Stage 3 Proposed Rule Establishes Single Stage After 2017

CMS, HHS, and the Office of the National Coordinator for Health Information Technology recently released the proposed rule for the third stage of the government's EHR incentive program.

In addition to including new objectives and new requirements, the rule modified the timelines and structure of the program.

Perhaps most significantly in that regard, all providers (regardless of prior participation in the program) would attest to Stage 3 starting in 2018. And, though the program's requirements could slightly change in subsequent years, Stage 3 would remain the final stage moving forward.

"This would align everybody on Stage 3 in 2018, and it would be the final stage," Jason Fortin, senior adviser at Impact Advisors, a healthcare technology consulting firm, told Physicians Practice. "... That doesn't mean that the program is going to end, just that those requirements - whatever is finalized in the final rule, which will probably come out in the fall - that those requirements will just kind of continue indefinitely. I could see a scenario where they may tweak certain measures or remove them at times, but everyone would be on the same set of requirements."

Fortin said this movement toward a single meaningful use stage has pros and cons for physicians.

"I do think it will be easier for physicians to be able to kind of understand the requirements once we get to everybody kind of being on the same stage," he said. "You won't have this confusion, of, 'Oh I just had Stage 1, this is Stage 2, do I do this in this year?' You won't have that confusion, but it's going to be tough to get there."

New physicians and those just getting started with the incentive program, he said, would bear the brunt of the challenges associated with a transition to a single meaningful use stage.

".. New physicians would have to start right out of the gate in Stage 3 in 2018, if they were to start in 2018," said Fortin. "Or, physicians who may be [in] their first year, 2015 or 2016, there's a scenario where, depending on what they decide, they could go from Stage 1 to Stage 3, and that's a big jump."