In public comments submitted to CMS, many industry stakeholders were highly critical of the proposed meaningful use Stage 3 requirements. The College of Healthcare Information Management Executives (CHIME) characterized the Stage 3 proposal as “unworkable,” expressing doubts that “many providers could participate in 2018 successfully” under the currently proposed rules. The American Hospital Association urged CMS not to finalize the Stage 3 requirements at all right now, and instead “evaluate the experience in Stage 2 while accelerating the availability of mature standards and the infrastructure needed for efficient and effective health information exchange.” Under the rule proposed in March, all hospitals and EPs would be responsible for the new (and significantly more difficult) Stage 3 requirements no later than 2018. Note that in April, CMS also proposed – in a separate rule – major changes to Stage 2 requirements starting in 2015.
Impact Advisors’ Thoughts: We agree that the Stage 3 requirements (as proposed) would be very difficult for most providers to meet right now (especially the measures related to patient engagement). The timeline – given that vendors will need to recertify their products – also strikes us as somewhat aggressive. The degree to which CMS decides to scale back the proposed requirements (if at all) is what everyone will be watching for when the Stage 3 final rule is eventually published (likely later this summer). Although CMS is no longer accepting public comments on Stage 3, the comment period for the proposed rule on MU changes in 2015 will remain open until June 15, 2015 – so we encourage hospitals and EPs to submit their concerns to CMS. For more insights on what CMS has proposed for MU Stage 3, click here to download Impact Advisors’ recent summary and analysis. For information on the proposed changes to MU in 2015-17, click here for our key takeaways.
In case you missed it… an article in Politico this week – titled “Health care spending billions to protect the records it spent billions to install” – provides yet another reason why it is so important to monitor vulnerabilities proactively and address information security threats before they are exploited.