HITPC Floats Preliminary Stage 2 Meaningful Use Criteria

The Health IT Policy Committee released a draft of stage 2 meaningful use criteria for public comment. HITPC intends the release of the criteria, which it describes as a “preliminary set of
recommendations,” to alert the industry to potential new EHR functionalities, start the public comment process in advance of formal stage 2 recommendations this summer, and gather responses to 10 specific questions.

HITPC emphasizes that the draft represents preliminary thinking of the committee and its meaningful use workgroup. Comments are due by February 25.

The recommendations come in the form of a matrix that plots stage 1 criteria, proposed
stage 2 criteria, and in many cases, proposed stage 3 criteria. The stage 3 criteria are provided for context, HITPC explains, since it conceives of stage 2 as a steppingstone to stage 3. However, the committee stresses that it is primarily interested in comments on stage 2 at this time.

The objectives address four of the five health outcome priorities established in stage 1. The draft does not cover the privacy and security domain, which HITPC and its privacy and security subgroup will address in recommendations to be released separately. In addition, the committee’s quality measures workgroup is developing a framework for the evolution of clinical
quality measures to be electronically reported in stages 2 and 3.

Stage 2 of the program begins in 2013.

Eight New Objectives

For the most part, the recommended stage 2 objectives heighten the measures of stage 1, although some objectives and their measures are unchanged. Objectives from the menu set in stage 1 are required under stage 2.

There are eight new objectives in the four domains that have no precedent in stage 1:

  • 30 percent of visits have at least one electronic EP note
  • 30 percent of EH patient days have at least one electronic note by a physician, NP, or
  • 30 percent of EH medication orders automatically tracked via electronic medication administration recording
  • 80 percent of patients offered the ability to view and download via a Web-based portal, within 36 hours of discharge, relevant information contained in the record about EH inpatient encounters. Data are available in human-readable and structured forms (new to EHs).
  • Online secure patient messaging is in use (EPs)
  • Patient preferences for communication medium recorded for 20 percent of patients
  • List of care team members (including PCP) available for 10 percent of patients in EHR
  • Record a longitudinal care plan for 20 percent of patients with high-priority health conditions of patients
10 Questions

HITPC is soliciting comments on any aspect of the draft, but it asks the following specific questions:

  1. How can electronic progress notes be defined in order to have adequate specificity?
  2. For patient/family access to personal health information, what standards should exist
    regarding accessibility for people with disabilities (e.g., interoperability with assistive technologies to support those with hearing, visual, speech, or mobile impairments)?
  3. What strategies should be used to ensure that barriers to patient access—whether secondary to limited Internet access, low health literacy and/or disability—are appropriately addressed?
  4. What are providers’ and hospitals’ experiences with incorporating patient-reported data (e.g., data self-entered into PHRs, electronically collected patient survey data, home monitoring of biometric data, patient suggestions of corrections to errors in the record) into EHRs?
  5. For future stages of meaningful use assessment, should CMS provide an alternative way to achieve meaningful use based on demonstration of high performance on clinical quality measures (e.g., can either satisfy utilization measures for recording allergies, conducting CPOE, drug-drug interaction checking, etc, or demonstrate low rates of adverse drug events)?
  6. Should Stage 2 allow for a group reporting option to allow group practices to demonstrate meaningful use at the group level for all EPs in that group?
  7. In stage 1, as an optional menu objective, the presence of an advance directive should be recorded for over 50 percent of patients 65 years of age or older. We propose making this objective required and to include the results of the advance-directive discussion, if available. We invite public comment on this proposal, or to offer suggestions for alternative criteria in this area.
  8. What are the reasonable elements that should make up a care plan, clinical summary, and discharge summary?
  9. What additional meaningful use criteria could be applied to stimulate robust information exchange?
  10. There are some new objectives being considered for stage 3 where there is no precursor objective being proposed for stage 2 in the current matrix. We invite suggestions on appropriate stage 2 objectives that would be meaningful stepping-stone criteria for the new stage 3 objectives.

1 Comment

  1. Very interesting cmenmot, Alan. I am actually a doctor, one that has had an electronic office for almost 10 years; way before CCHIT, not to mention MU. I believe each practice must decide on conversion to EHR based on what value it perceives itself and to its patients. Simply increasing adoption of EHR’s with incentive dollars is exactly the wrong way to go. I see more and more practices adopting EHR’s for this sole reason and cursing themselves for it, because it did not help improve their efficiency and their patients are upset about how IT has changed their doctor’s approach to care for the worse. Since I am considered somewhat of a pioneer in this field, when people ask me should I got for it to get the MU money? I quickly advise them against it, unless they go in for the right reasons. The only meaningful way to reward practice that effectively digitize is to allow them better reimbursement rates for their services. In other words, let medical practices work like any other for-profit business; allow the cost of IT improvement be passed on to the consumers of the service. This would not only save taxpayer money, but everybody would have a stake in making the system better. Good intentions do not justify a flawed process.

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