As so many users have learned, new technologies, whether EHRs, smartphones, tablets, or personal health devices, can and should be a source of liberation, efficiency, and even pleasure. Health IT technology developers, like GE, work hard to delight our customers, using the latest tools (e.g., the “cloud,” mobile, agile development, “lean startup” product development, user centered design, and new interoperability standards and models) to identify priority problems and to develop innovative and highly usable health IT to solve these problems. As discussed in Part 1 of this post, we need to quickly move out of the cul de sac of product design by federal committee and regulation and back onto the highway of technology innovation. To do so, we should fundamentally rethink the approach to meaningful use and certification, including the approach under development for Stage 3 by the HIT Policy Committee.
Overall, CMS and ONC should take a very focused and prioritized approach to Stage 3, emphasizing deeper use of Stage 2 requirements and related EHR capabilities, considering usability implications of potential new requirements, as well as needed enhancements for interoperability (using mature and tested standards) and care coordination. The meaningful use balance, which has under-emphasized the importance of adoption as an end in itself, should shift away from detailed use and functionality requirements, with provider decisions on “meaningful use” following from the outcomes-linked drivers of value-based payment and accountable care incentives, including those in the Medicare physician payment “SGR fix” being actively developed by the Congress.
New and emerging technologies needed to support integrated and accountable care and payment reform need to develop in an atmosphere of innovation, outside of functionality-focused certification requirements. Although EHRs will provide essential support for these needs, not all relevant health IT will or should be part of the EHR, especially with “EHR” defined by federal policy rather than market dynamics. In contrast, the latest proposals under consideration by the Health IT Policy Committee would add a large number of new meaningful use and especially certification requirements (in some cases, as with Stage 2, “certification only,” without a corresponding meaningful use requirement), many of which are neither central to value-based payment nor reflective of provider priorities. Notably, it seems to be becoming clear to providers that “certification only” is not cost-free, and can lead to addition of non-priority features, with all of the attendant negative implications
In addition, based on learnings from Stages 1 and 2, it is critical that, ONC and CMS finally allow enough time from when final regulations and all associated specifications and guidance are available and when the next edition of certified EHRs must be implemented and used.
Meaningful use has been successful, and it will remain important for at least the near-term to support and incentivize EHR adoption and use. But, with CMS recently pushing out by a year the expected initial start of Stage 3 to 2017, we should use this time and opportunity to shift focus, beyond Stage 2, to a simpler and more powerful approach to EHR and HIT adoption, grounded in how other areas of technology have advanced.
We need a fresh look at the way forward, one that recognizes that market-driven innovation is advancing more rapidly and flexibly than can be managed through regulation/certification. It would therefore be enormously valuable to hold one or more “summits” at which key stakeholders, including government policymakers, vendors, employers, and consumers, could re-examine the landscape, recognize all we have achieved in recent years, and realign for a smart course beyond Stage 2.
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