Health Information Technology Policy Committee Approves MU Stage 3 Recommendations

by Davis Wright Tremaine LLP

On March 11, the Health IT Policy Committee (HITPC) voted to approve the meaningful use workgroup’s Stage 3 recommendations. The federal advisory committee’s recommendations will be presented to the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator (ONC) where they will be closely reviewed and considered in the development of the Stage 3 proposed rules expected to be published this fall. HITPC’s recommendations represent one of the best crystal balls into what is to come for Stage 3.

The workgroup presented recommendations for Stage 3 emphasizing four goals: clinical decision support, patient engagement, care coordination, and population management. Following the previous pattern of changes from Stage 1 to Stage 2, the recommendations for Stage 3 generally: (i) heighten or clarify the Stage 2 measures to accomplish existing meaningful use objectives, (ii) change certain Stage 2 menu objectives to core objectives, (iii) introduce some new menu objectives, and (iv) require additional certification criteria for electronic health record (EHR) technology, both related to and independent of the specific objectives. These include:

  • Five new intervention areas for clinical decision support: preventative care, chronic condition management, appropriateness of laboratory/radiology orders, advanced medication-related decision support and improving problem, medication, and allergy lists.
  • Creating two new types of transitions of care at which a summary of care record is provided: consult (referral) request and consult result note.
  • Recording whether an older patient has an advance directive changes from a menu to a core objective for eligible hospitals, and introducing it as a menu objective for eligible professionals.
  • Recording electronic progress notes in patient records becomes a core objective.
  • New menu objectives for:
    • Order tracking (eligible professionals only): Eligible professionals use EHR to assist with follow-up on orders; results of specialty consult requests are returned to the ordering provider/specialist
    • Unique device identifier (UDI): Providers record Food and Drug Administration unique device identifiers when patients have newly implanted devices.
    • Patient-generated health data: Providers receive provider-requested, electronically submitted patient-generated information.
    • Notifications: Eligible hospitals and critical access hospitals send electronic notifications of significant health care events to members of a patient's care team. These events include arrival at an emergency department, admission to hospital, discharge, and death.
  • Additional certification criteria for EHR, such as:
    • Ability to capture additional patient information and communication preferences;
    • Capacity to enable intervention tools in connection with clinical decision support
    • Allowing provider organizations to configure summary reports to provide relevant, actionable information related to a visit
    • Indicating whether a patient is expecting a response to a message s/he generates and tracking responses to patient-generated messages; and
    • Ability to receive results of external clinical decision support pertaining to a patient’s immunization.

The workgroup also eliminated eight items from its initial recommendations, including those dealing with patient reminder preferences; electronic medication administration record (eMAR) as a core objective; EHR imaging functionality; and objectives for medication adherence, patient requests for amendments, and case reporting.

The HITPC approved the workgroup’s recommendations with the caveat that the concerns expressed on both sides by HITPC members—from some that the recommendations could overly burden providers, and from others that the recommendations did not go far enough to improve outcomes—would be included in its reports to CMS and ONC. In addition to its influence on the proposed rulemaking on Stage 3 meaningful use objectives and EHR certification criteria expected this coming fall, HITPC’s recommendations may play a role in finalizing the rulemaking for the voluntary 2015 Edition meaningful use EHR certification criteria.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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