It is surely not an enviable task to receive, review, and analyze public comments on Stage 2 of Meaningful Use. HHS wrapped up the public comment period last Friday. There are surely hundreds of comments as providers, HIEs, EHR vendors, HIT consultants, etc. all have a strong interest in what Stage 2 will look like and how it will be implemented.
Practice Fusion participated in the public comment process and, although comments have not yet been made public, I believe that Practice Fusion’s comments are unique. We had two goals:
- Represent the best interest of providers;
- Enable HHS to meet its connectivity goals as quickly as possible.
Stage 2 of Meaningful Use is predicated on an antiquated notion of connectivity. Communication and information sharing between providers is achieved by re-inventing the internet for healthcare. It places hospitals and other large institutions at the center of local healthcare connectivity and relies on a hierarchical serial structure of unique connections between providers, hospitals, HIEs, and other large institutions. This HIE design is based on legacy EHR systems rather than web-based platforms that can connect individual users instantly and, using pipeline connection technologies, can connect labs, hospitals, HIEs, and other large institutions. This technology doesn’t require the creation of a healthcare internet, it is the internet.
This is a fast and easily connectivity solution both for providers and HHS. Providers get a great product without purchasing costly equipment, have access to data anywhere, and have an easy and intuitive connectivity solution that doesn’t require special integrations with every hospital, every lab, and every potential HIE that would fall within their referral network.
HHS wants providers to communicate as easily and quickly as possible. This new HIE paradigm accomplishes the task without reinventing the wheel (or the internet). It gives HHS to concentrate on the creation and promotion of standards that will facilitate the connectivity process to ensure that vendors are building products that will meet the connectivity challenge.
Recently, the American Health Information Management Association asked HHS to delay Stage 2 of Meaningful Use until Stage 1 is evaluated. If this were to happen, I believe that HHS would find that providers flocked to web-based EHRs during Stage 1 and experienced an enhanced and superior form of connectivity that resulted from industry innovation rather than government mandates. It would lead Stage 2 of Meaningful Use and likely EHR certification criteria to reflect this form of connectivity rather than the legacy HIE paradigm.
Whether or not HHS decides to delay criteria for Stage 2 of Meaningful Use, HHS has a unique opportunity to study and understand how Practice Fusion and other web-based EHRs are changing connectivity, providing significant value to providers, and solving HIE adoption rate-limiting factors with elegant solutions rather than provider-level work-arounds.
Key recommendations to HHS for the Meaningful Use include:
- Develop Meaningful Use criteria around true standards for interoperability that strictly adhere to HL7 v2.x type or XML;
- Alter CPOE criteria to require electronic, structured data;
- Broaden care coordination language to include connectivity that will be achieved through physician network solutions such as web-based EHRs or pipeline connectivity solutions;
- Define a standard for county-level public health agency communication ensuring one standard for all agencies by ICD-9CM code.
Further comment by Practice Fusion can be accessed via www.regulations.gov.
Health Policy Manager
Practice Fusion EHR