The conversation continues regarding the effectiveness, appropriateness, and reasonableness of the EHR meaningful use criteria proposed earlier this year.
The Health Information Technology (HIT) Policy Committee, a federal advisory committee, recommended many changes, some significant, to the EHR meaningful use proposed rule in a recent draft letter to National Coordinator for Health Information Technology David Blumenthal.
The committee's comments and recommendations include the following:
1. The committee disagrees with the proposed rule when it states that electronic progress notes are not directly related to improvements in patient care, quality, safety, or efficiency. The committee believes this is true for many reasons, including that handwritten records take additional time to decipher and are often illegible, and because it believes hybrid record systems "cause fragmentation of the record and inefficient workflow." For these and other reasons, the committee suggests the final rule contain an explicit requirement to include progress notes as part of the EHR.
2. The committee found that after reviewing the proposed core measures, none met its criteria for inclusion and thus recommends removing the proposed Stage 1 core measures.
3. The committee believes providers should maintain updated problems, medications, and allergy lists, but the proposed one-time reporting measure doesn't adequately demonstrate meaningful use. It notes that CMS could audit randomly selected charts instead of requiring a single report.
4. The committee believes that eligible professionals (EP) and hospitals should report on "the percentage of patients for whom they use the EHR to suggest patient-specific education resources," and that EPs should also report on "the percentage of all medication entered into the EHR as a generic formulation," when applicable.
5. The committee suggests that while the proposed meaningful use requires EPs and hospitals to implement five clinical decision support rules "relevant to specialty or high clinical priority, including for diagnostic test ordering," this language should be amended to highlight the importance of efficient diagnostic test ordering by requiring that at least one of the five support rules address diagnostic test orders
6. The committee recommends expanding the proposed measures for the preventive/follow-up reminders criterion to more than just patients older than 50. However, the committee does allow for provider discretion regarding the focus of those efforts, such as for a chosen preventative service.
7. The committee recommends that the final rule clarify the definitions of transitions of care and relevant encounters.
8. The committee believes the meaningful use incentive program should "contain some inherent flexibility," and "recognize providers who make good progress" toward meeting Stage 1 meaningful use criteria, even though they may not meet all of the requirements. Therefore it recommends that providers be permitted to defer fulfillment of a small number of requirements until Stage 2 criteria apply.
The proposed rule is open for comments through March 15. The final rule is expected in late spring.
Andrea Kraynak, CPC, is senior managing editor of Medical Records Briefing and HIM Connection. She may be reached at akraynak@hcpro.com.