Shortly after the news broke on Friday afternoon, March 20, that the federal Centers for Medicare and Medicaid Services (CMS) had released the proposed rule for Stage 3 of meaningful use under the Health Information Technology for Economic and Clinical Health (HITECH) Act, and that CMS and the Office of the National Coordinator for Health IT (ONC) had released the 2015 Edition Health IT certification Criteria, Russell P. Branzell, president and CEO of the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME) gave HCI Editor-in-Chief Mark Hagland an industry-first interview with his perspectives on the Stage 3 proposed rule, based on a preliminary read of the proposed rule. Below are excerpts from that interview.
I know that you and your colleagues are still analyzing the proposed rule. What are your first impressions of it?
Our initial impressions are that we’re pleased with the flexibility built into the overall program, as promised. It appears as part of their eight core objectives within Stage 3 that there’s flexibility within them on reporting measures, allowing people to choose, which is one of the things we were hoping for. As far as the overall timeline goes, we’ll still need to obviously review this, but there is some concern over whether all participants can catch up to Stage 3 by 2018; and what that sequencing means in 2017, for all participants.
That said, we are pleased that they’re shifting both hospitals and eligible professionals to calendar-year reporting; but it would still be nice to have a 90-day reporting period instead of a 365-day reporting period.
Does this seem to be in line with what federal health officials have been promising publicly for months, in terms of to harmonizing the demands being placed on providers? I’m thinking of the SGR-fix legislation introduced into the House of Representatives this week, for example.
Our initial impression is that they’ve tried to bring this in, in such a way that it encourages interoperability and improved care coordination through sharing of information. With Stage 3 appearing to be the final stage of meaningful use, it does appear to present a significant challenge to full interoperability and exchange of data, when most of these measures are still being set at smaller levels, as in 50 percent of care coordination. It does seem that there’s still work to be done, once MU ends.
One example to discuss might be the requirement that 35 percent of patients participate in secure electronic messaging with their providers.
Yes,; that’s a requirement under care coordination through patient of engagement. There are three measures there, and providers will have to fulfill two. The other two requirements from which providers will be able to choose is ensuring that 25 percent of patients view, download, or transmit their own data electronically through an API; and that 15 percent of patient-generated data be incorporated into the patient record.
Do you have any thoughts regarding the health information exchange-related requirements under the proposed rule?
Again, these are things that are generally being performed today and are just increases of things being done already; so that is the next logical step to improve care coordination.
Is there anything you’re dissatisfied with in what you’ve read so far?
We need to do a full analysis, and we’ll be doing a full set of comments to ONC/CMS via the NPRM [notice of proposed rulemaking] process. I’m sure there are things we’ll need to address, in terms of the 17 quality measures. It’s just as with the two previous stages, there will be full analysis and review. But we’re pleased that we have something to react to. If we can get through this NPRM process effectively, in theory, we’ll have time to have software deployed appropriately to those who can use it, by 2017.
Overall, you’re satisfied with what you’ve seen, then?
At this point, we’re pleased with what we’ve seen relative to an overall approach towards simplifying flexibility and interoperability, all things we’ve been asking for, and are pleased that ONC has put out a rule that address those big concerns. Now we need to look into the details.
What would your advice be at this moment, for CIOs and other healthcare and healthcare IT leaders?
We’ll be putting out a formal review of this out there for all our member groups, as will others. We’ve got 1,400 members and four membership groups. And every organization will have to analyze for themselves, too. We’ll put something out very quickly; we’ll probably be putting out a first-blush review by early next week.
Healthcare Informatics will continue to update readers on this rapidly evolving story.