Last week, ASCRS submitted comments  to CMS in response to the Medicare and Medicaid Programs: Electronic Health Record Incentive Program – Stage 3 and Modifications to Meaningful Use in 2015 Through 2017 Final Rule. Even though this final rule was published in October, CMS is allowing a 60-day comment period on the final Stage 3 Meaningful Use, and they have expressed their intentions to make changes to Stage 3 based on the feedback they receive from stakeholders.
Overall, ASCRS’ comments asked CMS to delay Stage 3 Meaningful Use until a significant majority of providers are successfully attesting to Stage 2 Meaningful Use. In addition, we explained the impossibility for the majority of our members to successfully attest to Stage 3 as it is currently designed.
Specifically, we pointed out the significant increase in thresholds for many of the measures, including patient access to health information, computerized provider order entry, and using the EHR to send messages to patients. CMS addressed many of these threshold issues in the Stage 2 Modifications Rule; however, CMS has increased the thresholds even further for Stage 3. ASCRS pointed out it is counterintuitive to offer flexibility in the Stage 2 Modifications rule and then raise thresholds significantly higher in Stage 3.
ASCRS also asked CMS to eliminate measures that hold providers responsible for factors outside their control, such as the health information exchange measure and the patient accessing health information measure. Providers who are attempting to meet Meaningful Use should not be penalized for actions of patients or other local providers that they cannot control.
ASCRS also emphasized the importance of developing meaningful and achievable measures specifically for specialty providers. Measures such as the public health reporting measure do not apply to ophthalmologists and will be virtually impossible for specialties such as ours to meet. ASCRS argued that providers should only be required to report Meaningful Use measures that are relevant to their specialty, and CMS should work with medical specialty societies to focus on providing meaningful measures for each specialty.
In addition, ASCRS urged CMS to focus on improving interoperability as they move forward with the Meaningful Use program. Finally, ASCRS emphasized that Stage 3 Meaningful Use should not be an all or nothing approach, and should provide partial credit for the measures that providers are able to successfully meet.
We will keep you updated as CMS reviews these comments and makes changes to Stage 3 Meaningful Use.