Benefits and Challenges of Proposed Stage 3 HHS Rule


On Friday, March 20, HHS released their proposed rule for what is expected to be the third and final stage. The changes as proposed are expected to support HHS’ broader efforts to simplify and add flexibility in the program while driving interoperability and focus on patient outcomes.

In reviewing the 301-page proposed rule, there are a number of obvious benefits that most providers will appreciate including:

  • Establishing a single set of objectives for providers (EPs, EHs, and CAHs) to meet beginning in 2018 regardless of previous program participation (can optionally meet in 2017)
  • Aligning the EHR Incentive Programs with other CMS Quality Reporting Programs that use certified EHR Technology such as Hospital Inpatient Quality Reporting (IQR) and Physician Quality Reporting System (PQRS)
  • Changing the EHR reporting period so EPs, EHs, and CAHs all report on a calendar year
  • Removing of topped-out / duplicative measures or measures no longer useful in gauging performance (re., Record Demographics)
  • Removing Paper-based objectives (re., non-electronic summary of care, printing clinical summary)
  • Reducing the overall number of objectives to eight (8), down from 19 EHs / CAHs and 20 EPs

proposed objectives


With the rule, HHS has included a number of changes that maybe problematic (and surely debated) for providers including:

  • Increasing objective performance thresholds and/or reducing timeframes to make information available
  • Mandating ePrescribing and Secure Messaging for EHs and CAHs
  • Mandating that providers incorporate into the patient’s EHR:
    • an electronic summary of care document from a source other than the provider’s EHR system
    • Patient-generated health data or data from a non-clinical setting
  • Introducing the “ONC-certified API” that can be used by third-party applications or devices to provide patients access to their health information
  • Increasing the number of Public Health Agency reporting requirements

HHS has established a 60-day comment period with the final rule expected late summer, early fall. While we anticipate some changes will be incorporated into the final Stage 3 rule, there a number of actions we recommend providers take now to better position themselves for success. These include:

  • Working toward achieving the higher performance thresholds for CPOE, e-Prescribe, and Patient Education
  • Leveraging secure messaging to improving overall patient engagement performance
  • Revisiting your current Risk Analysis process to determine if changes are required based on the proposed rule
  • Understanding your state’s plans / options for increasing public health agency reporting
  • Inquire about your EHR vendor’s current API capabilities

In Part 2 of our Series on Meaningful Use Stage 3, we will look at the new technology challenges for increased interoperability.

Jennifer Schenck 3

Jennifer Schenck, a North Highland expert healthcare practitioner, co-authored this post.  Jennifer has worked with large healthcare service organizations in the development of their Meaningful Use programs.

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  1. Stage 3 HHS Rule Brings New Technology Challenges