The clock is ticking down to the deadline for comments (January 14, 11:59 pm ET) on the Health Information Technology Policy Committee (HITPC) Stage 3 Meaningful Use draft recommendations. Many readers of the AmericanEHR blog are undoubtedly involved in reviewing the objectives/metrics and some are hurrying to finalize a submission to the Office of the National Coordinator. To that end, I offer five questions and a few ideas regarding Stage 3 for your consideration and comments. I can’t be sure if ONC will read what you post here, but feel free to use this forum as your sounding board.
Stage 1 and Stage 2 focused on driving health care professionals to adopt certified EHR technology (CEHRT) and to capture information in structured format with the goal of leveraging those building blocks to improve quality, reduce costs, and improve patient experience in future stages of MU. Without the structured data elements, it would be difficult to incorporate relevant clinical decision support systems, population management features, etc. Should Stage 3 continue to add new requirements for collection of these elements — or should Stage 3 focus on quality and other complex measures that can only be met by attaining adequate performance on prior Stage 1 and Stage 2 metrics?
If your response to Question 1 is “yes” then should the number of structural measures of conformance with data collection and specified work flows be reduced or eliminated?
Is it necessary for any Stage 3 measure (or any measure from prior stages) to be specified to the extent that it essentially prescribes a particular work flow based on the requirements — or should measures focus on the quality of care provided as determined by reporting on clinical quality measures, which, in turn, depend on appropriate (meaningful) use of CEHRT functions? Would a focus on clinical measures encourage eligible professionals (EPs) and hospitals (EHs) to innovate around these goals?
For the most part, the Stage 3 recommendations are associated with new certification requirements (as in Stages 1 and 2) — which means that EHR vendors will once again need to build and test new features/functions in time for EPs and EHs to use these new capabilities for Stage 3. Should the certification requirements for new EHR functionality be separated from the requirement that EPs and EHs use these new functions in practice? Would disconnecting the lock step “build and use” process help ensure that new features are ready for implementation in the care of patients?
The list of measures for Stage 3 continues to grow. Would identifying a smaller set of “foundational” EHR functions (i.e., must pass elements) assessed by appropriately specified metrics plus a core set of specialty and practice/location specific clinical quality measures meet the goals of MU? Would such an approach be more relevant to clinicians and their teams?
This post is the personal opinion of the author and does not necessarily reflect the official policy or position of the American College of Physicians (ACP).