The Centers for Medicare and Medicaid Services (CMS) on March 20 released its proposed rule for Stage 3 of the Electronic Health Record (EHR) Incentive Program, also called Meaningful Use Stage 3. The rule contains the proposed criteria that eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must meet in order to qualify for EHR incentive payments and avoid penalties for non-participation.

According to CMS, the proposed rule would "continue to encourage electronic submission of clinical quality measure (CQM) data for all providers where feasible in 2017, propose to require the electronic submission of CQMs where feasible in 2018, and establish requirements to transition the program to a single stage for meaningful use." Of concern to the ACC is a proposal to require all providers, even first-time participants, to report for a full calendar year, as well as proposals to require all participants to immediately begin participation in Stage 3 starting in 2018, rather than allowing participants to proceed through the Stages in a progressive fashion.

"The ACC has long supported the adoption of EHRs as a mechanism for improving patient outcomes," said ACC President Kim Allan Williams, Sr., MD, FACC. "The EHR Incentive Program as currently structured has been focused more on 'checking the box' than changing care delivery to achieve the goal of improved patient care. Implementing an EHR system in a physician practice or a hospital is not as simple as flipping a switch; it takes time, financial investment, careful consideration and planning, as well as education for all staff. The program must take this learning curve into consideration."

The Stage 3 proposed rule can be accessed here. The ACC is currently reviewing the rule and will submit comments by the May 29 deadline. CMS is considering additional changes to meaningful use for 2015 through separate rulemaking.

Keywords: Centers for Medicare and Medicaid Services, U.S., Electronic Health Records, Learning Curve, Meaningful Use, Medicaid, Medicare, Patient Care, United States

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