On May 28, HIMSS submitted comments to the Department of Health and Human Services on the meaningful use Stage 3 proposed rule and the 2015 Edition Health IT Certification Criteria. The two letters, sent to Acting CMS administrator, Andrew Slavitt, and National Coordinator for Health IT, Dr. Karen DeSalvo, respectively, strongly urge CMS and ONC to:
Decrease the prescriptive nature of the EHR Incentive program,
Increase focus on the substantial capabilities established earlier in the program, and
Reduce complexity in the 2015 Certification Criteria.
HIMSS voiced its continued support for the meaningful use program as a tool to positively transform health and healthcare in the United States. Identifying meaningful use as a “critical tool for enabling healthcare transformation,” the response cites HIMSS Analytics data – collected annually on all non-federal US hospitals, and more than 30,000 tethered US ambulatory facilities – that “70 percent of hospitals have made a positive progression in the advancement of their EHR capabilities over the last five years, with more than 60 percent of ambulatory facilities showing similar progress in the last three years.”
HIMSS reiterated its long-standing commitment to interoperability: “HIMSS is committed to a culture in which IT is fundamental to transforming healthcare; improving quality of care, enhancing the patient experience, containing cost, improving access to care, and optimizing effectiveness of public payment.”
HIMSS remains strongly committed to making the Electronic Health Record Incentive program less prescriptive and more focused on encouraging and assisting providers to take advantage of the substantial capabilities established in Meaningful Use Stages 1 and 2, including interoperability.
HIMSS applauds a proposal in the NPRM for a single definition of Meaningful Use starting in calendar year 2018, no matter when a provider began to participate in the EHR Incentive Program.
HIMSS supports the work being done by CMS to align the EHR Incentive Program with other CMS quality reporting programs that also use certified health IT. HIMSS believes such efforts will lessen the burden on providers.
HIMSS is committed to ensuring patient safety remains paramount to the development, implementation, and wide-spread use of health IT systems.
HIMSS reiterates its long-standing assertion that 18 months is the minimum length of time needed between the final rules on Meaningful Use, certification, and standards, and the start of any stage of Meaningful Use. An 18-month timeline allows stakeholders to help educate and prepare providers on the upcoming new stage. The current timeline for transitioning to Meaningful Use, Stage 3 in 2017 and 2018 does not include 18 months.
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
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
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.”
Seems all the chittering was right: The meaningful use Stage 3 proposed rule has been released prior to the annual HIMSS conference, to give all conference goers and government officials in attendance something to talk about.
The news of the rule’s release now comes as no surprise.
The feds like to make these kinds of splashes, to be the bearers of news – any kind of news – especially at big venues where they’re likely to get lots of ink and face time with those in attendance, and the supposed powers that be.
The same thing happened last year at HIMSS when officials, peppered with questions, were vehement that the ICD-10 roll out deadline would not be delayed. Only a few weeks later, federal officials had to walk that back and, untimely, wound up changing the deadline.
These are apples and oranges, I understand, but the grandiosity of the occasion (HIMSS15) means that everyone attending the conference really does need to “bring it.” Vendors, presenters, the feds. At HIMSS, to capture hearts and minds, this is a simple truth — we need to bring it no matter who “we” are.
I’m not trying to be cynical about the announcement or the timing of the proposed Stage 3 rule, but there seems to be something about the nature of its timing that seems suspect. It’s as if CMS wants the news about meaningful use to be relevant. But, as we know, on its own, it is relevant; we all know this.
It’s as if CMS is trying to secure the legacy of a failing program – where as of January 0nly 4 percent of eligible professionals had met meet Stage 2 requirements. It’s sort of like the agency, to make people talk about a once relevant product, is bursting through the HIMSS gates like a has-been celebrity and is announcing, “Don’t worry, we’ll be there.”
How could we forget?
We know you’ll be there, we know we’ll be looking to you for guidance, we know what you have to say is important to us because it impacts the very professions in which we have built our lives.
CMS will make their claims, get us to talk then they’ll ride off into the sunset like Shane.
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.
Guest post by Darin VanderWell, Director of Product, DocuTAP.
Rumors about the next phase of the Centers for Medicare and Medicaid Services (CMS) EHR Incentive Program has prompted concern among healthcare providers. To truly understand meaningful use Stage 3 and its impact, it is important to differentiate between the rumors and the truth.
The final rule for meaningful use Stage 3 has yet to be published, so discussion on its effects are based on available drafts. Even those drafts are in question since the December 2013 announcement that Stage 3 would be delayed until 2017. One reason cited was to allow more time to research the impacts of Stage 2 before finalizing Stage 3. The delay will be particularly important for that research, since compared to Stage 1, 2011 Edition, there are so few Stage 2 vendors certified currently.
As for what is expected, the attention turns from data capture and access (Stage 1) and information exchange (Stage 2) to improved outcomes in Stage 3. One expected goal is to simplify and reduce the reporting requirements on those attesting. Some of that change can be achieved by consolidating the program’s current objectives, which I expect hospitals and providers will welcome, provided it truly reduces the reporting burden and does not coincide with other, new objectives and reporting requirements.
Stage 3’s goal of improving outcomes will be incredibly interesting – through November 2013, CMS had disbursed nearly $18 billion in incentive payments. Until now, the program’s success has been judged by the number of participants adopting certified EHRs. At some point during Stage 3 (or thereafter), we will know whether those payments have truly improved outcomes.
