Guest post by Charles Settles, Product Analyst at TechnologyAdvice
Electronic prescribing has become an integral part of EHR software, but the proposed rule for Stage 3 of Meaningful Use may introduce changes — for better or worse.
Stage 3 of the Meaningful Use incentive program, according to the proposed rule, will “streamline the program by removing reporting requirements on measures which have become redundant or ‘topped out’ through advancements in EHR function and provider performance for Stage 1 and Stage 2.” In other words, easily attained measures have been removed, consolidated or otherwise changed.
Many of these changes have come about due to correspondence between program administrators, stakeholder associations and provider groups. Reducing the complexity of the program and its burden on providers — particularly surrounding reporting and attestation — has been a focus since the program’s inception.
In that spirit, perhaps the largest single proposed change is a realignment of objectives and measures for those yet to attest to Stages 1 and 2.
- For 2015 and 2016, new participants in the program would be allowed to attest for any 90-day period within the calendar year.
- For 2015 only, all eligible providers would be allowed to attest for any 90-day period regardless of stage. So, if you’re scheduled to attest for Stage 2 in 2015, you won’t need a full year.
- Lastly, beginning in 2017, all providers, regardless of stage, will use a full calendar year as the reporting period.
These proposed changes to reporting and attestation underline the difficulty that many providers and hospitals have had with Meaningful Use.
Despite the myriad challenges, the growth in e-Prescribing has been a particularly bright spot for the EHR incentive program. According to the Office of the National Coordinator (ONC), “by April 2014, 70 percent of physicians were e-Prescribing using an EHR.” This was up from just over 20 percent at the program’s inception, as seen in the figure below.
A Brief Overview of E-Prescribing & Meaningful Use
Computerized physician order entry (CPOE), clinical decision support (CDS) and e-Prescribing have been inexorably linked since the Meaningful Use program’s inception; in the initial proposal for Stage 1, CPOE was to be used for medication, laboratory and any other provider orders.
When the Stage 1 rule was finalized, CPOE requirements were limited to medication orders only, in order to placate stakeholders that claimed the implementation of CPOE usually came in the final steps of a hospital or provider’s conversion to electronic records and processes.
According to the Stage 1 final rule, 30 percent of medication orders were required to be made using CPOE, limiting the numerator in the calculation to only include those patients with at least one medication order entered using CPOE. Additionally, more than 40 percent of prescriptions issued were required to be transmitted to the pharmacy electronically with certified EHR technology (CEHRT). Also, CDS was required to perform drug-drug and drug-allergy interaction checks for these prescriptions.Exclusions were made for EPs issuing fewer than 100 prescriptions during the EHR reporting period. Regardless of these exclusions though, the majority of the EHR market needed to order and submit prescriptions electronically at the beginning of the Meaningful Use incentive program, so software vendors had little choice but to be ready.
In Stage 2, the thresholds rose. More than 50 percent of percent of prescriptions needed to be sent electronically, and a new CDS measure was added requiring those prescriptions to be compared to at least one drug formulary. Also, the CPOE threshold for medication orders was increased to 60 percent. Furthermore, the previously optional, or ‘menu’, objective to provide patient-specific education resources to more than 10 percent of unique patients became a required, or ‘core’, objective in Stage 2. This is relevant to e-Prescribing since many office visits result in at least one medicine being prescribed to a patient.
Well-made e-Prescribing modules should automate this process, pulling drug-related information into the EHR so that it can be disseminated to the patient at the point of care, or via a patient portal. The only exceptions made are for providers who are attesting to Stage 1 in 2015. If they had not planned to attest to these previously optional objectives, they will not be required to do so.
E-Prescribing in Stage 3
Stage 3, once it is finalized, will likely look substantially similar to Stage 2, at least as far as e-Prescribing is concerned. Medication orders should still be required to be sent electronically in at least 50 percent of instances, and input using CPOE at least 60 percent of the time. Also, the requirement to provide patient-specific educational resources should remain unchanged at 10 percent. Also unchanged is the Stage 2 requirement that when receiving a transition of care, all participants must perform, for at least 50 percent of relevant patients, medication reconciliation — or verify the medication list is accurate.
The only potential change likely to affect e-Prescribing is the new focus on application programming interfaces (APIs) for health information exchange. If CMS makes APIs a requirement — which they are considering — it will signify a shift towards true interoperability and software-agnostic methods of exchanging health data.
Connecting your EHR or e-Prescribing software to an immunization registry, drug formulary or any other electronic resource would be far easier and less expensive with an API.
In short, while the proposed changes for Stage 3 of Meaningful Use are substantial, e-Prescribing will remain relatively untouched. Though e-Prescribing is becoming ubiquitous, there are still improvements that can be made. Providers and hospitals should focus on driving towards 100 percent e-Prescribing utilization, 100 percent CPOE for medication and other orders, and properly transitioning care. Once the comment period closes and the Stage 3 rule is finalized, we’ll see where the dust settles.