In Larry Wolf’s mind, the 2013 date for implementing Stage 2 electronic health records meaningful use criteria is too tight. Unless actions are taken in the next six months to specify the criteria, he fears providers and vendors will not have the lead time to achieve Stage 2 until 2014.

Wolf, health I.T. strategist at Louisville, Ky.-based Kindred Healthcare, and serving on the HIT Policy Committee as a designee of Kindred CIO Richard Chapman, broached the idea during December’s committee meeting. Following the meeting, David Blumenthal, M.D., national coordinator for health information technology, told Wolf that the government’s plan remains 2013.

But Wolf worries that the math doesn’t add up and providers and vendors won’t have adequate time to prepare for Stage 2 before it starts with hospitals in October 2012. The HIT Policy Committee, he notes, estimates providers and vendors need 18 months of lead-time to be ready for Stage 2, and even that is tight.


But the calendar calls for the committee to seek public comment on a new set of criteria in early 2011, finalize the criteria and make recommendations to federal officials, who then will write a proposed rule and issue it in late 2011. In the end, the final rule is likely in the summer of 2012 and that would be only three months or so before fiscal year 2013 starts.

Wolf is hearing of problems in getting ready for Stage 1. Some vendors are providing products that meet the letter of the criteria but are more a beta release than a full product, he says. Providers are finding that some of the issues they thought would be difficult are going well, such as physician order entry, but there are problems in other areas, such as measure reporting.

He’s pleased that public hearings in January will enable policymakers to learn what providers are going through as they work toward Stage 1 meaningful use, to help guide development of Stage 2 criteria.

There’s also a new wrinkle to developing new meaningful use criteria, as the President’s Council of Advisors on Science and Technology recently recommended creation and adoption of a “universal exchange language” for transmitting protected health information. Further, PCAST recommended having the language in place for Stage 2 criteria and the Obama Administration supports the recommendations.

But while Wolf worries that the 2013 deadline for Stage 2 is too tight, the recognition is that what the administration wants it likely will get, he acknowledges. And he doesn’t think getting a universal exchange language in place by then makes meeting the date impossible.

HIT Policy Committee members are in the process of learning what are in the PCAST recommendations and it’s too soon to know if a consensus is emerging, Wolf notes. But the committee will have to move quickly to get a language in place and there are ways to do that, he adds. The HIT Standards Committee in the early months of 2011 will recommend standards to anchor a universal exchange language. If the committee deems the Clinical Documentation Architecture of Health Level Seven, which supports clinical summaries, to be the standard, then having a universal exchange language in Stage 2 criteria becomes doable, Wolf believes. The CDA, he adds, has ways to tag metadata, which is a key component of a universal exchange language.

There will be work needed to identify the data elements to be exchanged and map a supporting subset of SNOMED CT codes, but all of the giant code set need not immediately be mapped, he adds. Further, it wouldn’t be a stretch for vendors to within six months modify their EHRs to support a universal language based on the CDA, Wolf says. The challenge is when to give vendors the signal that this is indeed the direction they need to go and that signal’s got to come well before the final rule.

So for now, the PCAST recommendations are a major focus, but there are ways that they could become game-changers, Wolf contends. Use of a universal exchange language, modifications of which are extensively used in other industries, would bring health data out of its proprietary fortresses with instructions on how to use the data. “We can then use data in more ways and that becomes a game-changer.”

 --Joseph Goedert


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