Meaningful Use 3 Rules Introduce Major Patient Engagement Challenges


Friday, the Office of the National Coordinator published a draft version of its Stage 3 Meaningful Use rules. Since its 2009 creation, the Meaningful Use program has been the primary catalyst behind EHR adoption within the US. The three-stage program was designed to subsidize the roll out of EHR systems, plus implement a framework of interoperability and quality reporting systems that would drive healthcare into the 21st century. While debate rages on over the value of EHRs in general, the Meaningful Use program has thus far been successful in the first of its goals, promoting EHR adoption. With MU3, ONC was expected to focus on improving interoperability between EHR systems, but the new new rules published Friday were light on interoperability requirements, and instead focused on creating a single definition of “meaningful use” that will simplify attestation complexities and level-set all providers and hospitals by 2018. MU3 also implements objectives designed to streamline quality reporting requirements and introduces significant new patient engagement challenges.

Patient Portal Enrollment Requirements Increase to 25 percent

The first patient engagement challenge introduced within MU3 centers around patient portal use by recently discharged patients. MU2 initially introduced a requirement that 10 percent of a hospital’s discharged patients must subsequently log into a hospital-hosted patient portal to view or download their medical records. This threshold was decreased to just five percent after hospital executives argued that they could not force patients to log into a patient portal and therefore should not be held financially accountable for their patients’ choices.

Now, in the MU3 rules, this metric is bumped from five to 25 percent, meaning that hospitals and providers are going to have to convince one-quarter of all discharged patients to view their medical records online. According to ONC, the median performance for patient portal engagement during MU2 was 32 percent for practices and 11 percent for hospitals, meaning that hospitals will have some work ahead of them to meet the next threshold.

Secure Messaging With Patients

Next, MU3 mandates that secure messaging between patients and providers will not only be made available, but that its use will be mandated. The proposed rule requires that 35 percent of all discharged patients receive a secure message from the hospital or provider via a MU-certified patient portal, a significant increase over Stage 2 requirements. MU2 did not set a minimum threshold for hospitals, and set a five percent threshold for providers. However, ONC is not going to accept all patient-to-provider messages as part of the numerator on this metric. Messages related in some way to clinical care will count toward the 35 percent, but “messages with content exclusively relating to billing questions, appointment scheduling, or other administrative subjects should not be included in the numerator.” The requirement to only count clinically-focused messages is going to force health systems and providers to implement sophisticated data analytics tools that can help them sort through messages and separate the clinical ones from the administrative ones.

Consuming Patient-Generated Health Data

In addition to increased patient portal engagement and adding a new secure messaging requirement, MU3 is also introducing new requirements around consuming patient generated health data into the core EHR. The new objective requires “Patient-generated health data or data from a non-clinical setting” be incorporated into the core EHR for 15 percent of all discharged patients. The language within the objective clarifies that “data from a non-clinical setting” can include data from care providers such as nutritionists, physical therapists, occupational therapists, psychologists, and home healthcare providers, in addition to data obtained from patients themselves.

With such a broad range of options available, health systems aren’t likely to target patient-generated health data to meet this objective, but for those that do there are increasingly sophisticated frameworks available to work with, including Apple’s HealthKit and the Google Fit platform. EHR vendors are also putting the pieces in place to begin consuming patient generated health data. Cerner announced earlier this year that it would integrate patient-generated health data through a partnership with Validic, which markets a data integration engine focused on medical devices and fitness apps. Epic last year reported that it would begin consuming patient-generated health data through its “Open.Epic” API initiative.


With dramatically increased patient engagement requirements on their way, the big question will be which objectives will survive the public scrutiny of the open comments period. Patient engagement-specific measures have historically been targeted for removal by industry groups as they are seen as more difficult to achieve, and MU3 will be no exception.

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