Where’s Paul Shaffer when you need some theme music?
Now that the comments on the Meaningful Use Stage 2 Notice of Proposed Rulemaking (NPRM) have been submitted by anyone with an opinion and Internet access, the media is making hay of all the negative feedback from industry stakeholders. There have clearly been some provocative conversations. There’s even a protest planned in response to one organization’s suggestions!
But there are also plenty of people who actually liked elements of the proposed Stage 2 program, including the leadership of Allscripts. It may not be as sexy to point out what we like, but even federal bureaucrats deserve kudos on occasion – especially when their proposals benefit patients and providers. So here we go …
The Top Ten Things We Like About Meaningful Use Stage 2
10. There’s so much more for specialists
CMS heard the complaints from Stage 1 participants that it was too heavy on primary care quality measures and general program structure, and they’ve added several different elements that should go a long way towards mitigating those concerns.
9. Public health is a big focus
The public health measures in Stage 1 are being expanded. We’ve advocated for a common national data submission standard because there is simply too much churn in the industry right now from non-standardized registry and public health interfaces. But we strongly support the effort to get more data flowing to benefit population health.
8. There’s recognition that MU might not be right for every provider
While the payment adjustments are becoming more clearly defined, CMS also asked for comment on whether there are certain provider types (i.e. certain specialists) who should be excluded from the penalties because of the program’s inapplicability to their clinical or business processes. While health IT is beneficial to every provider type, it is clear that the specifics of the Meaningful Use program may not work for anesthesiologists, for example, or hospitalists, and we applaud CMS’s consideration of their unique dynamics.
Allscripts strongly supports the introduction of the eMAR (electronic medication administration record) objective. We believe it will have clear and measurable benefits related to patient safety, and we think CMS got it exactly right as proposed.
6. Computerized provider order entry (CPOE) is being expanded
What started as only medication CPOE in Stage 1 is being expanded to labs and images in Stage 2. This will offer very clear benefit to patients. So while we’ve proposed a slightly different approach in measuring participation, this effort to push providers forward with CPOE is worthy of applause.
5. Clinical decision support is taking a big step forward
The most substantive benefits of health IT adoption are realized when healthcare professionals respond to appropriate, intelligent clinical information presented in a way that complements their workflow. The broad majority of our clients who already use clinical decision support say it has improved the care they deliver to their patients, and now the Meaningful Use program will likely accelerate that adoption at a rapid pace.
4. Lots and lots of clinical quality measures
Many people are complaining that the NPRM includes too many clinical quality measures (CQM). Realistically, the list should probably get a little smaller because some of the measures are being pushed too quickly without the necessary analysis and testing of the specifications. That said, clinical quality measurement is going to allow us a peek into what care is being delivered to whom and when; something that mere analysis of claims simply can’t deliver. That will be good for patients and good for the nation’s pocketbook.
3. Patient Engagement gets several boosts in the NPRM
This is a big bucket and really could be broken out into individual points, but generally speaking, we think CMS deserves a high-five for this one. The proposals are imperfect in some ways and require reengineering, but we hope that CMS keeps assertively moving forward in this area. Patient engagement is too important to soft pedal.
2. The one-year delay until the state of Stage 2
This is important. The prior timeline, which would have required Stage 2 to begin in October of this year, was simply untenable. It was unreasonable to expect that the Final Rules would be released this Summer and that the industry (software vendors and healthcare providers) would then conduct appropriate and safe product development, testing, implementation and training before going live in October 2013 (only four months later).
And the No. 1 Thing We Like about Meaningful Use Stage 2 is…
1. The interoperability football has been run down the field
If clinical data about patients isn’t flowing, the Meaningful Use program can’t deliver its full return on investment. CMS and ONC take very big steps forward in the Stage 2 NPRMs, both by pushing the technical elements of interoperability and by tackling some of the governance issues that are blocking data exchange today. It’s clear that some of the ideas aren’t practical, at least not in their current form, but we wholly support the NPRM’s approach to interoperability and hope that the Final Rule maintains that focus. This interoperability challenge is a make-or-break issue for the program and for the American healthcare system in this country, so while it may be hard, we’re all in.