Life Science Compliance Update

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December 06, 2012

HHS Offers Look into the Future for Meaningful Use Stage 3

Doctor Cristal Ball
One of the central pieces to the Affordable Care Act (PPACA), along with the American Reinvestment and Recovery Act (ARRA) was the implementation and “meaningful use” of electronic health records (EHRs)—through the HITECH provision.  Consequently, the Office of the National Coordinator for Health IT's (ONCHIT) HIT Policy Committee has released a copy of its proposed recommendations for public comment. 

Under the 2009 federal economic stimulus package, health care providers who demonstrate meaningful use of certified electronic health record systems can qualify for Medicaid and Medicare incentive payments.  The final rules for Stage 3 of the program are expected to take effect in 2016. 

The 38-page document, unveiled at the committee’s meeting Nov. 7, recommends some of the percentage thresholds be increased and suggests several new objectives for stages beyond Stage 3.  Some of the provisions new to Stage 3 include offering patients the capability to submit patient-generated information, and to request amendments to their records online, requiring electronic health records to receive, generate or access appropriate immunization recommendations, and requiring EHRs to be able to query other entities for outside records. 

One recommendation would require participating hospitals and physicians to “provide 10% of patients with the ability to submit patient-generated health information to improve performance on high-priority health conditions and/or to improve patient engagement in care.”  The committee also is seeking input about: 

  • Whether existing standards could incorporate medical device data from the home; and
  • How consumer-reported data could be incorporated into clinical quality measures.  

In a prior meeting this past June, some of the concepts addressed included aligning with emerging payment, supporting population health, and tools to assist interaction with patients "that may be a bit more difficult" according to the meeting materials.  At another meeting in late October, the Committee had several potential opportunities for inclusion of prescription drug abuse: 

  • Including prescription drug monitoring program (PDMP) prescription drug history in medications reviews before a prescriber finalizes a controlled substance prospection order;
  • Adopting a clinical quality measure that reports a provider's performance based on the use of the PDMP prescription drug history;
  • Mandatory provider registration with the applicable state PDMP drug monitoring program
  • Requiring a single sign-on or hyperlink to access PDMP data. 

Reporting the release of the recommendations, FierceEMR noted that the committee explained that to be considered for Stage 3, an objective should support new models of care, address national health priorities, have broad applicability, promote advancement, be achievable, and reflect the reasonableness/feasibility of EHR products.  The committee prefers that standards for EHRs should be available if not widely adopted.

The committee also said that it recommends that “Stage 3 is the time to begin to transition from a setting-specific focus to a collaborative, patient- and family- centric approach. 

ONC added several additional items for public comment, including questions on identity matching, transitions of care and the need for health IT safety risk assessments.  The recommendations will be published in the Federal Register later this month; public comments will be accepted for 45 days after that date.  Here is where public comments are to be submitted

The committee said that it will analyze the comments and hold further public meetings about Stage 3 in 2013 before formal rules are issued.

     

In addition to these rules, ONCHIT recently announced applications to be considered for Health IT Policy and Standards Committee Workgroups.  Also, ONCHIT released a new primer on the 2014 Edition of the certification criteria for electronic health records under Stage 2 of the Meaningful Use program. The primer provides an overview of the new certification requirements and compares the 2014 Edition to the current 2011 Edition. The materials also detail how to prepare for the objectives and clinical quality measures, and outline timing and penalty concerns

 

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