Halamka, Tripathi weigh in on Stage 3 proposed rule

Commentary on the proposed rule for Meaningful Use Stage 3 keeps coming. CIO of Beth Israel Deaconess Medical Center in Boston, John Halamka, MD, and Micky Tripathi, president and CEO of the Massachusetts eHealth Collaborative, penned their thoughts on the good, the bad and the ugly of the rule, which was published on Halamka's blog, Life as a Healthcare CIO.

Under good, the authors called the rule a good first draft that streamlines and consolidates "a lot of the stray threads from MU Stages 1 and 2." The proposed rule also identifies several potential certification candidates but doesn't "lock in those standards before they are mature and market-tested."

The MU rule makes a practical leap into query-based exchange by requiring receipt of records from other entities and patients are given a high priority.

Under bad, Halamka and Tripathi said alignment of clinical quality measures (CQMs) with other Centers for Medicare & Medicaid Services (CMS) programs is good, but the details on CQMs won't be provided until later this year. However, "we’re asked to weigh in now on quality measurement policy issues (such as whether all products should be required to support all measures) absent important information such as how many measures CMS is considering, whether they are all well suited to EHRs, and if they would be generally applicable to all EHR products."

The authors named several other problems including the concept of decoupling, a lack of prioritization and the proposal of some standards that are not sufficiently market-tested.

Under ugly, Halamka and Tripathi cite a high threshold rate--80 percent--for performance of clinical information reconciliation. On top of all the other requirements facing providers, "the collective burden is making practice impossible.

"The sheer number of requirements may stifle innovation and reduce the global competitiveness for the entire U.S. health IT industry by over-regulating features and functions with complicated requirements that only apply to CMS and U.S. special interests. The certification criteria are often not aligned with what EHR users ask for. In some cases, the criteria are completely designed to accrue benefits to people who aren't feeling the opportunity cost. So if certification is loaded by non-EHR users, EHR users are going to find that even if the MU objectives are fewer in number and more focused, that their EHRs are focused on a lot of things they haven't asked for."

The authors call for public discussion about who should prioritize EHR development. "The work of the country over the next few months needs to be achieving a consensus about what should be in the certification rule and what should be removed. If industry, academia, clinicians, payers and patients can align on a minimal set of requirements, we're confident ONC will listen."

Read the complete blog post.