Today we’ll address the third of the proposed Stage 3 objectives, “Clinical Decision Support”. As a reminder, the complete Stage 3 proposed rule can be downloaded here.
Clinical Decision Support (Page 75)
- 2 Measures; Both must be met
- Implement five clinical decision support interventions
- Enable drug-drug and drug-allergy interaction checks for the entire EHR reporting period.
- Attestation Only
This objective essentially represents a consolidation of similar measures from Stage 2.
- This seems like a strange metric—given that CMS had defined no fewer than nine different ways (beyond traditional “pop up” warnings) to meet this attestation measure, it would seem almost impossible to not be able to achieve this metric so long as an EHR has been implemented.
- More curious still is that CMS has mentioned its desire to simplify MU, and is deleting other “topped out” metrics from Stages 1 and 2, it seems odd that they have not only kept this metric, but have rewritten the specifications so that it is virtually impossible to not be able to attest to this measure–essentially creating a measure that is “topped out” almost by definition.
- Most EPs are familiar and somewhat comfortable with Clinical Decision Support rules and drug-drug / drug-allergy checks.
- CMS notes that CDS interventions can use other methodologies besides “pop-ups” including alerts and reminders, information displays or links, incorporation of information from online resources (“InfoButtons”); clinical guidelines, condition-specific order sets, focused patient data reports; documentation templates; diagnostic support; and contextually relevant reference information.
- Given the amount of alternatives and because this is an attestation only measure, this should be an easy metric for virtually all EPs and EHs to meet.
- The CDS interventions have to be somehow linked to a “relevant point in patient care when the intervention can influence clinical decision making” but CMS does not define how it may choose to interpret what constitutes a “relevant point” in patient care.
- While there is an exclusion for drug-drug / drug-allergy checks (measure 2) for EPs writing <100 prescriptions, there is no exclusion for CDS interventions (measure 1).
- As this is an “Attestation Only” measure, there is an audit risk. Documentation clearly detailing how the CDS interventions were configured and enabled in the EHR will be critical to maintain, along with a way to validate that these were in place for the entire reporting period.
- CMS notes their preference for providers choosing “outcomes measures” over “process measures” but does not add any additional metrics or thresholds to support this opinion, nor how it might be examined during an audit.
CPOE—another “hold over” from Stage 2 that will be familiar to the MU community.
Thanks for reading, and see you next time!