Impact Insights

Week in Review 3/27/15

In a relatively quiet news week last week, the biggest story for most was undoubtedly the publication of the proposed rule on Stage 3 of meaningful useA more detailed overview of the proposed rule (which are only focused on requirements in 2017, 2018, and beyond) is on the Impact Advisors blog – but we have summarized the important highlights below:

  • All hospitals and EPs would be required to be on Stage 3 by 2018
  • Stage 3 would be optional in 2017
  • 2015 Edition CEHRT would be required by 2018
  • Starting in 2017, the EHR reporting period for both hospitals and EPs would be a full 365 days, based on the calendar year
  • No more “core” and “menu” sets; instead only eight objectives for both hospitals and EPs
  • Each objective would have one or more measures associated with it
  • For three of the eight objectives, providers actually could fail an associated measure and still achieve MU
  • Starting in 2018, CQMs would need to be reported electronically “where feasible”

Proposed MU Timeline second image

Impact Advisors’ Thoughts: The biggest problems – by far – with Stage 2 were around the requirements for patient engagement and health information exchange. Based on our initial read of the proposed rule, we suspect those will continue to be areas of concern for providers (particularly the patient engagement measures). For more details on Stage 3 and our initial impressions, definitely check out the IA blog – and stay tuned for a more detailed primer, as well as more insights on the ONC certification requirements!


An early look at Medicare’s bundled payment initiative published in Health Affairs finds that participating hospitals are only focused on “a few high volume conditions.” Under the Bundled Payments for Care Improvement (BPCI) initiative, which was launched in January 2013, hospitals can sign up for bundled payments for as many as 48 clinical conditions defined by CMS. (For context, a “bundled payment” is a predetermined amount of money that is intended to cover the costs of all services associated with a specific episode of care or condition.) The authors found that a number of hospitals entered into the risk-free “preparation phase” of the program that is focused on just understanding spending patterns. Only a “small proportion” actually enrolled in the risk-bearing phase of the program though – and most of those hospitals only decided to sign up for less than four (!) of the 48 conditions.  Overall, the authors found that the hospitals taking on risk in the CMS bundled payment initiative were primarily large, nonprofit teaching hospitals in the Northeast that already had affiliations with post-acute care facilities.

Impact Advisors’ Thoughts: The actual results of the BPCI initiative won’t be published for years, but this article still underscores some of the very real challenges CMS is facing to make any kind of value-based program or pilot that includes accountability for services spanning multiple settings of care more widespread.


In case you missed it… the average wait for patients at a physician office is 19 minutes 16 seconds, according to an article in Becker’s Hospital Review. (More details on wait times for certain cities and specialties are available in the study from Vitals.)