HIT Policy Committee debates Stage 3 requirements

Several Health IT Policy Committee workgroups presented their assessments of the Meaningful Use Stage 3 proposal on May 12 with much agreement but some definite objections.

The Interoperability and Health Information Exchange Workgroup disagrees with the vast majority of Stage 3’s HIE recommendations, particularly thresholds they deemed too high.

At a May 12 HIT Policy Committee meeting, four workgroups—the Advanced Health Models and Meaningful Use Workgroup, Consumer Workgroup, Interoperability and Health Information Exchange Workgroup, and Privacy and Security Workgroup—presented their assessments of the Stage 3 proposal.

The Interoperability and Health Information Exchange Workgroup, chaired by Massachusetts eHealth Collaborative president and CEO Micky Tripathi, specifically looked at Stage 3’s objective 7 on HIE which includes three measures, of which providers have to meet only two out of three (but must report on all three):

• Measure 1 calls for sending an electronic summary of care record for 50 percent of outgoing transitions or referrals.
• Measure 2 would require receiving and incorporating an electronic summary of care record for 40 percent of incoming transitions or referrals of new patients.
• Measure 3 would reconcile clinical information for 80 percent of transitions or referrals of new patients.

Tripathi said the workgroup in general agrees with the direction and goals of the HIE measures. "We want to motivate providers but we don't want to have to backtrack," he said, citing the lowered thresholds for view/download/transmit requirements. "We don't want to penalize people for things that are genuinely out of their control." Tripathi said the group recommends setting a high threshold only if exclusions are allowed.

The workgroup recommends lowering the threshold for measure 1 from 50 percent to 40 percent and measure 2 from 40 percent to 25 percent. “Our biggest concern is that this is a brand new measure and novel territory nationwide,” Tripathi said of measure 2. “We think that it’s inappropriate to raise [the bar] too high, and 40 percent is such a high bar…By allowing some flexibility in how it’s done through some of the exclusions that we’re suggesting, we think that 25 percent—though it is a high bar for a new measure—is something that can be accomplished.”

The workgroup agreed with the idea of any electronic means for governance, Tripathi said, which is the current approach. "We believe that providers should have flexibility in the electronic means they use to meet the objective. At some point in the future a more assertive role might be required." They also suggested excluding certain specialists. He noted that the JASON Task Force recommended a series of escalating nonregulative steps to get the ball moving.

That approach is "not in touch with the realities of where things are with accountable care," countered David Bates, MD, MSc, of Brigham and Women's Hospital in Boston. Citing the high rate of in-network referrals within integrated delivery systems, he said referrals should move back and forth. "If you look at [referrals] outside of the network, it's a small percentage of all referrals and most of those are very different." Excluding the vast majority would create problems, he said.  

Overall, the workgroup disagreed with 14 proposed Stage 3 recommendations, while only agreeing with 8 recommendations.

The Advanced Health Models and Meaningful Use workgroup divided their content into small groups. The quality measures group was concerned about the "downstream impact when stability is upset by updates. We would like annual updates to be limited to changes that do not have significant impact on physician workflow," said Joe Kimura of Atrius Health.

There is a "great pressing need to capture information that doctors value," said David Lasky of Pacific Business Group on Health. "The ability to discern value is going to be based on EHRs and interconnections between them. If we can’t build measurement in the next 3-4 years, we'll be at a terrible disadvantage in terms of rewarding providers based on not very good information." It's tme to make quality measures a priority element in the recommendations for Stage 3, he added.

The Consumer Workgroup focused in on patient-generated health data and said they need to be provider requested, said Chair Christine Bechtel. That answers several questions and concerns stated in the proposed rule, she said, such as whether it is automated and how to plan for collection. "If provider-requested it hopefully means providers are working with patients to determine which data to collect and the mechanism for getting it into the record."  

The Privacy and Security Workgroup supports the Stage 3 proposal to increase the opportunities for patient access to information through the use of view/download/transmit technology and open application programming interfaces. However, the workgroup also expressed concerns about potential privacy and security risks associated with increasing patient access to health information electronically.

Chair Deven McGraw, JD, MPH, was obviously frustrated with the committee's response to the workgroup's assessment and recommendation, asking the members for specific items to consider if they sought changes.

The HIT Policy Committee will vote on the recommendations at a May 22 meeting.