Final Stage 3 meaningful use rules are a long way away—2014 by most estimates—but initial guidelines are indeed being discussed. According to Michael Peters, the American College of Radiology (ACR) continues to strongly advocate for appropriateness / criteria-based clinical decision support (CDS) to be leveraged by referring physicians during order entry.
“Meaningful use should be a natural vehicle for promoting and enabling this type of CDS, which is shown to improve quality, enhance patient safety, and reduce health care costs,” says Peters, director, Regulatory and Legislative Affairs, Government Relations and Economic Policy Departments, ACR. “Anyone interested in this topic should explore t he new ‘ACR Select’ initiative and read ACR’s past comments and letters to CMS and the Office of the National Coordinator (ONC).”
Preliminary draft recommendations by advisory committee members of the ONC for Health Information Technology (HIT) are in the works, but Peters cautions that these do not amount to regulations, requirements, or policies.
“This advisory activity will have no direct bearing on the future Stage 3 regulatory requirements, which will need to be developed by CMS and ONC via the usual federal rule-making process,” he says. “As always, CMS and ONC will be free to use, or not use, external advice—such as advisory committee recommendations—however they wish.”
Despite the early stage 3 rumblings, Peters points out that CMS’ and ONC’s final rules for Stage 2 are only now beginning to navigate Office of Management and Budget review, which can take up to 90 days. After Stage 2 publication in early Fall, CMS and ONC will not begin Stage 3 rulemaking for at least another year.
The message from advocates has so far remained consistent in anticipation of Stage 3, and Peters expects that strategy to remain for the foreseeable future. “ACR’s fundamental platform of asks specific to meaningful use has not changed over the years,” he says. “As per the usual, ACR’s IT and Informatics Committee will review all materials and provide the advisory committee members with helpful, in-depth feedback.”
While the ONC for HIT advisory committee recommendations are not yet done, Peters estimates that a draft will soon be ready for stakeholder comments. “CMS and ONC will not begin their respective Stage 3 rulemakings for at least another year,” he reiterates, “because most staff energy will be focused on Stage 2 (and Stage 1) implementation, education, technical corrections, and guidance development.”