Stage 2 Meaningful Use NPRM To Be Published Tomorrow – OMG!

As everyone interested in Meaningful Use is already aware, an overview of the Stage 2 NPRM was presented at the annual Health Information Management Systems Society (HIMSS) today.  In addition to a presentation by CMS to standing room only audience, Dr. Farzad Mostashari (the National Coordinator for ONC) spent 45 minutes with a small group of physician informatics leaders (including the leadership of Doctors Helping Doctors); where he presented the main themes of Stage 2 MU.  Before I react to those themes, a few items to point out:

While Dr. Mostashari did mention a few specifics, I believe it wise not to discuss those specifics until we can spend time carefully reading the entire Proposed Rule – which will be published in the Federal Register on Thursday February 23rd.  As such, I won’t mention any specifics in this post.

  1. Dr. Mostashari specifically asked for commenters to remember that ONC and CMS can only use written comments submitted as per government regulations, during the 60d comment period, which starts tomorrow. 
  2. He also asked that commenters spend time commenting on proposed rules which they like, as well as one they find problematic – as without these positive comments, a few individuals with strong negative feelings can change a proposed rule that most everyone really likes.

What does this mean?  While Doctors Helping Doctors is not just about Meaningful Use, and not just about the optimization of health IT into clinical practice, Drs. Bria, Zaroukian and I will need to spend significant time reading this proposed rule, making sure we understand the details, and then create written comments on behalf of our various organizations.  Time spent on commenting on the Stage 2 proposed rule is not just for those of you who already attested for Stage 1 and thus ready for Stage 2. Stage 2 creates directional signals for measures that will impact doctors and vendors now, and thus adds important nuance even for those doctors who haven’t started Stage 1 yet. 

Themes for Stage 2 Meaningful Use

Dr. Mostashari started his presentation to us with some very thoughtful and reassuring words.   Here is my paraphrasing of his message…  “You spoke and we listened.  We know that Stage 1 presented challenges for many doctors, and in some cases doctors came to see Meaningful Use as a distraction, and not an opportunity.  We want Stage 2 to not just be Stage 1 plus… but rather an opportunity for most doctors to make their Meaningful Use journey meaningful to them and to their patients.  This means:

  1. Increasing flexibility, particularly for specialists
  2. Decreasing burden with participation in multiple reporting programs
  3. Accelerating interoperability and exchange capabilities with via a single standard for many data types (such as document summaries, labs, public health reporting)
  4. Providing more time for all providers to be successful with Meaningful Use and understand what must be done by what date to avoid negative payment adjustments in 2015
  5. Increasing focus on patient engagement
  6. Increasing focus on safe medical practice and using the EHR to improve safety

My first reaction to the general themes and the few specific examples mentioned – bravo ONC and CMS!  As someone who has sat on a variety of committees and workgroups throughout the development of Meaningful Use – I have heard several approaches that aim to get all (or most all) of the nation’s doctors on board with Meaningful Use.  And one of these approaches advocated for a “full steam ahead / take no prisoners” approach.  The rationale was doctors will be in compliance when they are forced to – so let’s just force them to do what we believe needs to be done.  The approach and themes I heard today fortunately took a different tact.  Yes, we can force doctors to comply, but if we do so, we end up with begrudging acquiescence. 

And doctors who feel devalued will respond to Dr. Mostashari’s call for Stage 2 as the time to make Meaningful Use meaningful by instead figuring out how to be minimally compliant so that they can get paid.  Rather, as we are all invited to rise to the occasion and leverage this new flexibility and focus of Stage 2, I am hopeful that the vast majority of us will accept Dr. Mostashari’s challenge, and use the next 2 years of Stage 1, and the subsequent 2 years for Stage 2 to not just find meaning in Meaningful Use, but where it doesn’t exist, to create it.

Returning both feet to the ground for a moment. ..  As I mentioned at the beginning of this post, Drs. Bria, Zaroukian, and I will soon be “heads down” in the minutia of Stage 2.  We will regularly pick our heads up however, as the lessons from Stage 1 are just beginning to be written.  After all, as only a minority of doctors has successfully attested for Stage 1, most of the voices for making Meaningful Use meaningful have yet to speak; and we want Dr. Mostashari to be able to say, “You are still speaking, and we are still listening.


About Peter Basch, MD

Medical Director, Ambulatory EHR and Health Information Technology Policy
MedStar Health

Washington, DC

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