As the comment period has come and gone (ended May 29, 2015) for meaningful use Stage 3, and as multiple organizations, like CHIME, and countless other individuals have taken the time to comment on the final rule, I thought it was a good time to ask the question: Does the meaningful use Stage 3 rule sail or sink?
Procuring responses to this question from a number of health IT insiders helps to identify some of the most pressing issues with the final stage of meaningful use, a topic that is almost second to none in regard to generating support or opposition from those in the sector.
The College of Healthcare Information Management Executives, in its comments on the rule, called federal plans for the third stage of meaningful use too ambitious and in need of several important changes, but still offered their support for a corresponding CMS proposal that would shorten meaningful use reporting in 2015 from a full year to any continuous 90-day period. In total, CHIME said meaningful use Stage 3 is “unworkable.”
“Were all requirements finalized as proposed, we doubt many providers could participate in 2018 successfully,” CHIME said. “And with so few providers having demonstrated Stage 2 capabilities, we question the underlying feasibility of many requirements and question the logic of building on deficient measures.”
Bennett Lauber, chief experience officer, at The Usability People offered a slightly different take: “The MU3 program contains some well-needed enhancements to the Safety-enhanced design portion of the 2015 certification criteria. They have also proposed significant changes to the Safety-enhanced Design (aka usability) testing requirements. These new requirements might seem burdensome to some of the smaller EHR vendors, as they require 17 and not seven items to be usability tested and finally set a minimum number of participants for these studies and more. With everyone complaining about the (lack of) usability of healthcare software these additional requirements should be welcome as they force the vendors to perform real summative usability tests and as a result it eventually might actually save lives.
David Muntz, former principal deputy director of the ONC and current CIO of GetWellNetwork adds, “Getting to a common stage is a good thing, but there is still some concern expressed by those who are struggling with the move from Stage 1 and Stage 2 to the future state. The limit on adding new elements is a positive, though some of the thresholds that need to be met will be a concern to many, particularly those that require a provider to affect behaviors in the patients. Standardizing quality measures and adjusting the reporting period are good moves, but the possibility of requiring all vendors to have a complete set will delay release dates.
“The encouragement to add APIs for data exchange is a positive. More thought, however, is needed to the areas where open APIs can prove beneficial. Secure messaging is great, but the threshold for usage is really based on patient preference and may be a bit aggressive. The greatest disappointment was the continued use of specific features and functions without an alternative to deem features and functions based on a combination of appropriate process and outcome measures. A deeming approach would have given the users a great deal of latitude in how to implement features and functions that would have produced favorable outcome.”
The College of Healthcare Information Management Executives (CHIME), the professional organization for chief information officers and senior IT executives, is calling on innovators throughout the U.S. to participate in the CHIME National Patient ID Challenge.
In an effort to find a universal solution for accurately matching patients with their healthcare information, CHIME will launch a $1 million challenge early this summer on the HeroX platform, co-founded by XPRIZE CEO Dr. Peter Diamandis.
The digitization of the U.S. healthcare system maintains that electronic health records must be able to seamlessly share and exchange information. According to CHIME, interoperability is not enough — to realize their full potential, patient data contained in the EHR must be accurate to support the requirements of coordinated, accountable, patient-centered care, the organization says.
“There is a growing consensus among payers and providers that a unique patient ID would radically reduce medical errors and save lives,” said CHIME CEO and president Russell P. Branzell, FCHIME, CHCIO.”Incomplete or duplicate health records present significant issues in terms of patient safety, and there is a pressing need for preventing, detecting and removing inaccurate records so hospitals can positively match the right data with the right patient in order to provide the best possible care.”
Duplicate or inaccurate patient records can occur from manual data entry errors, or when two or more individuals share the same name. This presents considerable concern for different individuals being identified as the same patient, potentially resulting in inadequate treatment or unintended injury.
The College of Healthcare Information Management Executives released the following statement in support of embracing federal interoperability plans:
The federal government’s top health IT advisers recently made recommendations on how public and private stakeholders should progress toward interoperability in healthcare. Leaders from the College of Healthcare Information Management Executives (CHIME) and Health Level Seven International (HL7) embraced the recommendations of the JASON Task Force, calling them a significant step forward in achieving the promise of information technology in healthcare. CHIME and HL7 also highlighted the need to incorporate critical enhancements to standards currently under development for meaningful use Stage 3.
During a joint meeting of the Health IT Standards and Health IT Policy Committees, federal officials discussed new details regarding a national interoperability roadmap and outlined concrete recommendations meant to improve the appropriate access and use of health data. The JASON Task Force said that a solid foundation for interoperability should utilize public APIs, advance modern communications standards, such as HL7’s Fast Healthcare Interoperability Resources (FHIR), and use meaningful use Stage 3 as a pivot point to initiate this transition.
FHIR is a simple-to-use format that can improve interoperability for a range of technologies, including EHRs, patient-centric solutions and mobile applications. A next generation standards framework created by HL7, FHIR combines the best features of HL7’s Version 2, Version 3 and CDA product lines while leveraging the latest web standards and applying a tight focus on implementability.
“Today’s discussion and the recommendations of the JASON Task Force represent an evolution in thinking,” said CHIME president and CEO Russell P. Branzell, FCHIME, CHCIO. “The updated roadmap and the recommendations put forth by the JASON Task Force incorporate a tremendous amount of stakeholder input and articulate the challenges facing our industry much more completely than previous efforts.”
“The prioritization of standards-based interoperability and a commitment to long-term policymaking will enable healthcare to benefit from information technology in very tangible ways,” said Charles Jaffe, MD, PhD CEO of HL7.
CHIME and HL7 believe important recommendations were accepted by the full Health IT Standards and Health IT Policy Committees. HL7 and CHIME also support allowing time to make meaningful use Stage 3 more impactful with the inclusion of key standards that are still under development. “There remains a disconnect between artificial government timelines and the realities of standards and technology development,” Branzell said. “This highlights a principle concern with how health IT policy is created, adopted and implemented at the federal level.”
CHIME and HL7 are committed to collaboration in the advancement of health IT initiatives such as FHIR and support government efforts on the interoperability roadmap.
CHIME is an executive organization dedicated to serving chief information officers and other senior healthcare IT leaders. With more than 1,400 CIO members and more than 140 healthcare IT vendors and professional services firms, CHIME provides an interactive environment enabling senior professional and industry leaders to collaborate; exchange best practices; address professional development needs; and advocate the effective use of information management to improve the health and healthcare in the communities they serve.
Congresswoman Renee Ellmers (R-NC-02) released the following statement after introducing H.R. 5481 – The Flexibility in Health IT Reporting (Flex-IT) Act of 2014:
“Healthcare providers have faced enormous obstacles while working to meet numerous federal requirements over the past decade. Obamacare has caused many serious problems throughout this industry, yet there are other requirements hampering the industry’s ability to function while threatening their ability to provide excellent, focused care.
“The meaningful use program has many important provisions that seek to usher our healthcare providers into the digital age. But instead of working with doctors and hospitals, HHS is imposing rigid mandates that will cause unbearable financial burdens on the men and women who provide care to millions of Americans. Dealing with these inflexible mandates is causing doctors, nurses, and their staff to focus more on avoiding financial penalties and less on their patients.
“The Health IT Reporting Act will provide the flexibility providers need while ensuring that the goal of upgrading their technologies is still being managed. I’m excited to introduce this important bill and look forward to it quickly moving on to a vote.”
Congresswoman Renee Ellmers introduced H.R. 5481 – the Flexibility in Health IT Reporting Act of 2014. The legislation would allow healthcare providers to receive the flexibility they need to successfully comply with meaningful use program.
On August 29th, the HHS published a short-sighted final rule, maintaining a provision that requires providers to perform a full-year EHR reporting period in 2015. According to Ellmers, “The Flex-IT Act will allow providers to report their health IT upgrades in 2015 through a 90-day reporting period as opposed to a full year. This shortened reporting period would be an important first step in addressing the many challenges faced by doctors, hospitals and other medical providers due to the inflexible mandates of the meaningful use program.”
Breaking news hits the wires from the College of Healthcare Information Management Executives (CHIME), which has responded to a recent query by a group of six Republican senators who are hell bent on slowing down the meaningful use program to ensure its operating efficiently and not just handing out money to everyone claiming they’ve met Stage 1 (and eventually the other stages).
What’s remarkable about the news, though, is that CHIME actually issues a letter calling for a one-year extension of meaningful use Stage 2. According to CHIME’s letter, as reported by Healthcare Informatics,