Health Data Management recently asked John Halamka, M.D., CIO at Beth Israel Deaconess Medical Center and co-chair of the HIT Standards Committee that advises federal agencies, if the healthcare industry needs Stage 3 of the electronic health records meaningful use program. Here is his answer:

Meaningful Use Stage 1 and 2 created an important foundation. However, only now is the private sector catching up from the backlog of deferred work. The private sector Argonaut Project is accelerating interoperability, but is not yet mature. A delay in MU Stage 3 would actually improve adoption of EHRs and innovation in data exchange.

Also See: Argonaut Project for Interoperability Nears Completion of First Phase

Since I have been a CIO, over 300,000 pages of new healthcare regulations have been published. Although each of these may be well meaning and reasonable on its own, the combined effect of ACA, ICD-10, Meaningful Use, and the HIPAA Omnibus rule has been to co-opt the IT agenda from the stakeholders.

Some of this was needed. I would argue there was a market failure in adoption of EHR technology, so we needed Stage 1 to level and set the capabilities of every hospital and clinician.

Stage 2 was rushed into a marketplace that was not ready for it. There are certain enablers - a national provider directory with Direct (secure messaging) addresses, a master patient index with probabilistic or voluntary national identifiers, governance, a trust fabric, and cultural change - that were necessary pre-requisites to the Stage 2 interoperability requirements.

In some ways, Stage 2 required cars before highways were built. It’s time to pause, give the vendors and providers a chance to work together to meet growing market demands for care coordination, and reassess the helpfulness of further regulation.

As written, the Stage 3 Meaningful Use rule is salvageable for the future. It needs to be scoped more tightly and the thresholds have to be decreased, since many are not achievable today. After 20 years of engaging patients, Beth Israel Deaconess has regular secure electronic communications with 25% of patients. The other 75% have chosen other means. Requiring 35% in regulation is not reasonable.

The Stage 3 certification rule needs to be rewritten from scratch. It is decoupled from the Meaningful Use program and includes lists of standards that are not used anywhere in production in the world. I support offering a standards advisory document outside of regulation - highlighting emerging standards that are likely to be fit for purpose in the future. Requiring them in regulation will not help anyone. Including them as optional standards in regulation outside of the Meaningful Use program will just cause market confusion.

In summary, let’s delay Stage 3 entirely, and reassess our position in 2018, after the private sector has enhanced products to meet the business demands of stakeholders.

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