The HIT Policy Committee’s Meaningful Use Workgroup met this week to begin discussing the question that I posed at the end of my EMR Straight Talk post last week, i.e., how to reconcile the various stakeholders’ positions regarding Stage 2 meaningful use. Most of the feedback received by the workgroup in response to its request for comments relate to issues surrounding timing, with providers and vendors urging restraint, and consumer groups (representing patients and payers) pushing for more aggressive timelines.
Given the statutory constraints (i.e., changes to the law itself would require Congressional action, a path the workgroup will not pursue), the options are limited—and each carries consequences for the program’s long-term goals. The workgroup acknowledged the concerns of vendors regarding the time needed to adequately and safely develop and deploy any new required functionality. They also appreciated the impact on providers of the implementation and training demands associated with upgrading technology, particularly at a time when providers are facing other IT challenges such as ICD-10 and HIPAA 5010. The workgroup considered the following options:
Option 1: Slow down the program’s pace by not adding any new measures and functionalities to Stage 2, but merely increasing the thresholds related to Stage 1 measures.
Option 2: Delay the start of Stage 2 by allowing each provider more time at Stage 1 or by basing the initiation of Stage 2 on the overall level of provider compliance/success in Stage 1.
Option 3: Shorten the first year’s reporting period to 90 days when providers progress to Stage 2.
The workgroup identified the following as the problems associated with each of the above proposals:
Option 1 (no new measures) will not get the program where it needs to be rapidly enough. It does not advance the program past data capture and towards the program’s goals: interoperability; “advancing clinical processes” (the goal of Stage 2); or improving outcomes (the goal of Stage 3).
Option 2 (delay Stage 2) raised the concern that extending Stage 2 will set a precedent for delaying Stage 3. The dwindling financial incentives and the lack of positive incentives after 2016 could reduce interest in Stage 2 or make it difficult for the program as a whole to ever progress past Stage 2, given that there are no positive incentives available after 2016.
Option 3 (90-day reporting period) does nothing to resolve the vendors’ concerns about the timeline for development.
Another critical issue to be addressed is how to increase the relevance of the EHR program to specialists, which will be the subject of a special hearing on May 13—similar to the hearing that solicited their input for Stage 1. Of all of the stakeholders, physicians are the most critical to the attainment of the EHR program’s goals. Physicians—primary care and specialists alike—are the cornerstone of the program, and their participation beyond Stage 1 will depend on the development of a set of reasonable and achievable requirements.
A preliminary set of recommendations for defining Stage 2 meaningful use was released by the Meaningful Use Workgroup of the HIT Policy Committee earlier this month in the form of a Request for Comment—the deadline for comments is February 25. The decision-makers in Washington clearly realize the value of securing buy-in from providers, having received over 2,000 comments to the proposed Stage 1 rule when it was issued last year. As a result of those lobbying efforts, which included the Voice of the Physician Petition that we circulated on EMR Straight Talk, CMS made changes that accommodated the specialists and made participation realistic for them.
This is the opportunity for physicians to have a voice in Stage 2 before the final recommendations are submitted to CMS this summer. This request comes very early in the process of developing and finalizing the requirements—the workgroup will consider the comments and then present its recommendations to the HIT Policy Committee, which will review and revise and then forward them to CMS, which will issue the final rule. So for this stage, providers have the chance to provide input well before recommendations become set in stone.
Since most providers haven’t even embarked on Stage 1, and many are not yet conversant in the rules and requirements for that stage (as evidenced by the results of the Meaningful Use IQ Test), the following are highlights of the proposed recommendations. Note that clinical quality measures are not discussed—they will be the subject of a separate set of recommendations.
The proposal does not address the excludability of non-relevant measures. I assume its retention is implied, but it is important to comment on the need to keep these options in place. This was a very valuable modification added to Stage 1, particularly for specialists.
Disappointingly, Stage 2 still does not define meaningful use in a way that adds value for many specialists, and a way that will keep them engaged once the significant portion of the incentives have been collected.
Menu measures will become core measures, so the measures physicians choose to defer in Stage 1 will be mandatory in Stage 2. Some of these measures pose challenges for specialists, e.g. sending reminders to 20% of patients may not be reasonable for certain specialists such as orthopaedists or ENT physicians, because they provide episodic care.
Most of the changes involve increased thresholds for satisfying the measures, e.g., CPOE increases from 30% to 60%, ePrescribing from 40% to 60%, etc. These changes should not present a challenge since the software and relevant workflows will already be in place from Stage 1.
There are several new measures, such as adding lab or radiology to CPOE and including online secure patient messaging.
To voice your thoughts on this initial set of recommendations, go to www.regulations.gov and click “Submit a Comment”. Don’t say they didn’t ask!