What should Meaningful Use Stages 2 and 3 include?

During two days in late April 2009, the National Committee on Vital and Health Statistics convened a meeting in Washington, D.C., to better define what "meaningful use" was--and who could be a "meaningful user." More than three dozen experts--representing physicians, hospitals, vendors, consumers, academia, and public health interests, to name a few--presented their comments and visions before the panel.

Flash forward two years now. The panel is now a memory. We're now familiar with the Stage 1 requirements of the Meaningful Use incentive program. But the funny thing is, the interest is still very much there about getting the MU concept and the use of electronic medical records (EMRs) right.

Why? Take a look at the feedback that has been coming in the forms of letters to the Health Information Technology Policy Committee this week addressing the proposed set of requirements for meaningful use measures and objectives for Stages 2 and 3. They have a lot to say.

For instance, the American Hospital Association, in its 38-page letter (.pdf), noted that in a January AHA survey completed by 1,297 hospitals, a disconnect was emerging: More than 95 percent of those responding hospitals said that they planned to "pursue meaningful use," but only 1.6 percent of those hospitals (21 of the hospitals) could meet Meaningful Use and certification requirements today.

When the hospitals were asked if they could meet 14 of the core MU objectives--and an additional five menu set objectives-using certified EHRs, "few can put it all together to meet the meaningful use requirements," the AHA said. "Clearly, the Stage 1 requirements are challenging--raising the bar significantly in Stage 2 risks limiting the success of the EHR incentive programs."

HIMSS' Electronic Health Record Association (.pdf) said it was "very concerned" that the government's proposed clinical decision support (CDS) EHR requirements that "go well beyond" what an EHR should be programmed to do. It added that CDS features with an EHR should allow EPs [eligible providers] and hospitals as much flexibility in designing CDS as possible.

By allowing providers to customize their own CDS alerts and advisories, they can create specific and targeted decision support "based on criteria specific to their patient population," the association said.

With the American Medical Group Association, many of its members are currently involved in offering patients the ability to view and download via a web-based portal--within 36 hours of discharge. But AMGA said it had some concerns.

For instance, among eligible providers, at least 20 percent of patients should use a web-based portal to access their information at least once. Patients without the ability to access the Internet are excluded. This objective, however, "puts the burden on the EPs to track and measure how many patients have access to the Internet--placing the burden on EPs for things they cannot easily a certain or measure, AMGA's report says.

And so it goes. Many other groups have opinions, too. It's very much interesting to see how meaningful use and EHRs are still alive. - Jan

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