HIE Workgroup Takes CMS to Task for Proposed Stage 3 Rule
For the most part, the Health IT Policy Committees workgroups agree with the proposed Stage 3 meaningful use rule from the Centers for Medicare and Medicaid Services. However, the one glaring exception is the Interoperability and Health Information Exchange Workgroup which reported to ONCs advisory committee on Tuesday that it disagrees with the vast majority of Stage 3s HIE recommendations.
At a May 12 HIT Policy Committee meeting, four workgroupsthe Advanced Health Models and Meaningful Use Workgroup, Consumer Workgroup, Interoperability and Health Information Exchange Workgroup, and Privacy and Security Workgrouppresented their assessments of the Stage 3 proposal.
The Interoperability and Health Information Exchange Workgroup, chaired by Massachusetts eHealth Collaborative president and CEO Micky Tripathi, specifically looked at Stage 3s objective 7 on HIE which includes three measures, of which providers have to meet only two out of three (but must report on all three):
*Measure 1 calls for sending an electronic summary of care record for 50 percent of outgoing transitions or referrals.
*Measure 2 would require receiving and incorporating an electronic summary of care record for 40 percent of incoming transitions or referrals of new patients.
*Measure 3 would reconcile clinical information for 80 percent of transitions or referrals of new patients.
While Tripathi said the workgroup in general agrees with the direction and goals of the HIE measures, there are concerns about thresholds set unrealistically high.
Not because were opposed to higher thresholdswe very much support higher thresholdsbut we dont want to have to backtrack on the thresholds as has happened with view/download/transmit, Tripathi told the HIT Policy Committee. And,we certainly want to motivate providers to own the problem so we dont want to take that off the plate in terms of accountability. On the other hand, we dont want to be penalizing people for things that are genuinely out of their control.
He argued that you can balance thresholds with judicious allowance for exclusions, adding that you can set a high threshold as long as you allow some appropriate exclusions along the way, correspondingly if you get rid of all the exclusions then you probably need to lower the threshold in order to accommodate the real-world variation that exists out there.
In that vein, Tripathi said the workgroup took a look at Stage 2 meaningful use requirements, given that two out of three of the proposed Stage 3 measures (Measure 1 and 3) have direct connections to Stage 2. According to Tripathi, Stage 2 experience suggests that the Stage 3 thresholds are higher compared with performance to dates, and perhaps significantly higher given the small sample results to date.
As a result, among the workgroups recommendations is that Measure 1s threshold of sending an electronic summary of care record for 50 percent of outgoing transitions or referrals should be lowered to 40 percent. Stage 2 data suggests that the average provider could be well below 50 percent, Tripathi said. We do want to keep the rate high to motivate forward progress, so were not saying lets reduce it down to 20 percent We felt like we couldnt come in with a measure that was below the experience from last year. So, thats why were saying 40 percent would be our recommendation rather than 50 percent.
Likewise, the workgroup recommends that Measure 2s threshold of receiving and incorporating an electronic summary of care record for 40 percent of incoming transitions or referrals of new patients should be lowered to 25 percent. Our biggest concern is that this is a brand new measure and novel territory nationwide, commented Tripathi. We think that its inappropriate to raise [the bar] too high, and 40 percent is such a high bar By allowing some flexibility in how its done through some of the exclusions that were suggesting, we think that 25 percentthough it is a high bar for a new measureis something that can be accomplished.
Overall, the workgroup disagreed with 14 proposed Stage 3 recommendations, while only agreeing with 8 recommendations.
For its part, the Privacy and Security Workgroup reported to the HIT Policy Committee that it supports the Stage 3 proposal to increase the opportunities for patient access to information through the use of view/download/transmit technologies as well as open application programming interfaces. However, the workgroup also expressed concerns about potential privacy and security risks associated with increasing patient access to health information electronically.
The HIT Policy Committee on May 22 will hold a follow-up virtual meeting to hear the workgroups final comments on the proposed Stage 3 rule, at which time the committee will vote on the recommendations. In the meantime, slides from the May 12 workgroup presentations can be found here.