On Thursday, CMS announced their intent to update the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs for 2015 and beyond, reducing the reporting burden on providers, while supporting the long term goals of the program.
A busy week. What does it all mean?
The CMS announcement includes planning for a Spring 2015 rule that:
- Realigns hospital EHR reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 Edition software into their workflows and to better align with other CMS quality programs.
- Modifies other aspects of the program to match long-term goals, reduce complexity, and lessen providers’ reporting burdens.
- Shortens the EHR reporting period in 2015 to 90 days to accommodate these changes.
It’s a positive sign that HHS leaders are listening and responding to stakeholders. Meaningful Use Stage 2 contains numerous goals that require an ecosystem/marketplace to develop first. The HIE marketplace is just developing and usable apps for patient view/download/transmit are still 6 months away. The new timeline gives us the flexibility we need to do these projects right, leveraging the market foundation that is developing.
The draft Interoperability Roadmap released by ONC describes the current market and issues in interoperability.
It aligns well with the work of the Jason Task Force, recognizing the role of the private sector and the importance of market-based networks. It supports the move to modern internet interoperability conventions (including RESTful APIs like FHIR)
It wisely suggests “non-government governance” for health information exchange rather than trying to create a single top-down nationwide governance entity.
It focuses on the importance of clarifying HIPAA to reduce confusion and misconceptions about HIPAA restrictions and enablers. For example, does everyone know there is no such thing as HIPAA certified software and there are no restrictions on giving patients access to their own data?
The Roadmap does have a few areas of concern. It suggests that States become more active in the area of interoperability. We need to be careful with this approach or else we’ll create 50 interoperability silos given variation in State laws. The new economic incentives of accountable care organizations will motivate vendors to address health information exchange needs based on business cases, not geography.
The Roadmap needs to describe a few more concrete steps that government should take to support the listed goals. Increasing value-based purchasing and having federal agencies accelerate standards-based interoperability are very good, but there are other levers to consider such as creating reusable components at scale (i.e. a nationwide provider directory), aligning quality measurement programs/aligning quality measure reporting with modern interoperability standards, and harmonizing other health care regulations with interoperability conventions (i.e. community health center, nursing home, and home health reporting and regulation).
ONC is currently accepting public comments and key commitments on the draft Roadmap for approximately 60 days which will end at 5pm ET on April 3, 2015.
The “Standards Advisory” companion document does specify some standards that are mature or becoming mature such as HL7 2.x, CCDA, and FHIR. However, it also includes standards that are not likely to achieve maturity based on the objective criteria outlined by the HIT Standards Committee. I would advocate for leaving some of the boxes blank, since no mature or becoming mature standards are available for them.
Overall, I give ONC kudos for their articulate summary of where the federal government would like the industry to focus. The market is making tremendous progress at this point, and the roadmap is a useful directional guide.