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Our Take on the Meaningful Use Comments

by Lauren H. Fifield, Senior Policy Advisor

If you read the athenahealth blog regularly, you know we tend to write about and discuss Meaningful Use.

Often.

We have a good reason. We have approached Meaningful Use the way we approach everything we do—by working with our providers to get them paid for doing the right thing. To that end, we offered the industry’s only incentive guarantee, established a Meaningful Use Resource Center for clients, held a multitude of MU webinars and created a cross-functional team to tackle each problem clients might face. And our CEO, Jonathan Bush, pulled a Full Monty (of his data) while in Las Vegas for the MGMA convention last October.

Our approach worked! We helped 85% of our eligible, participating physicians attest to the Stage 1 measures and receive their incentive payments.

With so much blood, sweat and tears invested in the Meaningful Use of our EHR by providers, we jumped at the opportunity offered by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) to provide comments in response to two sets of rules: The Meaningful Use Stage 2 Notice of Proposed Rulemaking (NPRM)—“CMS Rule”—and the 2014 Edition EHR Standards and Certification Criteria Proposed Rule—“ONC Rule”. In future posts, we’ll dig into key topics in greater detail but, for now, we thought it’d be helpful to summarize what we submitted on May 7th.

General Thoughts on the CMS and ONC Proposed Stage 2 Rules

We are highly encouraged by the inclusion and expansion of objectives and measures related to the exchange of health information, patient engagement, and quality reporting. The increased focus on these critical areas will lay the foundation for providers to leverage health IT to promote better care for individuals, improved population health and increased value in health care (aka the health care “Holy Grail”.)
Because there is often a variance between standards and their implementation, we believe a high degree of harmony between the ONC Rule and CMS Rule is fundamental to the Certified EHR Technology (“CEHRT”) vendors’ ability to help providers achieve Meaningful Use. We also think it’s vitally important for the ONC and CMS to create enough rules flexibility to encourage continued innovation. (PLEASE!)

In the specific case of health information exchange, we hope the ONC will consider the certification criteria as the minimum, baseline standard upon which existing and new means of electronic exchange can support providers in achieving Meaningful Use.

Last, we greatly appreciate the many ways CMS and the ONC have fostered a transparent rule-making process: public access to the Federal Advisory Committee meetings and recommendations; presence at industry events like the HIMSS12 conference; and, opportunities to participate in private-public collaborations. The efforts made by CMS and ONC representatives to educate the public on comment-making best practices have been great too.

Our Comments to the CMS and ONC

So, what did athenahealth contribute to the conversation? In our comments to CMS, we focused on:

  • Why the implementation of Stage 2 should not be delayed
  • Health Information Exchange
    • A logistically feasible, cross-vendor-and-organization alternative to the electronic provision of summary care record at transitions of care
    • Supply chain issues with incorporating lab results as structured data
  • Patient Engagement
    • An alternative to the proposed secure messaging measure
    • Considerations for the implementation of View, Download, & Transmit
  • How to aggregate data and attest with an EHR conversion

We also commented to the ONC about their Proposed Rule:

In addition to the nitty-gritty, technical issues, at a high level we also covered:

  • Reporting on Patient Safety Events and the vendor’s role
  • Support of a flexible and process-based approach to Quality Systems
  • Ideas on how to facilitate data portability
  • The importance of maintaining “Complete EHR” as a concept

Finally, we urged the ONC and CMS to continue driving transparency by a) continuing to make vendor, specialty and state attestation data publicly available; b) releasing registration-by-vendor data to inform providers during their EHR purchasing decisions; and, c) private-public sector collaboration.

So, now we wait. CMS will review 230 comments and the ONC will review 400. And what a range of comments they have to consider. To cite a few:

What do you think? How did you weigh in? We’ll keep you posted as the comments get reviewed during HIT Policy committee and HIT Standards committee meetings over the next couple of months. But now, we’d like to hear from you.

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