When I tell people that part of my job is to read regulations that were written by the government, the reactions I get vary from blank looks to sympathy to “better you than me.” And when I tell them that I actually enjoy that part of my responsibilities, most think I’m joking.
The truth is, I love the process of healthcare regulatory promulgation. As all of us who waited anxiously for the Meaningful Use Stage 2 NPRM can attest (pun intended), there is an awful lot of conversation that takes place as regulations are written. I find the back-and-forth invigorating. Before a regulation is written, there are numerous Federal Advisory Committee (FACA) meetings to listen to, carefully scripted presentations by ONC and CMS, and private meetings requested by various stakeholders and industry associations. It’s really a constant opportunity to learn and improve.
The face behind the Rule?
After getting to know some of the people who contributed to the Stage 2 process at ONC and CMS, I can occassionally convince myself that I see the stamp of a certain person in the Rule, or echoes of a conversation. For instance, you can clearly see the mark of the learnings gleaned so far from Stage 1 – how people who’ve already attested to Stage 1 did, what they deferred and what exclusions they filed. You can see areas that were identified as particularly challenging by stakeholders such as specialists, public health officials or those participating via Medicaid; where they agreed with the FACAs and where they didn’t; and even where ONC is feeling political pressure.
Most of all, though, in reading the hundreds of pages that make up the Meaningful Use Stage 2 proposed rule, you can see evidence that a great deal of thought and consideration went into what was ultimately published.
Hitting the mark
That isn’t to say that I agree with everything that is in the NPRM, of course. Allscripts will submit comments on many of the proposals, including the challenges we foresee with holding providers accountable for patient behavior … calling out the need for continued exclusions around registry reporting … as well as anywhere we see regulatory overreach within the Standards & Certification proposal.
However, I don’t think there is a page in the Rule that wasn’t reviewed by an entire team of people. As a result, there are numerous proposals that we believe are right on the money. For instance, the expansion of specialty-specific clinical quality measures … the focus on inter-vendor information exchange … and adding imaging and labs to the CPOE requirements.
I’m passionate about healthcare and the opportunity we all have in front of us during this unprecedented time of industry evolution. And since a proposed regulation is really elemental to the interesting, enthusiastic and occasionally exasperating conversation about the best way for us to move forward with fixing healthcare, honestly I can’t wait to get my hands on the next NPRM.