Halamka: Give us specifics, give us time on meaningful use proposals

Aggressive interoperability timelines require specific implementation guides and reference implementations, wrote John D. Halamka, MD, CIO at Beth Israel Deaconess Medical Center in Boston, in his blog, on which he summarized the comments he received from colleagues concerning the interim final rule (IFR) and notice of proposed rule-making (NPRM) for the proposed meaningful use definitions.

“[E]ither the standards need more detail, especially in the transmission area, or the NPRM goals need to be reduced in scope/extended in time,” Halamka said. He further reviewed his initial reactions and those of his colleagues on the two proposed regulations:

The Interim Final Rule on Standards

• Many believe the lab standards are not specific enough. If details like implementation guides are not added to rules that set a firm technical direction for Stage 2 with a minimum of two years advance notice for implementation, it will not be possible to achieve the policy targets of Stage 2 for structured information exchange until a later date.
• Transmission needs more detail.
• There is uncertainty how to implement the RxNorm requirement in Stage 1, whether EHRs internally must have one of the RxNorm source vocabularies or the requirement is that data exchanged from the EHR include one of these vocabularies.
• While emerging standards in the quality area such as Quality Reporting Document Architecture and Healthcare Quality Measure Format are not mature enough to require in Stage 1, giving implementers credit for early adoption would advance quality reporting.
• There is too much optionality in the security standards.

The Notice of Proposed Rulemaking

• The computerized physician order entry (CPOE) requirement should include emergency departments (ED). Many professionals believe the ED could be the first place to implement CPOE and the transaction volume would meet 10 percent of hospital orders.
• Many have said that the quality reporting requirement is "too much, too soon."
• The patient engagement requirements also are "too much, too soon." Vendors have commented that they do not understand how to send reminders to patients per their preference. Providing 80 percent of patients with a clinical summary of office visits or care transitions will require significant retooling of software and incremental staffing.
• Electronic medication reconciliation at each transition of care is challenging to implement technically and requires significant workflow redesign.
• There is no standard for submission of immunization, syndromic surveillance data or public health lab reporting, making this challenging to implement. Given that the transmission standards in the IFR lack detail and there is no national reference implementation to follow, there will be significant heterogeneity in each locality, creating a challenge for vendors.

A presentation to review the requirements of the IFR and NPRM proposals can be downloaded in a Jan. 13 post on Halamka's blog.