seems that CMS is viewing the API as “the answer” to EHR interoperability.
- Reporting all three measures seems odd, given that only 2 are required in order to achieve MU. The requirement to report all three becomes particularly concerning given CMS’ expressed desire to making MU metrics publicly available via the Physician Compare website (see page 181 in the proposed rule).
So one can envision a scenario where an EP meets the required 2 of 3 measures for Coordination of Care (and meets MU) but all three “reportable” measures make their way to the Physician Compare website (including the one measure that was not met). Would users of the data on Physician Compare be savvy enough to understand the nuances of MU, or could this potentially reflect poorly on the EP?
Hopefully CMS will carefully consider such scenarios and their potential implications prior to making MU performance data public.
Up next is another “old friend” from Stage 2 (repackaged with a new name): Objective 7–Health Information Exchange.
Thanks for reading, and see you next time!