Provider alliance Premier Inc., in comments on initial draft criteria for Stages 2 and 3 of meaningful use, urges federal officials to not add new clinical quality measures until provider performance can be evaluated for Stage 1.

"Premier members are especially concerned about any increase in the number or sophistication of clinical quality measures for Stages 2 and 3--particularly when collection and reporting of Stage 1 measures is not yet underway," according to Premier's comment letter to the Office of the National Coordinator. Other comments include:

* Premier members are concerned that enabling patients to consent to giving providers piecemeal medical information will diminish care quality.

* Many data elements proposed for being offered to patients to view and download in a timely manner currently are not available in structured formats. "We recommend that the committee delay requiring any items currently without accepted structured formats, and require only structured elements such as problems, allergies and medications in the summaries."

* Requiring hospitals to discuss with patients the existence of an advanced directive is not feasible, since a hospital cannot compel such a discussion. "We believe the committee should recommend that hospitals only be responsible for asking a patient if he or she has an advance directive, and recording the patient's response accordingly."

* A proposed Stage 2 requirement that 20 percent of patients with high-priority health conditions have a longitudinal care plan is overly ambitious.

Premier's full comments are available here.

--Joseph Goedert


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