The Centers for Medicare and Medicaid (CMS) recently released the proposed rule on Stage 3 of the Medicare/Medicaid Electronic Health Record (EHR) Meaningful Use Incentive Program. The stage 3 objectives, for the most part, reiterate the stage 2 goals, with higher thresholds for demonstrating meaningful use. These requirements will go into effect in 2016. To that end, organized neurosurgery sent a comment letter to CMS which voiced our concerns for the unique challenges of specialty care and cited that the proposed Stage 3 requirements would be overly burdensome for specialists and therefore would not allow neurosurgeons to comply with the program’s requirements.
In our letter we highlighted our apprehension that Stage 3 recommendations are being made without considering how providers, especially neurosurgeons and other specialists have fared with meeting the criteria used in Stages 1 and 2 of the EHR Incentive Program. In addition, we also cited the need for CMS to better align their various quality improvement programs given the fact that these programs will become punitive in future years (a topic we have chatted about before – remember our 85 percent cumulative pay cut to physicians chart? If not, check out this Neurosurgery blog post).
As it turns out, neurosurgeons aren’t the only folks who have some trepidation over the meaningful use stage 3 requirements. Earlier this month, David Pittman of MedPage Today wrote an in-depth article on this entitled, “Groups Want Delay in Meaningful Use Rules.” We encourage you take a gander at it and let us know what you think.