The following are excerpts from comments – some of them dozens of pages long – submitted to the federal government regarding the proposed meaningful use requirements. The final rules, taking the comments into account, are due out in late spring, according to federal officials.
“The CPOE-related Objectives and Measures should be phased in with compliance targets for each year that provide hospitals and their medical staffs with sufficient time to accomplish the process changes and training necessary for successful CPOE.
“The compliance targets for 2011 should be set at appropriate levels in light of the current absence of a functioning electronic health information exchange (“HIE”) in most communities, and the time typically necessary to implement an HIE. Also, compliance targets, which require the existence of a functioning HIE should be phased in so as to avoid multiple overlapping HIEs being established to serve any particular community or region.”
- Blair Childs Senior Vice President, Public Affairs
“We recommend that:
- CMS adopt a different measure for use of CPOE that would be less burdensome to report. Our preferred measure is Hospital has CPOE activated.
- If CMS does not accept this as a preferred measure, we recommend either 1) at least 10 percent of unique patients have had at least one order placed through CPOE, or 2) at least 10 percent of medication orders placed through CPOE, which can be calculated from a hospital’s pharmacy information system.
- If either of the secondary options are chosen, ONC should require this measure calculation as part of the EHR certification process.
“Clarification is needed to determine what electronic data are to be given to patients and their families, and in what format. If in electronic format, we support movement over time to the use of records in the CCD (Continuity of Care Document) standard, which provides the best opportunity for interoperability between providers’ records. The CCD will not, however, be used widely in the near term.
“We recommend a thoughtful review and revision of the definition of “eligible professional” to include all physicians practicing in ambulatory clinics, whether owned by physicians or hospitals. We endorse the AHA’s proposed change to the definition of Eligible Professional, which is based on specialty, types of services provides and contribution to the EHR system.”
- Richard A. Correll, President & CEO CHIME (College of Healthcare Information Management Executives)
“HIMSS endorses the adoption of one patient record summary standard to support Meaningful Use (MU) in Stage II and beyond and the use of CCD or CCR for Stage I as a glide path to a single standard. This means that the selection of the single standard needs to occur within a 6 month time window so that vendors and providers have the lead time to factor changes into their product and implementation plans. HIMSS membership is concerned that several key items in the required certification criteria are not clearly- defined, and short timelines present huge challenges.
“It is critical for Health Information Technology stakeholders to have consistency in terminology related to terms. Stakeholders need significant advance time for the industry to deliver and test the products and have clearly understandable language to do that – not doing that raises the risk of failure and the likelihood that we can deliver a quality outcome in time. To give an example, “structured data” and “structured reporting” are part of the certification criteria, but the terms are not clearly defined”
CMS Meaningful Use NPRM defines structured data as “data that have a specified data type and response categories within an electronic record or file.” This definition is vague. In order for Meaningful Use to be accomplished, many of these criteria require improved granularity. HIMSS also requests that the Final Rule fully harmonize with the CMS Meaningful Use Final Rule. HIMSS membership is concerned that many of the certification criteria and standards listed in the IFR pose significant challenges to end users and vendors of inclusive best of breed and modular systems. Based on these criteria, HIMSS is concerned that it would be much more difficult than anticipated to certify a modular EHR.”
- Barry Chaiken, MD, chair of the HIMSS Board of Directors, and H. Stephen Lieber, President and CEO of HIMSS
“Please don’t create another quality measures reporting program. CMS already has quality measure reporting programs for eligible professionals (PQRI) and for hospitals (RHQDAPU which we all call The Core Measures).
“Instead, enable those programs for “reporting from an EHR” first.
Then, add more quality measures. Do make sure those are enabled for “reporting from an EHR” and vetted, of course, through the established channels.
“Definitely don’t ask us to report new quality measures before there are specs for EHR reporting. That was clearly not the intent of congress when they added that part about the Secretary not requiring electronic reporting of information on clinical quality measures unless the Secretary has the capacity to accept the information electronically. I don’t think they meant keying in some data on a website.
“If you insist on quality measures in Stage 1, couldn’t you just use satisfactory reporting through the existing programs while you get the “reporting from an EHR” part worked out?”
- Denni McColm, CIO of Citizens Memorial Healthcare
“The “bar” for demonstrating meaningful use during Stage 1 should not be set too high or too low. The goal of widespread EHR adoption and use will be undermined if the majority of physician practices, especially smaller ones, determine that they will be unable to meet and attest to the Stage 1 EHR incentive program measures and decide not to take part in the incentive program."
“The timelines and criteria for demonstrating meaningful use must factor in the expense and time to transition a physician practice to an EHR environment, the interruption of existing workflows, changes in patient-physician communication techniques, and the interaction between Practice Management Systems (PMS) and EHRs. CMS should also keep in mind that the majority of the proposed measures will require significant EHR use, manual calculations, software programming, training, and information exchange, in order to attest to the accuracy and completeness of metrics, including numerators, denominators, and exclusions. The expected manual review and counting of records to meet most of the proposed measures is highly burdensome and takes away from patient care. Percentage threshold reporting should only be required when the EHR has the ability to automatically calculate all metrics that are required to be reported and that this can be easily done by the physician.”
- American Medical Association (along with several medical specialty organizations)
