Making sense of healthcare regulations is difficult. Just when you finally wrap your head around a major program, they go and change everything.
One area that is especially confusing for health tech is Meaningful Use Stage 3 (pat yourself on the back if you remember that little dandy). For everyone else, here’s a quick reminder to get you up to speed.
The healthcare community was forced to become very familiar with Meaningful Use as part of the Health Information Technology for Economic and Clinical Health (HITECH) Act. (If I want to prove my point about regulation being confusing, HITECH was part of the even larger American Recovery and Reinvestment Act).
In short, Meaningful Use was an electronic health record (EHR) incentive program. The HITECH Act made money available for healthcare organizations to adopt EHRs while Meaningful Use outlined specifics around what those EHRs should be able to do and how they should be used in order for health systems to get maximum Medicare reimbursements.
All told, Meaningful Use was a pretty effective program and laid the groundwork for what providers expect from their EHRs. It’s the reason we have seemingly obvious things like patient portals and e-prescribing.
What Meaningful Use Stage 1 and 2 didn’t always do a good job of was outlining exactly how the organization and its EHR would accomplish certain tasks. This oversight lead to things like patient records in barely-readable formats being saved to CDs and given to patients.
I mean, technically, we gave a digital copy of records to our patients. You can make that Medicare reimbursement check out to “Mr. Letter of the Law”, please.
And that’s what was so exciting about Meaningful Use Stage 3! It the took the successful core components of Meaningful Use Stage 2, the mandate that patients should be able to…
- View their health information
- Download their health information
- Transmit their health information to a third party
and added a crucial nugget:
- Access their health information through an API
By golly! Now we’re on to something—specifying the technical method for improving patient access to medical records might actually lead to a world where this information is truly accessible and usable.
As with all of these regulations, the primary party impacted is providers. They’re the ones on the hook for potential Medicare payment penalties if they don’t adhere to the specifications. However, the regulations start at the top of the chain with EHR vendors. To keep their customers happy, EHR vendors have to make it easy for providers to adhere to government regulations. (Hell hath no fury like a doctor who has to pay a penalty because a software system they’re required to use doesn’t have certain functionality.)
Then, just as everyone was scrambling to figure out how they would attest to this new regulation, they went ahead and killed it (sort of).
“On October 14, 2016, the U.S. Department of Health and Human Services (HHS) announced a final rule to implement key provisions of the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) in a new program called the Quality Payment Program. The Program advances Medicare’s value-based transformation for hundreds of thousands of physicians and other eligible clinicians by tying these payments to quality patient care. A number of the provisions in MACRA directly relate to the use of certified electronic health record (EHR) technology and health information technology (health IT), including the Advancing Care Information performance category under the Quality Payment Program. The Advancing Care Information category will modernize, streamline, and replace the Medicare EHR Incentive Program for eligible professionals (also known as “Meaningful Use”).The Quality Payment Program advances the use of certified EHRs and health IT as tools to improve the flow of health information among clinicians and, ultimately, improve the quality of care provided to patients.”
-The Office of the National Coordinator for Health Information Technology
Just like that, Meaningful Use Stage 3 was no longer.
In its stead stands the Advancing Care Information category of the Quality Payment Program, which resides under the Medicare Access and CHIP Reauthorization Act.
See what I mean about regulations? Just when you think you have them neatly sorted in your head…
Believe it or not, the goal of MACRA is to streamline all of the various regulations to which providers have to adhere. Whether this will be accomplished remains to be seen, but at least CMS made a nice website to try to explain it all!
What you need to know is that Meaningful Use Stage 3 is obsolete. While providers are on the hook for Meaningful Use Stage 2 until the end of 2018 due to reporting and payment lags, everyone will begin transitioning to the new QPP outlined in MACRA. Just for giggles, underneath the QPP, providers will report in adherence of either MIPS or APMs payment systems. They’ll begin submitting data under these new programs starting this year (2017) and have their Medicare payments impacted starting in 2019.
As for APIs, the spirit of Meaningful Use Stage 3 lives on. Nested deep within MACRA is language specifying that EHR technology must meet the 2015 Edition Health IT Certification which emphasizes the use of APIs to exchange clinical health data.
In many ways, this legislation is the reason more and more EHR vendors are releasing FHIR components as part of their newest releases. Their customers understand they have to comply and the vendors are following suit. The question, as usual when it comes to regulation-induced change, is whether this will lead to serious adoption and a new paradigm of open health information data sharing, or if most providers and vendors will be satisfied with meeting the bare minimum requirements to maximize their payments.
If there’s one thing for certain moving forward, it’s that it’s time to learn some new acronyms.
As the leading API platform for healthcare integration, we’re well positioned to help you meet (and exceed) functionality for health information exchange outlined in recent government regulations. If you ever need help making sense of it all, drop us a message. We’re happy to help in any way we can.
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