CHIME’s message to the Office of the National Coordinator for Health IT is clear: slow down.
In its comments regarding the Health IT Policy Committee’s proposed measures for Stage 3, CHIME urged the federal advisory committee to recommend thorough evaluations of what has been accomplished so far in order to establish realistic measures and objectives.
“Every desirable EHR-related objective cannot feasibly be met by 2016,” the letter stated. CHIME also noted that it sees no value in trying to rush the EHR adoption by that time. Rather, “verifiable and continuous progress should be the goal.”
“One of our main messages to regulators is that we shouldn’t look to cram everything into Stage 3,” said Pam McNutt, SVP and CIO Methodist Hospital System and a member of CHIME’s Policy Steering Committee. “The modernization of America’s healthcare system is a decade-long progression. We need to make sure that the HIT Policy Committee is looking at more than just the Stage 2 measures and objectives when making recommendations to HHS.”
In response to proposed Stage 3 measures, CHIME is recommending the following:
Actual and proven HIE operations and interoperability, combined with a standard and highly-reliable way to identify patients, is mandatory to achieve the goals of Stage 3, and even stage 2. The time frames for Stage 3 should be linked to and preceded by proven HIE capabilities.
EHR certification requirements should yield vendor products that allow EPs and hospitals to fully and easily satisfy any meaningful use documentation and audit requirements — such functionality must be inherent to certified EHR technology. Audit measures should be standardized to be based clearly on the certification requirements, and not subject to auditor variation.
To help mitigate disruption from discontinuity in the EHR vendor space due to vendor business failures, vendor consolidation, decisions not to seek certification or performance problems, hospitals and health professionals that must undertake EHR product transitions at the same time that they are expected to progress from one stage of meaningful use to another should be granted protection or accommodation.
CHIME also noted that the same efforts that have been made to harmonize disparate health IT system requirements, technical standards, and disseminate best practices need to be applied to clinical quality measures (CQMs).
The organization is urging regulators to keep a handful of fundamental tenets in mind with regard to CQMs: future measure sets should always tie back to care delivery quality and clinical efficacy; they should be expansive enough to allow clinical flexibility based on population characteristics; and regulators across federal, state, local and private sector reporting organizations should convene to understand what collection and reporting requirements will allow for optimal care quality improvement.
“Even minute changes to specifications can present tremendous workflow and monetary burdens on providers,” said Liz Johnson, vice president of Applied Clinical Informatics at Tenet Healthcare. “A sensible approach to future measure set development allows for evolution in technology in a way that minimizes such burdens on providers. We need a concerted effort in the near-term that improves data collection, abstraction and reporting on current generation CQMs. This effort should include an absolute focus on harmonizing the current data specifications for similar measures.”