Impact Insights

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

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 thresholds…

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!