All the people collaborate together to make this big rule
As director of the HIT Initiatives Group in the Office of E-health Standards and Services at CMS, Elizabeth Holland is front and center at the rules table, shaping the meaningful use rules that many view as driving healthcare transformation. Holland is a veteran policymaker. She joined CMS in 1991, right around the time the proposed rule for the Medicare fee schedule was in the works. CMS received 100,000 comments - all on paper.
"We got these long letters from every medical specialty society that was worried about their batches of codes," she said. "So, we would sit and cut up the comments and sort them into boxes - and then give someone a box and then say, 'summarize your box.'"
"You think about all the CBT codes - how many boxes, how many ranges we had," she said. "So that's when I started doing regulations. It was really challenging."
Healthcare IT News asked this veteran rulemaker to provide a glimpse into the path taken to crafting the final rules for meaningful use Stage 2.
The final rule discusses the comments and gives an idea of what the group was thinking in each case?
Yes, and we feel very strongly about that. We feel that was our responsibility. For us, for this program, the real challenge was Stage 1 NPRM (Notice of Proposed Rulemaking) because that was when we were designing the program from scratch, and no one knew what to expect, and so that we had to go through every detail, not just meaningful use objectives, but everything - how the payments would be calculated, every little detail about the program. So this round of rulemaking was somewhat easier because we had a framework, and people knew what to expect. They knew we were defining meaningful use for Stage 2, but they already knew what meaningful use was all about. They knew how the program worked or where it didn't work.
You don't hear too many people complaining. CIOs seem to take it as a given.
From the NPRM, we stayed true to it, and there were many cases where we got comments. We read all the comments, and we really do puzzle over them, and we have to balance how we're going to move forward, and there were a lot of debates and analyses done. You try to satisfy as many people as you can. To me that is the most challenging part because you want to come up with good policy. You come on some sort of ground so that nobody's totally happy, but everybody's able to live with it.
How many people in the room discussing these issues before you come out with the final rule?