Weighing in on meaningful use proposed Stage 2 rules


It would be one thing for me to weigh in on the proposed rule for Stage 2 meaningful use, which was released last month. Indeed, there are some interesting progressions in the core criteria, which emphasize the phased approach and its potential long-term effectiveness. We will look at a few of those specifically relating to HIE engagement later in this post.

But far more important than my summary of the proposed rule is your feedback. Just as the ONC did with the Stage 1 proposed rule, they have enabled a 60-day public comment period on the proposed rule for Stage 2, which began at the beginning of March. This is where you, the provider, come in.

In a talk with members of the American Medical Group Association at their annual conference, the ONC’s national coordinator for health information technology, Dr. Farzad Mostashari, gave a compelling and perhaps underappreciated case for maintaining the open line of communication between providers, the ONC, and EHR vendors, which is largely facilitated through the Centers for Medicare & Medicaid Services (CMS) EHR Incentive Program. With meaningful use rules in place, a new precedent for EHR functionality criteria is determined in order for any EHR to be meaningful use-certified. Simply put, that means the meaningful use rules are driving current and future EHR functionality modifications. 

And so, the provider has two choices: (1) fall in line with the meaningful use criteria, meet the necessary thresholds, report it to CMS, and receive a check in the mail; or (2) drive the final decision on meaningful use criteria according to what you need in your EHR in order to improve care for your patients, then meet the criteria and get your check, etc. As the provider of care, you are the only true source for this critical information.

Mostashari understands this – and that’s why he wants you to do the driving.

The opportunity comes at a time where all health information technology policy still seems to be fluid and susceptible to change. The physician perspective is more important than ever because it will lay the policy foundation potentially for generations of physicians to come.

Click here to follow instructions on providing feedback to the proposed rule for meaningful use Stage 2.

And if you haven’t had a chance to look at the proposed rule yet, you can do so here.

As you will see, there is a clear push toward interoperability with fellow healthcare providers and organizations as well as patients in Stage 2. And from our perspective, connecting to an HIE is more important now than ever. 

One of the main differences between Stage 1 and Stage 2 is that organizations must go from testing their ability to trade data with other providers, to actually exchanging the information.  Hospitals and eligible professionals (EPs) will have to send clinical summaries to providers using disparate EHRs, and that can be most easily facilitated through an HIE. Additionally, hospitals and EPs will have to provide a specified summary of care record for at least 65 percent of transitions of care and referrals. 

These are just a few of the changes coming your way. The push to Stage 2 will do much to define our future healthcare practices as well as the future of local and regional HIEs. Take the time now to understand the proposed rule so you can react, respond, and prepare.

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