Updates on Proposed Stage 2 and 3 Meaningful Use Criteria

The Health IT Policy Committee has published proposed Stage 2 and 3 Meaningful Use Recommendations and they’re open for public comment until February 25.

I’ll share a couple of particularly useful and well written analyses and commentaries by colleagues.

Health IT guru and thought leader Dr. John Halamka writes about The Proposed Stage 2 and 3 Meaningful Use Recommendations.

This is a great article to get a thumbnail overview of all the proposed recommendations. John lists 38 criteria and provides a quick commentary on how challenging he sees each of them. (Keep in mind that he’s CIO at one of the most HIT-advanced health systems in the country — your definition of “easy” and his might not be alike.)

It caught my eye that the more challenging criteria generally are ones involving inter-organizational health data exchange, care coordination and care management. See his comments on the following criteria: 7, 17, 20–21, and 23–34.

Dr. Halamka concludes:

…areas of concern are chemotherapy automation, recording patient communication preferences, judging clinician performance based on patient adoption of PHRs, EMAR implementation, maturity of HIE capabilities,  widespread rollout of longitudinal care planning, and public health readiness.

Writing on the Practice Fusion company blog, Dr. Robert Rowley comments on Stage 2 Meaningful Use – what should it look like? He offers several provocative, out-of-the-box perspectives on how Stage 2 MU might change broader market dynamics:

Stage 2 is not merely an enhancement of Stage 1 – that would reduce it to simply “Stage 1a” – but instead is a whole new level….Stage 2 is about connectivity. Now that EHRs are adopted, implemented and used meaningfully, the next stage is intended to be about connecting the silos together. Stage 3, to come later, will be about inserting Decision Support between the connections, so that best practices (as well as authorizations) become part of the daily fabric of health care.

…small-scale ambulatory practices have disproportionately taken up web-based EHRs. Quite literally, tens of thousands of clinicians, especially in practices less than 10 physicians, and especially primary care practices, have chosen web-based EHRs as their preferred path to demonstrating Stage 1 Meaningful Use. In fact, it is conceivable that the whole small-size layer of health care delivery will be aggregated using web-based tools.

This turns the “center” of health IT around – no longer is the local hospital the de facto standard for local community docs. Instead, the web-based EHR, deployed nationally and capable of interfacing with a single, true standard, becomes what local hospitals, labs and HIEs need to be able to connect with. The challenge is with the legacy systems, and all their local variations – their ability to adopt true, national standards is the rate-limiting step for connectivity

Connectivity with patients will be more likely to emerge than connectivity to hospitals. Connected EHR-PHR systems will connect clinicians to their patients, and allow reporting of lab results, self-service options for access to one’s own health data and health education resources, and emergence of secure two-way messaging between the clinician and the patient…. Connection with patients will be through web portals, but also a myriad of mobile tools will allow two-way flow of data.

Given that connectivity with patients will likely emerge in a more robust way long before connectivity with local hospitals, it is likely that the patient, via their PHR, will be the conduit for health data exchange.

Wow! Great food for thought.

Vince Kuraitis JD, MBA, is a health care consultant and primary author of the e-CareManagement blog where this post first appeared.

6 replies »

  1. Reimbursement for for an office visit (99214) using modifier -25 ( smoking education) has not been recognized by Medicare and proper reimbursent denied. Where can I find specific coding instructions and a “help” site? ….thanks in advance for your time….Rich

  2. I agree that there is a strong trend of hospitals acquiring community physician practices, and pushing their HIT onto these practices as part of the effort. Health care deliver IS local, I agree. And data sharing between practices (in the formal or informal referral networks of the community surrounding a practitioner) is local – but with web-based HIT, if those practices are on the same platform, then sharing a chart (or pieces of a chart) can be done without the need to go through an HIE. We are building this functionality now, and will likely be something successful earlier than chart sharing via HIEs.
    The rate-limiting step is the extent to which local HIEs conform to the exact-same data standard. Our experience with labs has been that each lab uses slightly different interpretations of the same HL7 “standard,” and a good deal of customization is needed for each integration. If this pattern were to continue with HIE integrations, with customization needed for each and every one, then there are roadblocks. As a national web provider, we need standards that are truly standard, so that “local customization” is not necessary for each integration. For that reason, recognizing that it will take time for such standards to mature (hopefully Accenture will help with this), my belief is that peer-to-peer in-product chart sharing, as well as doctor-patient connectivity via a linked EHR-PHR will likely emerge earlier than meaningful HIE connectivity.
    I actually hope I’m wrong about this, and a true set of standards that allows plug-and-play integration with HIEs and labs (without the need for customizations each time) will emerge rapidly. I’m not holding my breath, though.

  3. Margalit, I certainly share your concern about the scenario of hospital dominated HIT. The first round of ACOs from Medicare is a shared savings model, which provides hospitals with only very weak incentives to get at the excessive costs of ER visits, admissions, and procedures.
    I labeled Dr. Rowley’s scenario as provocative and out-of-the-box…and I’d add “plausible but not the most likely scenario” to play out at this point.

  4. I don’t know about the “center” of HIT moving to national EHR vendor “clouds”. What I am seeing is small practices either being bought out by hospitals or accepting EHRs from hospitals, which is indeed hosted in a “cloud”, but it is the hospital private cloud, or “HIE” (none of these EHRs are truly web-based). In all fairness, connectivity to local hospitals and local providers is much more valuable to a private practice than connectivity to other practices located 5 States away. Health care IS local.
    Just like vendors did, hospitals have realized that data is going to be the most valuable asset down the road.
    Add to this the ACO frenzy and the various payment bundling schemes, and it seems to me that we are quickly approaching a completely Hospital dominated health care system, and HIT as a result.
    Not to mention that the largest HIE vendors are owned by payers now and they also offer EHR functionality, so perhaps this is where the data “center” is going to end up.

  5. “Given that connectivity with patients will likely emerge in a more robust way long before connectivity with local hospitals, it is likely that the patient, via their PHR, will be the conduit for health data exchange.”
    By 2013? Not a chance.