Everyone wants to be heard. And, by all accounts, the providers and healthcare organizations that commented on the proposed rule for meaningful use Stage 2 weren't just wishing upon a star when they sent their carefully crafted comments to the Centers for Medicare & Medicaid Services for consideration.
They may not have gotten all the changes they wanted, but they believe the rulemakers listened. They felt understood.
Charles Christian, CIO of Good Samaritan Hospital in Vincennes, Ind., told Healthcare IT News Managing Editor Mike Miliard the rules "appear to have been thoughtfully considered, even the ones where the response was that the proposed objective stands as the final." (P. 12)
Christian said he was satisfied that CMS and ONC listened to the provider community, and took to heart - wherever practical - the input received during the comment period.
William Spooner, CIO of Sharp Healthcare in San Diego zeroed in on "a couple of wins" for providers - one of those wins was the three-month reporting period for Stage 2. It provides the needed flexibility providers need, he says. The rulemakers had proposed raising the reporting bar to 12 months.
It's exacting work - though perhaps more taxing today for its complexity rather than for its review method. Imagine getting all these comments on paper - and somehow sifting through all of them, trying to make sense of them and to respond in a coherent fashion.
That's what Elizabeth Holland, director of the HIT Initiatives Group in the Office of E-health Standards and Services at CMS, faced when see started her career with CMS more than 20 years ago. The work is still challenging today, but she and her colleagues can handle it more easily digitally than on paper. They just know to plan to work 24/7 during crunch time.
Each measure in the final rule is accompanied by a summary of the comments from stakeholders, followed by a decision from rulemakers, paired with an explanation, giving detail of just what the rulemakers were thinking, providing the answer to the "why."
"We feel very strongly about that," Holland told me in an interview for this month's NewsMaker feature (P. 46) "We feel that was our responsibility."
Holland knew providers would be disappointed that the rule regarding patient engagement remained, though in a weakened form, requiring that 5 percent rather than the proposed10 percent of patients view online, download or transmit to a third party relevant health information. Providers say it's out of their control. Holland says, "I have confidence they'll be able to do it."
The attention to detail with which Holland and the other rulemakers approach their work may have added more than a few pages to the final rule, which came in at more than 1,000 pages, but that kind of care and thoroughness is commendable, and it inspires confidence in providers who are tasked with putting the provisions of the rule into action - all in the name of improved patient care and efficiency. No easy task, but critical to transformation, which after all is what healthcare is working to attain.
There will be high jumps for some. So, it's good to be reminded the hurdles healthcare providers and their organizations are expected to jump are not there simply for the fun of jumping. They have been given careful consideration. They are intended and designed to make over an entire industry. There are bound to be missed hurdles, a few falls along the way. What's being asked of providers is demanding.
Holland and her cadre of dedicated rulemakers have crossed all the 't's' and dotted all the 'i's.'
"We read all the comments, and we really do puzzle over them," she says.
How does that old saying go? "Good enough for government work."
It suggests government workers are careless, sloppy, or even lazy. That couldn't be further than the truth - particularly in this instance. The proof of the pudding is in the eating, the pudding in this case being a large serving of meaningful use.