A glide path to MU3. The new regulation proposes a glide path to ramped up requirements for MU3, which is required for everyone beginning in 2018. In the meantime, the new rule suggests changes to MU stage 2 that would significantly reduce requirements for patient access. To meet the requirements under the proposal, only one patient has to view, access, download or transmit records and that is down from a paltry 5%. The government is responding to industry feedback that this requirement has been very challenging to meet.
Impact of MU3 Objective 5. The first Objective 5 measure requires that 80% of patients be provided online access to view, download and transmit health information within 24 hours of availability. On first blush, this might not be so easy to achieve. It sounds like a lot but actually within the realm of possibility for many large health systems, accountable care organizations (ACOs) and even individual practices. Many have been ramping up to provide patient access via portals and other means in response to MU2 requirements as well as the emerging business case for practices and organizations involving value-based care and reimbursement. It should be noted the measure only requires that eligible professionals (EPs) provide access and instructions for accessing the information. This should help EPs meet the 80% threshold.
The government hopes that innovation and interoperability can be achieved for this and many MU3 objectives through the use of application program interfaces (APIs). The emphasis on APIs creates opportunities for technology entrepreneurs to spur patient engagement by providing innovative means of online access and communication mechanisms.
The potential of APIs can be seen with the launch of the Apple Watch. For example, Anthem and CareEvolution announced an Apple Watch application (app) called the comprehensive Family Health Record (cFHR), which is available as a free iPhone download. The app is designed so that consumers may easily and conveniently receive alerts, review new medical information and manage their health care from their wrist. Consumers would be notified of suggested preventive screenings, gaps in disease management and prescription refills, and potential drug interactions, the companies said.
Measure 2 of MU3 Objective 5 builds on MU2 measures by requiring EPs to provide patient-specific access to educational resources based on clinically relevant information in the electronic health records (EHRs) for 35% of patients. This is an easy way to engage patients and provide value, especially from the patients point of view. Pharmaceutical manufacturers and other content sources willingly provide in-depth educational content for various conditions. We see a big opportunity for API developers to provide innovative ways for furthering this kind of patient engagement.
Moreover, many organizations can achieve this MU3 Objective 5 measure and many Objective 6 measures, for that matter simply by targeting their chronic disease populations. Eligible professionals and hospitals adopting value-based care strategies are already targeting these populations. As a result, many are in a position to build on what theyve already got in place to increase communication and engagement with a significant number of their patients with chronic illnesses.
Impact of MU3 Objective 6. Measure 1 of Objective 6 requires engagement of 25% of patients by viewing, downloading or transmitting their health information to a third party. Measure 2 requires that 35% of patients must send or receive a secure message. Patient health data must be recorded in the EHR for only 15% or more of patients to meet Measure 3. Some of these Objective 6 measures are increased from MU2, such as secure messaging increasing from a low 5%. Meeting all of these measures sounds daunting, but EPs only need to meet 2 measures to satisfy the objective.
The Centers for Medicare and Medicaid Services (CMS) hopes that API developers will come forward with solutions that make Objective 6 measures more easily achievable. Providers are already aware of the potential, such as in the area of mobile health. According to a recent survey, nearly half of health care professionals would like to incorporate smartphone apps into their practices within five years and 72% believe that health apps will encourage patients to take more responsibility for their health. Patients also are coming onboard. Survey results indicate that 32% of mobile health app users share information collected by apps with their doctors. This certainly bodes well for new and expanded products that sync with the MU stage 3 requirements.
To ease the burden of achieving these measures, the government has increased the kinds of communications that count toward the goal. They include secure messages from the care team; data from such providers as nutritionists and physical therapists; data from the patient him/herself or an authorized representative; and fitness data from a wearable. These expanded data sources also should make it easier for providers to achieve the goal as well as create expanded patient engagement opportunities.
Patient engagement will increase by allowing authorized representatives such as caregivers access to a patients health information, which counts toward meeting MU3 Objective 6. This is crucial because so many elderly and chronically ill have others in charge of their day-to-day care, who will benefit from having more complete information about their patients. This new MU3 requirement opens new doors for patient engagement. APIs can offer new tools to do so, and the government is hopeful they will. Alternatives such as Blue Button already are available and gaining traction.
MU3 Measure 3 calls for EHRs to collect patient-generated health data for 35% of patients.To be sure, there is a lot of complexity involved in gathering, vetting and storing patient-generated data in the EHR. We believe that this is a huge opportunity for innovation for entrepreneurs and API developers, as well for mainstream EHR vendors, who can use such functionality as a market differentiator.
MU3 is only part of the story. MU3 will help drive patient engagement, but its not the only driver. As we have noted in previous issues of HIT Perspectives, the move toward value-based care especially the advent of ACOs is also a powerful driver for patient engagement. Both public and private payers have recognized the value of patient engagement in terms of reducing costs, improving outcomes, and increasing patient satisfaction. This was underscored by findings of the 26th Annual Leadership Survey, sponsored by the Healthcare Information and Management Systems Society (HIMSS), which found that patient engagement is a success factor. Nearly three-quarters of respondents reported that consumer and patient considerations such as patient engagement, satisfaction and care quality would be the top business issue for their organization over the next two years. Again, this is in sync with MU3s intent and time frames.
Moreover, such topics also are measures on which providers are graded and paid. Money talks and this creates the business case for driving patient engagement at the provider level. The results of the HIMSS survey make that clear.
However, the business case for providers concerning patient engagement is only part of the story. Tools are needed to make more and better patient engagement a reality. This is where MU3 comes in, providing additional impetus and a roadmap for what needs to be done technology-wise both for EHRs and EHR add-ons using APIs. Now vendors have their own business case to build new features to meet the requirements.
What happens next. It remains to be seen how MU3s percentage measures survive public scrutiny. Our guess is that the objectives will remain the same, but some of the measures may be ratcheted downward to make them even easier to meet. That certainly has been the practice in the past especially in response to pushback from provider organizations, which undoubtedly will be very vocal when it comes to MU3. Moreover, MU3 is the governments last chance for rule making for this program, so it is logical that the proposed measures are more aggressive than some might have anticipated. On the other hand, we believe that MU3s objectives and measures will help drive patient engagement, with the business case from value-based purchasing acting as an afterburner.