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2015 MU3 Certification Requirements in a Nutshell

By: Nextech | April 10th, 2015

2015 MU3 Certification Requirements in a Nutshell Blog Feature

meaningful_use_3_in_a_nutshellDon’t Panic! (About Meaningful Use Stage 3)

Part 2: The 2015 Certification Requirements in a Nutshell

“The certification criteria we have proposed in the 2015 Edition will help achieve that vision through provisions that consider the range of health IT users and uses across the care continuum, including those focused on interoperable standards, data portability, improved transparency, privacy and security capabilities, and increased oversight."
—Karen DeSalvo, MD.  ONC

Welcome to the second half of our series on Meaningful Use Stage 3.  In Part 1, we looked at the interoperability and EHR function requirements of the CMS rule.  In this article, we will look at criteria from the ONC 2015 rule.  To be honest, I suspect the ONC’s 700+ page rule may have been responsible for a lot of the panic attacks folks seemed to have in response to MU3.  Whereas the CMS rules are relatively straightforward, easy to follow, and seem to have the intent of stabilizing things, the ONC rule seems to be trying to do the opposite.  Seriously, it’s almost like they’re trying to sow chaos.

But remember: Don’t Panic… We can (and will) survive this.The first notably weird thing about the ONC rule is that it contains 68 unique criteria, but only 36 of them are required for Meaningful Use.  Some of these are already in place, while others are entirely new for Stage 3.  In order to qualify as having “Base EHR,” both the ONC and CMS require that participants meet these 36 specific criteria.

The Base EHR Requirements: ONC

The ONC has the following 16 requirements for Base EHR, the following 14 of which (arranged alphabetically) have been carried over from previous stages:

  • Clinical Decision Support (CDS)
  • Clinical Quality Measures (CQM)
  • CPOE – diagnostic imaging
  • CPOE – laboratory
  • CPOE – medications
  • Data Portability
  • Demographics
  • Direct Project
  • Direct Project, Edge Protocol, and XDR/XDM
  • Medication Allergy list
  • Medication List
  • Problem List
  • Smoking Status
  • Transitions of Care (ToC)

The following two (out of the 16 total) ONC criteria for Meaningful Use (Stage 3) Base EHR are new:

  • Application Access to Common Clinical Data Set
  • Implantable Device List

CMS requires that participants meet 20 more requirements, in addition to the above for Base EHR, to qualify for Meaningful Use Stage 3. The following 16 criteria (arranged alphabetically) are carried over from previous stages:

  • Automated Measure Calculation
  • Automated Numerator Recording
  • Clinical Info Reconciliation and Incorporation
  • CQM – Report
  • Drug-drug, Drug-allergy Interaction Checks for CPOE
  • Drug Formulary and Preferred Drug List Checks
  • Electronic Prescribing
  • Family Health History
  • Family Health History – pedigree
  • Patient-specific Education Resources
  • Secure Messaging
  • Transmission to Cancer Registries
  • Transmission to Immunization Registries
  • Transmission to Public Health Agencies – reportable lab tests and values/results
  • Transmission to Public Health Agencies – syndromic surveillance
  • View, Download, & Transmit to Third Party

The following four (out of the 20 total) CMS criteria for Meaningful Use (Stage 3), in addition to Base EHR, are new:

  • Patient Health Information Capture
  • Transmission to Public Health Agencies – antimicrobial use and resistance reporting
  • Transmission to Public Health Agencies – health surveys
  • Transmission to Public Health Agencies – reportable condition reporting

That just leaves the remaining 32 “requirements.”  You may be wondering why I just used quotation marks.  There’s a reason, I promise.  You see, even though these 32 items are included in the ONC rule, none of them are required for Meaningful Use (which has some people, quite understandably, wondering why in the world the ONC keeps including/adding them).  However, for the sake of thoroughness, I feel these should be included. 

You never know what might turn out to be important later on down the road.

The following 19 criteria (arranged alphabetically), of the 32 that are not required for Meaningful Use, and have been carried over from previous stages:

  • Accounting of Disclosures
  • Amendments
  • Auditable Events and Tamper Resistance
  • Audit Report(s)
  • Authentication, Access Control, and Authorization
  • Automatic Access Timeout
  • CQM – import and calculate
  • Electronic Medication Administration Record
  • Emergency Access
  • End User Device Encryption
  • Image Results
  • Incorporate Lab Tests and Values/Results
  • Integrity
  • Patient List Creation
  • Quality Management System (QMS)
  • Safety Enhanced Design
  • SOAP Transport, Security Specification, and XDR/XDR for Direct Messaging
  • Transmission of Lab Test Reports
  • Vital Signs, BMI, and Growth Charts

The following 13 (out of the 32 total), non-Meaningful Use criteria, are new:

  • Accessibility-Centered Design
  • Accessibility Technology Compatibility
  • Care Plan (consolidating multiple care plans)
  • Consolidated CDA Creation Performance
  • CQM – filter
  • Data Segmentation for Privacy (federal substance abuse privacy law) – receive
  • Data Segmentation for Privacy (federal substance abuse privacy law) – send
  • Decision Support – knowledge artifact: Send CDS Interventions
  • Decision Support – service: Receive CDS Interventions
  • Electronic Submission of Medical Documentation
  • Healthcare Provider Directory – query request
  • Healthcare Provider Directory – query response
  • Social, Psychological, and Behavioral Data

I apologize for not going into detail on the above criteria.  There just wasn’t room for that kind of detail.  This is just a blog post, after all.  However, further details on all of the above requirements (and non-requirement) can be found in the CMS/ONC written rules (Links to the complete documents can be found in Part 1). 

So there you have it, folks!  Meaningful Use Stage 3 in a nutshell… But, please… I beg you… don’t try to eat it.  As I used to tell my children (far more times than I could’ve ever anticipated) during their toddler years—“Everything is not food!” 

For those of you who are now calm, good for you.

For those who might still be panicking… stop it.

Like I told you at the start of this article… we will survive.

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