HIMSS: Stage 2 proposed rule includes dynamic EHR model

LAS VEGAS—The Stage 2 meaningful use proposed rule includes a new plan for dynamic EHRs, Steven Posnack, MHS, director, federal policy division, Office of the National Coordinator of Health IT (ONC), said during a presentation at the 2012 Healthcare Information and Management Systems Society (HIMSS) conference.

EHRs should speak to more than one audience, he said, and the rule informs providers of the EHR technology they must demonstrate meaningful use and conveys to developers what their customers will need to meet meaningful use. “There are two sides of this coin and we’re trying to structure to support both.”

Posnack and his colleagues said several times that they reviewed the meaningful use program with a “fresh look” and “there’s a clarity we’re trying to bring to make EHRs more intuitive.”

The new EHR model includes a base EHR that will meet 2014 EHR certification criteria, he said. That base EHR serves as the center of a bull’s eye model and then building outward, there will be core and module EHRs. Users are familiar with complete and modular EHRs, he said, and those two categories will continue to exist. Providers can meet the definition of a base EHR with either a complete EHR or a combination of module EHRs. “There is not a specific, finite construct,” he said, referring to the ONC’s effort to offer flexibility and decreased regulatory burden.

Providers need only use EHR technology with the capabilities of meaningful use core set objectives and measures for the stage of meaningful use they seek to achieve unless they can meet an exclusion. “No longer is the definition of EHR technology built to set, 100 percent criteria. Rather, it is driven by the meaningful use stage the provider needs to meet. The market needs to react and vendors need to supply different pathways. This is going to be an area where supply and demand need to meet. We think it will be worked out in a logical fashion.”

This new flexible and dynamic definition means there will be three ways to meet certified EHR technology requirements: complete EHR, EHR modules and a combination.

The one-year extension of Stage 1 includes a transition period, he said. “We recognize that there will be rollouts and upgrades during 2013” so the rule permits hybrid systems during that period so that users will still have something that meets the definition of certified EHR technology.

Posnack also said that the online sections provided for the 60-day comment period include a new comment template laying out the criteria and the ONC will make grids and educational materials available.