On March 30, 2015, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule (Proposed Rule) setting forth meaningful use criteria for Stage 3 of the Medicare and Medicaid Electronic Health Record Incentive Programs (EHR Incentive Programs). CMS intends for Stage 3 to be the final stage of the EHR Incentive Programs, and as a result the Proposed Rule seeks to implement a single set of meaningful use objectives and measures designed to promote best practices and continued improvement in health outcomes. The Proposed Rule also incentivizes interoperability of health information technology and reduces the reporting burden on EHR Incentive Program providers by transitioning nearly all such providers to a calendar year reporting schedule.

The Proposed Rule sets forth eight objectives intended to (i) align Stage 3’s meaningful use requirements with national health care quality improvement efforts; (ii) promote interoperability and health information exchange; and (iii) focus on CMS’s three-part aim of reducing health care cost, improving health care access, and improving health care quality. Stage 3 meaningful use objectives include the following:

1. Protect Patient Information
2. Electronic Prescribing
3. Clinical Decision Support
4. Computerized Provider Order Entry
5. Patient Electronic Access to Health Information
6. Coordination of Care through Patient Engagement
7. Health Information Exchange
8. Public Health and Clinical Data Registry Reporting

CMS proposes to make compliance with the Stage 3 meaningful use criteria optional in 2017 and mandatory in 2018. CMS has solicited comments regarding the Proposed Rule, and will consider all comments received on or before May 29, 2015.

For in-depth analysis of all aspects of Stage 3 meaningful use criteria for the EHR Incentive Programs, please see this Pulse Article from Robinson+Cole’s Health Law Group.

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