HIMSS VP of informatics outlines concerns with meaningful use
“We would like to identify three specific areas of concern regarding standards selection for Stage 1 meaningful use,” said Joyce Sensmeier, MS, RN-BC, HIMSS vice president of informatics, during a hearing at the U.S. House of Representatives Committee on Science and Technology Subcommittee on Technology and Innovation last week.
According to Sensmeier’s written statement, HIMSS was asked by the Subcommittee to address:
Until transport standards are identified, “EHR vendors will be forced to support all available transport methods or risk developing software that may not meet future interoperability needs. This lack of guidance creates marketplace confusion and wastes existing resources, ultimately delaying progress,” she wrote.
“Second, we would like to express concern regarding the selection of multiple standards for the same criterion, such as selection of two clinical summary content standards—Continuity of Care Records (CCR) and Continuity of Care Documents (CCD). When two standards are selected, vendors and providers have to choose to support one standard, or instead, support both, which is very costly, resource-intensive and minimizes interoperability capabilities across organizations. It is our recommendation that only one standard is selected for each criterion in future stages of meaningful use.
“Our third area of concern is the timing of identifying and publishing the selected standards in subsequent rules, which is critical to ensure that the industry can appropriately incorporate the standards into the product development and implementation cycle,” she wrote. “Thousands of EHR systems are currently being developed and upgraded by vendors and implemented by healthcare providers … To ensure optimal software development, testing, and safe implementation by providers, the final rules for meaningful use and certification criteria should be available 18 months before the next stage of meaningful use commences.
A centralized, coordinated process is needed for engaging standards development and harmonization organizations, such as Integrating the Healthcare Enterprise (IHE), in meeting the needs for interoperability and information security standards for EHRs, said Sensmeier. Government can enable this standards coordination process, but a neutral, uniform approach is necessary to ensure transparency, stakeholder representation, healthcare leadership, industry engagement, impartiality and balance. “A timely evaluation of the optimal process for standards coordination is needed to address this urgent and important need,” she wrote.
HIMSS was pleased that the Final Rule established standards criteria for supporting Stage 1 of meaningful use, including a general relaxation of implementation of the drug-drug and drug-allergy interaction checks; maintenance of an active medication list; addition of structured lab test results; and removal of the requirement to submit electronically in Stage 1.
However, “we were disappointed that HHS did not further leverage HITSP and other harmonization work, such as IHE,” she wrote.
HIMSS urges the Centers for Medicare & Medicaid Services, ONC and National Institute of Standards and Technology to ensure that all contractual engagements for standards harmonization and coordination efforts:
“The HITECH Act set the vision for transforming the healthcare setting and these final rules are key components in implementing that vision. To achieve HITECH’s vision, we recommend that HHS address the following:
“Finally, HIMSS urges HHS to publish criteria pertaining to Stage 2 meaningful use at least 18 months before the beginning of Stage 2. This will enable sufficient time to develop, test, and deploy software conforming to these standards and implementation guides so that all eligible users can become meaningful users.
“HIMSS is concerned that meaningful use and interoperability will be hindered if two key areas, a patient identity solution and security of personal health information, are not addressed," she concluded.
According to Sensmeier’s written statement, HIMSS was asked by the Subcommittee to address:
- The progress of the Office of the National Coordinator for Health IT (ONC) since the passage of the HITECH Act in meeting the need for interoperability and information security standards for EHRs and health IT systems; and
- The strengths and weaknesses of the current health IT standards identification and development process, and what the top standards-related priorities should be for future health IT activities.
Until transport standards are identified, “EHR vendors will be forced to support all available transport methods or risk developing software that may not meet future interoperability needs. This lack of guidance creates marketplace confusion and wastes existing resources, ultimately delaying progress,” she wrote.
“Second, we would like to express concern regarding the selection of multiple standards for the same criterion, such as selection of two clinical summary content standards—Continuity of Care Records (CCR) and Continuity of Care Documents (CCD). When two standards are selected, vendors and providers have to choose to support one standard, or instead, support both, which is very costly, resource-intensive and minimizes interoperability capabilities across organizations. It is our recommendation that only one standard is selected for each criterion in future stages of meaningful use.
“Our third area of concern is the timing of identifying and publishing the selected standards in subsequent rules, which is critical to ensure that the industry can appropriately incorporate the standards into the product development and implementation cycle,” she wrote. “Thousands of EHR systems are currently being developed and upgraded by vendors and implemented by healthcare providers … To ensure optimal software development, testing, and safe implementation by providers, the final rules for meaningful use and certification criteria should be available 18 months before the next stage of meaningful use commences.
A centralized, coordinated process is needed for engaging standards development and harmonization organizations, such as Integrating the Healthcare Enterprise (IHE), in meeting the needs for interoperability and information security standards for EHRs, said Sensmeier. Government can enable this standards coordination process, but a neutral, uniform approach is necessary to ensure transparency, stakeholder representation, healthcare leadership, industry engagement, impartiality and balance. “A timely evaluation of the optimal process for standards coordination is needed to address this urgent and important need,” she wrote.
HIMSS was pleased that the Final Rule established standards criteria for supporting Stage 1 of meaningful use, including a general relaxation of implementation of the drug-drug and drug-allergy interaction checks; maintenance of an active medication list; addition of structured lab test results; and removal of the requirement to submit electronically in Stage 1.
However, “we were disappointed that HHS did not further leverage HITSP and other harmonization work, such as IHE,” she wrote.
HIMSS urges the Centers for Medicare & Medicaid Services, ONC and National Institute of Standards and Technology to ensure that all contractual engagements for standards harmonization and coordination efforts:
- Incorporate HITSP and IHE work products and test tools;
- Complement each agency’s efforts when creating testing procedures, testing tools and services, and reference implementations; and
- Embrace transparent, open consensus processes with the private sector.
“The HITECH Act set the vision for transforming the healthcare setting and these final rules are key components in implementing that vision. To achieve HITECH’s vision, we recommend that HHS address the following:
- Publish implementation guidance (such as IHE and HITSP interoperability specifications) for all selected standards;
- Publish data transport, financial transactions, security and health information exchange standards as soon as possible;
- Publish the process and schedule for harmonizing standards and developing implementation specifications;
- Set up one repository (such as the National Library of Medicine) for licensure and access to all standards and implementation guides; and
- Publish, as soon as possible, federal health IT best practices guidelines.
“Finally, HIMSS urges HHS to publish criteria pertaining to Stage 2 meaningful use at least 18 months before the beginning of Stage 2. This will enable sufficient time to develop, test, and deploy software conforming to these standards and implementation guides so that all eligible users can become meaningful users.
“HIMSS is concerned that meaningful use and interoperability will be hindered if two key areas, a patient identity solution and security of personal health information, are not addressed," she concluded.