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MU Work Group Crafts Response to Stage 2 Proposal

April 5, 2012
by David Raths
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Panel urges keeping up-to-date problem list, active medication list as separate objectives

The Health IT Policy Committee plans to submit its response to the Centers for Medicare & Medicaid Services’ meaningful use Stage 2 Notice of Proposed Rule-Marking (NPRM)by May 7. At its April 4 meeting it heard from several of its work groups about suggested tweaks and recommendations. Paul Tang, M.D., of the Palo Alto Medical Foundation, and Columbia University’s George Hripcsak, M.D., co-chairs of the meaningful use work group, addressed several key issues.

On computerized physician order entry (CPOE), they noted that the NPRM for Stage 2 adds lab and radiology orders and raises the threshold to 60 percent of orders. Tang said the work group suggests making the threshold 60 percent of each order type to make sure people can’t avoid one type by reaching the 60 percent threshold with only meds and labs, for instance.

Last October, Healthcare Informatics ran a story on the use of physician scribes. The article by Jennifer Prestigiacomo asked whether scribes “are indeed the answer for the increased burdens physicians are carrying in the era of accountable care or they just a crutch keeping physicians from participating in the technological necessities needed for increased documentation?”

That continues to be a pressing question, as the policy committee debated scribes’ role in CPOE. The MU work group is recommending keeping the definition as requiring a licensed professional to enter the orders. “This is a contact sport,” Tang said. “Decision support influences orders as they are written,” so the licensed professional must be the person writing the order.

The NPRM plans to consolidate the requirement to maintain an up-to-date problem list and active medication list for 80 percent of patients with the summary of care requirement. The MU work group recommended keeping these three lists as separate objectives because they are motivators for clinicians to enter and maintain accurate lists. Also, the policy committee was planning to add more rigorous capabilities to facilitate maintaining complete and accurate lists. Tang noted that just having these elements in a transition-of-care document does not give the information the visibility it deserves. The work group is concerned that combining the objectives sends a signal that these three items are less important than other items like demographics and vital signs.

On the new menu item that 40 percent of all scans and tests whose result is an image ordered are incorporated into or accessible in the EHR, the MU work group recommends lowering the threshold to 10 percent with exclusions for providers that have no access to electronic images. (They also noted that Stage 2 might be too soon to expect physicians and hospitals to share images with outside providers.)

The work group also recommended lowering the threshold for sending a secure message using the electronic messaging function from 10 percent to 5 percent of patients.

On health information exchange, the work group agrees with the requirement for Stage 2 that the transmitted summary-of-care document must cross organizational boundaries. But they said requiring that the transmission occur between different vendor systems may cause unintended consequences in some geographic regions where a few vendors may have a dominant market share.

The committee also heard from work groups about privacy and security, information exchange, and clinical quality measures. Based on comments from the committee as a whole, each work group will refine its recommendations for the committee to present to CMS in May.

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