Having read and analyzed the voluminous Stage 2 meaningful use rules, EHR and HIE vendors have started the process of retooling their technologies to meet the certification criteria. Most seem satisfied that CMS and ONC listened to their input, but many are frustrated by some lingering uncertainties.
Leigh Burchell, vice president of government affairs at Allscripts, said the Chicago-based firm was pleased that the rules came out on August 23, rather than later in the fall as some had predicted.
And, as with many other vendors, "unquestionably we were really pleased with the 90 day reporting period. That is an important element that's going to facilitate success in the program. In the frame that it was laid out before, with the full year of reporting, it literally was bordering on something that wasn't doable.
"A lot of people don't realize the time that goes into not only development and testing to ensure a safe development process on the part of vendors, but there's also an excessive amount of work that takes place in the provider organization," she said. "Live environment testing, making sure all your interfaces work and that providers are trained appropriately in all the new measures, that takes time. And you don't want to rush it."
With this shortened reporting window allowing for more flexibility with testing and implementation, "We and our clients, collectively, feel we can be successful, which is great," Burchell adds.
That said, there will definitely be some challenges, for both developer and provider, when it comes to meeting certain measure.
"As an example," says Burchell, "There's a requirement to incorporate data after receipt of structured documents and then combine with a requirement for clinical decision support for the same data. That's really a different way of looking at things. It essentially means that HIE is going to become actionable for the first time for many providers. And it requires that structured medications, allergies and problem list data are going to have to be reconciled by our systems and then turned around so they're usable for evidence-based decision support."
That offers "enormous value to provider and patients, and we're wholly supportive of the concept, but it's really a different way of looking at the information," she says. "What do we have to do with it when it comes in? And how do we turn it, within a really quick time frame, in the system to become actionable by the provider? It's a change for us, we have to adjust our systems accordingly, and it's also something that's going to require workflow changes by the provider. They're going to have to figure out how to use this and maximize this information in a way that it becomes useful to them during the care process."
[See also: Chart: Stage 2 objectives and measures.]
Another item on many vendors wish lists is more guidance with regard to quality measure specifications and test scripts, says Burchell.
It's a concern that's echoed by Mark Segal, vice president of government and industry affairs at GE Healthcare IT. "We really would have liked the certification test methods closer to when the rule was out," he says. "We really need those as a guide for development. We also want the quality specifications out sooner."
Segal says he was "more than a little surprised to hear that the test methods would be out in waves through December. That's much later than we would have anticipated."
On the other hand, "Reading through the rules, I see that they really took some pains to give very explicit signals about things we vendors should be thinking about, in terms of likely ways in which a particular function would be tested," he says. "That was very helpful."
And with regard to quality measures, "It was very helpful that they chose an option for what we have to support that was much less than the full NQF data model, and they actually published a data elements that we need to support," says Segal.
Still, the sooner more specific guidance can be had, the better: "Every week, every month matters."
[See also: At a glance: Stage 2 final rule.]
Dave Riley, chief of informatics at Harris Healthcare Solutions, saw "no major surprises" in the Stage 2 rules. "To my knowledge there was nothing that we were concerned about in terms of input that wasn’t adequately covered," he says.
"If there is a disappointment at all, it’s in the fact that everything moves so slowly," he adds.
Many of the mandates of Stage 2 – data exchange, image access, patient engagement – are right in Harris' wheelhouse.
"I think as the market shifts from a volume-based fee for service approach to a value-based purchasing approach things like health information exchange, patient engagement and image access become critical to being able to assess whether or not organizations are getting value for the money being spent," says Riley. "What is needed is granular computable clinical data and lots of it. The sooner we can get to that the better able we’ll be to assess things like value, outcomes, etc. So despite the fact that many may think these are hard things to do (mostly because they haven’t really had to do them all that much in the past) they are necessary for addressing some of the critical problems in healthcare financing and delivery."
Harris Healthcare, he says, was just "waiting for the rule-making process to finalize the rules so we could have a stable set of targets to aim for in terms of product features and capabilities. … Now that this is a known quantity we can ensure compliance and move quickly in to addressing our customer’s needs. I’m not seeing any hurdles that are insurmountable at this time."
Michele McGlynn, senior director of strategy and operations at Siemens Healthcare and the chair of the HIMSS Electronic Health Record Association (EHRA)d-ehr" target="_blank" class="directory-item-link">Electronic Health Record Association (EHRA) agrees that the rules are doable – especially with the shortened reporting period.
"Hands down, it increases the likelihood for success," she says. "Now that there is more time, it's just project management 101."
Still, McGlynn echoes other vendors' "angst about the quality measures," the approach to which represents a "significant change in the way quality measures have been done in the past."
And a big part of that angst is not yet "having all the information to truly assess that."
Is there enough guidance to at least get going?
"Certainly there's things that can be done," says McGlynn. "But the quality measure specifications really define a lot of that. And the test scripts really define the workflow you have to follow. … We can get started, but we don't have it all."