There will be many blogs and news reports, on Health Affairs Blog and elsewhere, about the very-soon-to-be-released Stage 2 proposed rules on the Meaningful Use of electronic health records (EHRs). This report is more impressionistic. The message of the proposed rules, delivered to a packed house yesterday at the HIMSS conference in a pre-release presentation by the Office of the National Coordinator for Health Information Technology and the Centers for Medicare and Medicaid Services, is Interoperability. Safety. Patient engagement. Incremental advancement that will still be a stretch. A request for robust comments, the good and the bad.
The presentation by ONC and CMS was mostly directional, although there were some specifics. More to come when the Rules are released.
There were congratulations to healthcare providers and health IT vendors for their success to date with Stage 1. The Stage 2 Rules build on Stage 1. To quote the health IT national coordinator Farzad Mostashari: “Continuing what’s in Stage 1 and getting better at it.”
There were also thanks to the Health IT Policy and Standards Committees for their recommendations, and for the process of public hearings and discussions. Those recommendations were a key contributor to the Rules, although sometimes dissenting voices were listened to, as in the continued use of menu options.
There will be a heightened emphasis on interoperability, actual exchange ,and clarity of standards (standard = 1 choice, for example, problem lists coded in SNOMED, medications in RxNorm, care summaries in Consolidated CDA). While Stage 1 focused on use within a setting, Stage 2 looks to connect settings. Public health reporting will also expand and professional society disease registries will be included. Direct will join CONNECT as a required communication protocol. In this case, two options.
There will be expanded patient engagement and the sharing of information with patients. There will be an emphasis on usability and safety. This will include technology-assisted medication administration (presumably barcodes or other technologies) and expanded computerized physician order entry, or CPOE.
There will be better alignment of Quality Measures across Federal initiatives and better automation on the QMs from clinical documentation. The definition of Certified EHR Technology will mature. The criteria will be grouped into:
1. Base EHR
2. Meaningful Use Core
3. Meaningful Use Menu
This grouping of criteria is a conceptual architecture. It was presented as three concentric circles with Base EHR at the center. EHR software will continue to be certified as Complete or Modular. Providers will have the flexibly to only have the components that are necessary for their Meaningful Use menu choices.
ONC and CMS were clear that they want robust comments, positive and negative. To make it easier for us, they will be releasing a Word version of the proposed rules and various tables and grids, as well the usual pdf versions. They will also be supplying templates to better structure the comments to facilitate compiling them for response in the Final Rules.
After at long wait, the Proposed Rules are almost here. But of course, the devil and the angel will be in the details of the Final Rules, and they are still months away.