To say the final rule on Stage 2 of meaningful use and, the accompanying Stage 3 requirements work for CIOs who have to help implement them at their hospitals and health systems, would be a stretch.

Two separate sessions at the CHIME15 Annual Forum on Thursday indicated there remained ambiguity, anticipated difficulties and a short window for attesting to having met the measures.

Liz Johnson, RN, CIO of acute care hospitals and applied clinical informatics at Tenet Healthcare, and Pam McNutt, senior vice president and CIO at Methodist Health System teamed up Thursday morning to highlight some of the potential pitfalls to avoid.

"You guys really care about meaningful use to be here at 7 a.m.," Johnson remarked. "We feel your pain, and we'll try to share with you our insights."

CMS and ONC released the final rules for the EHR Incentive Programs on Oct. 6. The rules were published in the Federal Register on October 15, along with the 2015 edition of the certification criteria. Both were labeled "final."

[See also: CMS drops final EHR meaningful use rule and Healthcare reacts to new MU, interoperability rules.]

The meaningful use Stage 3 rule was also published in the Federal Register on October 15.

All three rules take effect 60 days from publication.

For Stage 3, there is a 60-day comment period, putting the deadline for comment on December 15, 2015.

"It is your right and duty to comment," Johnson told the audience.

One big change from Stage 2 to Stage 3, Johnson noted, is that the words "menu" and "core" go away.

"Now you're reporting on objectives, and the objectives have measures."

She went down a list of 10 objectives.  The first? "Protect patient health information."

"You know what that means," she said, "security assessment." Risk assessment has to be done sometime within your reporting period, Mcnutt added.

Last, but not least, Johnson and McNutt put up slide listing concerns with Stage 3:

The take from Capitol Hill
At a press briefing later in the day, Leslie Krigstein, CHIME's vice president of Congressional Affairs and Mari Rose Savickis, vice president of federal affairs, also discussed Stage 3 concerns.

"CHIME intends to comment fully on Stage 3, Krigstein told reporters. And now, lobbyists on Capitol Hill – herself and Savickis, "we should have more impact."

That the rules for meaningful use Stage 2 and Stage 3 came out together was unexpected Krigstein said. As she sees it, Stage 3 rules, as proposed, "would not move us closer to interoperability."

Top of the list of concerns for CIOs, she said, is a patient identifier. It is something that CHIME has made a priority to solve, she noted.

[See also: CHIME antes $1M for patient matching.]

Cyber security is also critical to CHIME members, she noted, adding that more than 119 million health records were breached this year.