Many of us who are close to healthcare IT regulation will soon be heads-down reviewing, analyzing and generally mulling over the Proposed Rule on Stage 2 of the Meaningful Use program, now that CMS is set to release it. On top of late nights and a headache or two, there is one other thing we’re bracing for: the Great Debate as to whether CMS – with significant input from others – did a good job or missed the mark.
No matter what is in the Rule, some will argue that the proposed measures are too difficult, while others will insist CMS didn’t go far enough. It’s clear we can expect significant back-and-forth on the appropriate balance of the Rule’s many elements – the thresholds, the quality measures, the requirements for data connectivity, privacy elements, and how best to measure patient engagement in the process.
Following are a few predictions of what will stir the fires the most.
Clinical Quality Measures (CQM)
Clinical Quality Measures were in Stage 1, and I think they will also be in Stage 2. Some of the conversation has centered around the idea of whether the Rule should still maintain a Core vs. Menu approach, and others on how to appropriately bring in CQM that are relevant to specialists and sub-specialists. Others who are more focused on the technological underpinnings of the process have noted there are many steps in the process of developing new eMeasures that can be reported directly from an EHR, and it’s important to include only those CQM that have been tested and proven useful within clinical workflows.
Evaluating Providers Using Patient-Centric Measures
In trying to achieve the high level goals of HITECH, which aims to improve the quality of life for patients, it’s critical that we engage patients as well as providers with health information technology. Holding physicians and hospitals accountable for what their patients do at home, though (for instance, their use of a Personal Health Record to check test results), is a tough concept for most providers. Finding that balance is a knotty but important challenge.
Health Information Exchange
Given that US health information exchange infrastructure remains a work in progress, many observers are skeptical about HITECH requirements related to data exchange. I understand the concern, of course, given some of the challenges being faced by state HIEs and the lack of required infrastructure in rural or other underserved areas. Nonetheless, there are many other alternatives for information exchange, ranging from private HIEs sponsored by health systems or other collaboratives to the Direct protocol. The real power of health IT comes when the data is flowing broadly in a community for use by clinicians and analysis by public health officials. I hope that the voices pushing for more aggressive requirements on data exchange ultimately prevail here.
After watching the Stage 1 debate play out back in 2009, my sense is that while the conversation is important, ultimately we should aim high. It is vitally important to be sensitive to providers’ concerns. But it’s also important to remember that many who felt the Stage 1 requirements were too stringent ended up demonstrating through the attestation reports their ability to clear the thresholds by a significant margin.
My opinion: After the noise dies down and we get through implementation of Stage 2, we’ll find that it has brought us one step closer to the goal of a cost-efficient, quality-intensive healthcare system.
And that will have made the whole effort worthwhile.