The Meaningful Use Stage 2 Final Regulations are out. My eyes have about glazed over after reading most of 1146 pages in the “readable,” single column format. These regulations are long and complicated and they should also advance broader and more robust use of interoperable electronic health records and other healthcare IT (HCIT).
As always with new regulations, there are many analyses of what they mean and how physicians and hospitals should respond. These are absolutely worth reading, however I also emphasize that providers and others should look to the “source” for authoritative interpretations – Centers for Medicare and Medicaid Services (CMS) on Meaningful Use and Office of the National Coordinator for Healthcare IT (ONC) on product certification and standards.
Over the coming weeks and months, we can expect CMS and ONC to issue guidance, specification sheets and FAQs. We can also expect them to accelerate and improve delivery of such information, based on their Stage 1 experience and feedback from providers and vendors.
In reading, and re-reading, these many pages, I’ve reached a few conclusions.
First, it pays to take the time to comment on proposed regulation and sometimes, to press hard for your views. CMS and ONC clearly read, considered, and responded to the many, many comments – CMS received 6,100 “timely” comments. CMS and ONC made numerous changes based on these comments, covering such critical areas as CPOE, clinical decision support, patient engagement, “payment adjustments” for not being a meaningful user, and interoperability. They did not always agree with comments but they gave them thorough consideration.
Of special note, not only did CMS finalize its proposed one-year delay in the start of Stage 2 (to October 1, 2013 for hospitals and January 1, 2014 for physicians and other eligible professionals), it agreed with urgent comments from GE Healthcare and other stakeholders to allow all providers a shorter “reporting period” in 2014 and not to require them to report for 12 months even if they are past their first year of meaningful use. This critical change will make a still very tight timetable more workable by allowing upgrade “load balancing” through 2013 and 2014, given that all meaningful users in 2014 must use “2014 edition” certified EHRs that will reflect these Stage 2 regulations.
Second, Stage 2 Meaningful Use for providers and “2014 edition” EHR certification are clearly designed to support broader federal and private sector agendas for payment and delivery reforms. These include accountable and integrated care, value-based payment, and related supporting areas like quality reporting, population management, patient engagement, evidence-based medicine, and standards-based interoperability. This linkage should position providers to benefit clinically and financially from their meaningful use investments well beyond federal meaningful use incentives through participation in ACOs, value-based payment, and other innovative models of payment and delivery.
Third, building on the prior point, we are fast approaching the point where we may want to take a different approach to future stages of Meaningful Use. Building on the approach that the federal government’s Shared Savings ACO regulations took, perhaps Meaningful Use and other federal programs leveraging HCIT should, in Stage 3 and certainly beyond Stage 3, focus less on detailed, escalating requirements and more on goals and outcomes that can best be met with EHRs and other HCIT, while leaving it to providers and vendors to define specific needs and requirements, fostering innovation, speed to market, and flexibility.
Finally, “modular” certification in the Stage 2 regulations reminds us that, as foundational as are robust EHRs to a “wired” healthcare system, they are not the only type of HCIT needed to support Meaningful Use and accountable/integrated care or that are encouraged by Federal regulations. ONC’s revised “2014” approach to “modular” certification encourages providers to meet specific meaningful use objectives with types of HCIT other than “Complete” EHRs, such as departmental solutions and specialized modules.
ONC is also clear that not all applications that contribute to Meaningful Use must be certified, for example revenue cycle applications can feed EHRs demographic data and non-certified departmental functionality can send interfaced data to EHRs for quality reporting and meaningful use. In addition, the new requirements for online provider access to images through EHR technology do not require that PACS be certified but, at the same time, will encourage high-value links between EHRs and PACS. Finally, as we look to accountable care and other value-based models, providers will need robust and enhanced revenue cycle applications well as more specialized functionality, such as analytics.
In sum, Meaningful Use and emerging payment and delivery programs are creating an accelerated ecosystem of innovative, interoperable HCIT that extends well beyond their formal scope. And that is a good thing and well worth a few days of tired eyes.
“Please note, this post reflects my personal opinions, beliefs and thoughts and does not represent the official views of GE Healthcare”
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