Stage 3 HHS Rule Brings New Technology Challenges for Increased Interoperability


In the second of our three part Meaningful Use Blog Series, we continue to explore the benefits and challenges of the proposed Stage 3 HHS rule, summarized here.  Stage 3 will require EHR vendors to enhance existing technology to increase interoperability. These enhancements will provide greater access to health information for patients, but also introduce challenges for both EHR vendors and providers.  The proposed technical enhancements include:

Patient Electronic Access to Health Information – “provide access” means the patient has all of the tools to gain access to their health information even if they previously opted out.  The threshold for this measure is proposed to increase from 50% to 80% and data must be available within 24 hours.

This will create challenges for those vendors who currently do not push patient health information to a patient portal or make available through an API (Application Program Interface) if the patient opts out.

Coordination of Care through Patient Engagement – Providers will have to meet the thresholds for two of the measures, but report on all three measures.

  • Patient accesses health information via patient portal or API (New) – As proposed, vendors will have to provide API functionality within the EHR. Patients will have the ability to access their health information through a third party application such as a mobile device.  The threshold for this measure is proposed to increase from 5% to 25%.   As written, the rule would not require a provider to have both a patient portal and API functionality.
  • Secure Messaging – Requirements will remain the same, but the threshold for this measure is proposed to increase from 5% to 35%.
  • Patient generated health data or data from a non-clinical setting is incorporated into the certified EHR (New) – Vendors will need to consider controls within the EHR application to allow review or verification before incorporating outside data into the provider’s EHR. The threshold for this measure is proposed to be 15%.

Health Information Exchange

  • For referrals received, incorporate data into EHR (New) – As with incorporating other outside data into a patient’s health record, controls in the application will need to be in place for validation and review before integration into the provider’s patient records. The proposed threshold for this measure is 40% of referrals received.
  • Clinical Reconciliation completed – Medication, Medication Allergy, Problem List (New) – For the 2015 Edition proposed rule, ONC has proposed a set of criteria called Clinical Common Data set, which includes a standard for capturing the unique device identifier for implantable medical devices. Vendors will have to ensure the EHR complies with the new data set.

Public Health Reporting – The proposed rule increases the focus on communications between providers and public health agencies by expanding the number of objectives to include Case Reporting, Public Health Registry Reporting (PHAs) and Clinical Data Registry Reporting (CDRs).  It establishes requirements for bi-directional exchange for multiple measures as well as increases overall number of submission requirements (3 measures for EPs and 4 measures for EHs and CAHs).

Chart 2

Anticipated challenges:

  • Receipt and consumption of immunization forecasts and history data
  • Receipt and response to Case Reporting supplemental and ad-hoc data request
  • Lack of standardized data submission requirements across states / registries
  • Identification of applicable public and non-public registries

 Until the Stage 3 Rule is finalized, we encourage providers to start discussions with their vendors regarding future plans.   It will be important to understand:

  • Will the vendor pursue certification for all public health measures? If not, how does this impact the provider’s ability to meet state requirements?
  • Does the vendor intend to develop their own API functionality or leverage another API platform that exists in the market?
  • Is the vendor planning to build controls within the EHR for importing outside data into a patient’s record?

Part 3 of our series will focus on the potential economic impact to hospitals and physicians to move to Stage 3.

Joseph BarretteJoseph Barrette, a Senior Manager at North Highland, co-authored this post.  In his current role, Joseph has managed Meaningful Use program for a large healthcare services organization.


For more on the proposed HHS Stage 3 Rule:

[button link=”” color=”blue2″ icon=”” size=”small”]Read Part 1[/button]

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