Policy Committee Wants Many Changes to MU

Paul Tang, M.D., Chair, Meaningful Use Workgroup

Most healthcare providers will be happy to hear that the federal health IT Policy Committee isn’t content with the proposed definition of what constitutes the meaningful use of e-health records. Though that doesn’t mean it’s getting any easier to qualify for the stimulus funds that will reimburse healthcare providers for EHR investments.

That’s largely because the committee—a panel that advises Dr. David Blumenthal, the Department of Health And Human Service’s national coordinator for health IT—is adding as much to the requirements as it’s taking out of the rules that will determine whether a health care provider qualifies for stimulus funds. In fact, the committee isn’t really taking anything out, but rather recommending more flexibility. Dr. Paul Tang, M.D., chief medical information officer at Palo Alto Medical Foundation and chair of the committee’s Meaningful Use Workgroup, proposed that providers be allowed to defer up to three measures until later years, while still qualifying for cash after meeting Stage 1 requirements, for example. No requirements involving privacy or security requirements would qualify for deferral. None of the current requirements will be taken off the table, Tang said, meaning providers would still have to work towards achieving every metric.

Committee member Christine Bechtel, VP of the National Partnership for Women and Families, suggested that a better approach might be to require pursuit of all measures, but lower the percentage of compliance required within individual areas. That approach would mean no organization could completely leave any one measure by the wayside for any period of time, Bechtel said.

Though it’s unclear which approach the committee will ultimately recommend, there’s no doubt some modification is supported.

That step on its own would offer an easier path to qualifying for the stimulus monies. But the Workgroup went on to recommend that several other measures be added into the proposed requirements. Some of those additions were ones Blumenthal’s office originally recommended but weren’t included in proposed requirements. Among those recommendations are:

Reinstate requirement to include progress note documentation to be eligible for Stage 1 reimbursement
Remove “core measures”—(quality measures that could apply to virtually all eligible providers) — from Stage 1
Reinstate recommendation to stratify quality reports by disparity variables, such as race, ethnicity, gender, primary language, and insurance type
Require providers to maintain up-to-date problem lists (not just one-time entries) of key patient summary information in EHR
Reinstate recommendation to include recording of advanced directives—instructions for care after a patient can no longer communicate—for Stage 1 eligibility
Reinstate recommendation to include patient-specific education resources for Stage 1
Reinstate recommendation to include clinical efficiency measures—such as percentage of all medications entered into the EHR as a generic formulation, when generic options exist in relevant drug class — for Stage 1
CMS should create a glidepath, or strong signal of intentions, for Stage 2 & 3 MU so vendors and providers can create more appropriate five-year strategic plans
Amend prevention/follow-up reminders criterion to allow for provider discretion in targeting. This would allow, for example, communities to select the reminders most relevant to the predominant health issues of their local populations
Clarify “transitions of care” as those which occur when a patient changes “setting of care” (e.g., hospital, ambulatory primary care practice, ambulatory specialty care practice, long term care, home health, rehabilitation facility) and delete the term “relevant encounters,” which is imprecise
Computerized physician order entry orders should be done by authorized providers

Regarding the last measure, a spirited discussion of just who is an authorized provider in an academic medical center ensued. That’s because in many of those organizations, nurses, pharmacists, students, and residents enter orders. When the person making the ordering decision isn’t a legally qualified provider, the order is reviewed by someone who is. The question becomes: does the individual reviewing the order need to be exposed to the clinical decision support rules which an EMR provides?

As happens generally in such meetings, important questions like these were brought to light, debated, recognized as important, and left unresolved.
Other important points of discussion took place around:

The fact that providers will be required to develop manual processes to report on many of the measures.
Most EMRs being unable to produce the quality metrics that the proposed Meaningful Use rules would require.
Health and Human Services having yet to issue the proposed rules on certification of EHR systems, contributing to anxiety among vendors and provider around timelines for qualification.

Paul Egerman, co-chair of the Workgroup on Adoption and Certification, recommended vendors look to the recently released Interim Final Rule on initial standards, implementation specifications, and certification criteria for EHR technology to direct them until further certification guidance is issued.

Regarding the delay—the proposed rules on certification were expected in January — he said byzantine government requirements are to blame. “This is an unbelievably complicated area. IRS, SEC and antitrust issues are nothing compared to the extraordinary complexity of this rulemaking process.”

Additional Meeting Materials:

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