EHR and Health IT Consulting
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EHR and Health IT Consulting
Technical Doctor's insights and information collated from various sources on EHR selection, EHR implementation, EMR relevance for providers and decision makers
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OMB Reviewing Proposed Stage 3 Meaningful Use Requirements | EHRintelligence.com

OMB Reviewing Proposed Stage 3 Meaningful Use Requirements | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it

The Centers for Medicare & Medicaid Services is one step closer to issuing a notice of proposed rulemaking (NRPM) for the next stage of meaningful use requirements for the Medicare EHR Incentive Program.

The Office of Management and Budget (OMB) is currently reviewing the proposed rule for Stage 3 Meaningful Use that is expected to be published in February.

Few details about the requirements for Stage 3 appear in the rule submitted to the OMB by the Department of Health & Human Services as part of the Unified Agenda — that is, with the exception of the following:

In this proposed rule, CMS will implement Stage 3, another stage of the Medicare and Medicaid EHR Incentive Program as required by ARRA. We are proposing the Stage 3 criteria that EP’s, eligible hospitals, and CAHs must meet in order to successfully demonstrate meaningful use under the Medicare and Medicaid EHR Incentive Programs, focusing on advanced use of EHR technology to promote improved outcomes for patients.  Stage 3 will also propose changes to the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements.

The rule before the OMG also indicates that CMS will coordinate with the Office of the National Coordinator for Health Information Technology to ensure that EHR certification criteria and certified EHR technology will be in place when Stage 3 goes into effect no earlier than 2017.

During a Health IT Policy Committee meeting in March, the group voted to approve 19 objectives recommended by the Meaningful Use Workgroup. Those recommendations fall into four categories of care improvements:

Improving Quality of Care and Safety
1. Clinical decision support
2. Order tracking
3. Demographics/patient information
4. Care planning — advance directive
5. Electronic notes
6. Hospital labs
7. Unique device identifiers

Engaging Patients and Families in their Care
8. View, download, transmit
9. Patient generated health data
10. Secure messaging
11. Visit Summary/clinical summary
12. Patient education

Improving Care Coordination
13. Summary of care at transitions
14. Notifications
15. Medication reconciliation

Improving Population and Public Health
16. Immunization history
17. Registries
18. Electronic lab reporting
19. Syndromic surveillance

Before any of the proposed rule’s requirements for Stage 3 Meaningful Use are enacted, the NPRM must made available for public comment which has the potential to influence the requirements of the final rule. Given the resistance CMS has faced as a result of Stage 2 Meaningful Use, the federal agency is likely to receive requests for greater flexibility and timing from healthcare organizations and industry groups.


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Time for Government to Step Out of the Way of EHR and Let the Market Takeover? | Hospital EMR and EHR

Time for Government to Step Out of the Way of EHR and Let the Market Takeover? | Hospital EMR and EHR | EHR and Health IT Consulting | Scoop.it

The always interesting and insightful John Moore from Chilmark research has a post up that asks a very good question. The question is whether it’s time for the government to get out of the EHR regulation business and let the market forces back in so they can innovate. I love this section of the post which describes our current situation really well:

But as often happens with government initiatives, initial policy to foster adoption of a given technology can have unintended consequences no matter how well meaning the original intent may be.

During my stint at MIT my research focus was diffusion of technology into regulated markets. At the time I was looking at the environmental market and what both the Clean Air Act and Clean Water Act did to foster technology adoption. What my research found was that the policies instituted by these Acts led to rapid adoption of technology to meet specific guidelines and subsequently contributed to a cleaner environment. However, these policies also led to a complete stalling of innovation as the policies were too prescriptive. Innovation did not return to these markets until policies had changed allowing market forces to dictate compliance. In the case of the Clean Air Act, it was the creation of a market for trading of COx, SOx and NOx emissions.

We are beginning to see something similar play-out in the HIT market. Stage one got the adoption ball rolling for EHRs. Again, this is a great victory for federal policy and public health. But we are now at a point where federal policy needs to take a back seat to market forces. The market itself will separate the winners from the losers.

His points highlight another reason why I think that ONC should blow up meaningful use. In my plan, I basically see it as the government getting out of the EHR business. I do disagree with John Moore’s comments that the government should step away from interoperability. If they do, we just won’t have interoperability. I guess he’d make the argument that value based reimbursement will force it, but not in the same way that the rest of the EHR incentive money could force the issue.

I have learned that to really get out of this game or even do what I describe will take an act of congress. HHS can’t do this without their help. Although, they could get pretty close. Plus, maybe they could exert their influence to get congress to act, but I won’t be holding my breathe on that one.


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