A trade organization representing the interests of more than 300 telecommunication companies is urging federal policymakers to incorporate mHealth into future electronic health record certification guidelines.
The Telecommunications Industry Association called on national coordinator Karen DeSalvo
, MD to make sure the voluntary guidelines are flexible enough to allow for "the delivery of healthcare in motion, virtually anywhere and at any time," in a nine-page document TIA sent to the Department of Health and Human Services' Office of the National Coordinator for Health IT.
"In crafting its 2015 certification criteria (and further editions moving forward) as well as its efforts generally to improve the U.S. healthcare system, we urge ONC
to fully appreciate the health information technology ('HIT') ecosystem which is comprised of many technologies, including medical remote monitoring products that are enabled with ICT, namely wired, wireless or mobile," Brian Scarpelli, the TIA's director of government affairs, wrote. "HIT includes the technologies that touch patients and electronically capture their physiological information and generate valuable data about the person’s health. HIT is not solely EHRs and EHR systems, but also includes mHealth, e-Care, telemedicine and eHealth."
"Embracing the diversity of solutions will allow for innovative improvements at each stage the patient along the continuum of care," he added, urging the ONC to "lay the foundation for robust inclusion of patient-generated health data as a core and menu set criteria for meaningful use
The TIA also expressed concern that the ONC might be making the certification process too complex.
"The proposed regulatory pathway for more frequent certification cycles could be the cause of confusion and create unintended consequences," Scarpelli wrote. "Although the 2015 Edition certified EHR technology (2015 CEHRT) is proposed to be voluntary, TIA is concerned that other associated federal programs and resulting regulations could reference or incorporate these voluntary requirements, thus subtly converting a voluntary program into a mandatory requirement."
In his comments, Scarpelli noted that healthcare providers nationwide are using EHRs to advance patient care, and meaningful use incentives "are absolutely critical to realizing the care transformation objectives of health reform." In that light, he urged the ONC to "structure its 2015 certification criteria in ways that maximize flexibility to permit evaluation of individual applications on their merits, in ways that account for the specific applicant's needs."
Finally, Scarpelli urged the ONC to consider patient-generated health data -- including data gathered in remote monitoring programs and with mHealth devices – "as part of meaningful use." He said the ONC should ensure that, to quality for meaningful use incentives, EHR systems incorporate standards for interoperability
with remote patient monitoring devices, services and systems.
"Clinical evidence has already demonstrated that interoperable remote monitoring improves care, reduces hospitalizations, helps avoid complications and improves satisfaction, particularly for the chronically ill," he wrote. "So far, the cost savings appear promising: a recent study predicted that remote monitoring will result in savings of $36 billion globally by 2018, with North America accounting for 75 percent of those savings. We believe that the ONC appreciates the value of PGHD to providers, patients, and other stakeholders, and that PGHD should become elemental to the efficient delivery of healthcare."
The TIA isn't the only organization raising issues with the proposed 2015 EHR certification criteria. The EHR Association and the American Medical Association
have written to DeSalvo in recent weeks.
In a letter to DeSalvo, the AMA said its constituents are concerned that the meaningful use program requirements are “overly rigid" and that the certification process “is not focused on ensuring interoperable and usable systems.”
According to the AMA's analysis of the most recent CMS
data on meaningful use, approximately 20 percent of eligible professionals have dropped out of the program, "a figure we expect to rise once all the data for 2013 are tabulated."
In addition, AMA officials say that poor EHR usability is partially due to a disconnect between development of the EHR and its use in the real world. More testing could remedy this, the AMA said, including requiring vendors to perform scenario-based testing prior to certification.
"The AMA firmly believes that the MU program and certification process must be substantially overhauled so physicians can leverage technology to help ensure improvements in health care delivery," AMA officials wrote in the letter. "We specifically encourage ONC to focus on more comprehensive testing along with greater transparency of these results."
While the proposed 2015 criteria is distinct from Stage 2 meaningful use, as early as October of last year EHR vendors were surprised by the complexity of Stage 2, citing clinical quality measures, interoperability, and automated measure calculation for reporting metrics among the most challenging issues.