As healthcare IT leaders pore over the details in the Notice of Proposed Rulemaking (NPRM), more informally known as the proposed rule, for Stage 2 of meaningful use, under the American Recovery and Reinvestment Act/Health Information Technology for Economic and Clinical Health (ARRA-HITECH) Act, analysts are finding different elements in the proposed rule to be of particular interest.
Most industry experts analyzing the proposed rule, as well as many of the CIOs and other healthcare IT leaders looking at the rule, have expressed broadly positive comments about it, even as they have cautioned their colleagues about some of its challenges and complexities. One of those industry experts who has come away broadly positive after a detailed analysis of the rule is Mark Segal, Ph.D., vice president, government and industry affairs, for GE Healthcare IT. The Oak Park, Ill.-based Segal spoke recently with HCI Editor-in-Chief Mark Hagland regarding his analysis of the rule. Below are excerpts from that interview.
What strikes you as most significant about the proposed rule?
At the highest level, there is a general level of continuity from the prior rule, and, in looking from Stage 1 to Stage 2, and from structured data through advanced care processes. Also, at the very highest level, there’s a sense that both CMS and ONC [the federal Centers for Medicare and Medicaid Services, and the Office of the National Coordinator for Health IT, respectively] listened [to providers’ concerns] and observed pretty carefully what’s going on, to how Stage 1 is progressing, and to what’s needed. Drilling down one level, the fact that they formalized the additional year to Stage 1 was very significant. [Health and Human Services] Secretary [Kathleen] Sebelius had indicated that they might do this, late last year, and the policy committee had recommended it. But the fact of it just drives home that, given the complexity involved, it would literally have been impossible to stick to the initial timetable.
Mark Segal, Ph.D.
In addition, there’s an increased emphasis on interoperability and health information exchange [HIE]. For example, they eliminated the single test for HIE in favor of requiring actual exchange. I think CMS really nailed this, because people had been very unclear about what they had to test; and because there hadn’t been any actual transport standards in Stage 1. So it had basically been about generating a CCD [continuity of care document] or CCR [continuity of care record], and then sending it; so it didn’t test for very much. Now, they’ve really shifted to actually having to do an exchange for 10 percent of the times when you actually have a referral or transition of care. And I think that that really is a very important move forward, because that really helps create the actual business case, not only for doing exchange, but for doing exchange in a way that integrates with your workflow.
There are things in here that really reinforce exchange: a move towards a single summary standard from the two that were in Stage 1. In Stage 1, they had the CCD or CCR; in Stage 2, you have something they’re calling a Consolidated CDA (clinical document architecture); and a CCD is a version of a CDA. The EHR, when it receives a clinical summary from another provider, needs to basically integrate the data from that summary into the EHR and structured data, whereas in Stage 1, you only needed to display it. And also, there are actual transports standards as to how you move the information from point A to point B; and that had been a very noticeable gap in Stage 1. So all those things taken together really make the prospect for health exchange really bright.
There are a couple of other areas to point out as well. In Stage 2, there is now an increased focus on patient access to their data, including the ability to view the data and actually transmit to somewhere else; as well as secure messaging between patients and their providers. Another step forward is the alignment of quality measures across different federal programs, so on the physician side, it’s aligning the measures with the PQRS system [the federal Physician Quality Reporting System under Medicare]; and it’s aligning the measures themselves, as well as aligning the reporting processes.
And finally, they’ve explicitly mentioned the role of access to images, both as images themselves, as well as imaging reports. Images and imaging reports are obviously a very important part of this. Stage 1 for the most part really didn’t address images or access to images. In Stage 2, they’re proposing that there be access to images either as embedded in the EHR itself, or as will more likely be the case, through links to PACS [picture archiving and communications systems] and other systems. And they actually reference the DICOM standard when patients get access to their own information. That’s really an important first step. They also asked for comment on creating an additional meaningful use item that would involve the exchange of images among providers.
So they’ll fashion that requirement based on comments on the proposed rule, and put it into the final rule, then?