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Make Your Voice Heard: Urge ONC to Provide a Clear Roadmap and Harmonized Requirements for Reform

By Michelle Freed
Vice President
Achieve HIT/ARRA Program Office
McKesson Provider Technologies




In the first year of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program, 769 eligible hospitals (15% of the national total) and 20,864 eligible professionals (4% of the national total) attested successfully, according to CMS's November 2011 data. The small number speaks to the challenges providers are encountering on their journey to what is foundational to health reform.

In recent months, the Office of the National Coordinator for Health IT (ONC) has been asking for feedback on the journey to meaningful use. During a hearing held on Oct. 5, 2011, the HIT Policy Committee Meaningful Use Workgroup heard from multiple providers, payers, vendors and industry experts regarding what’s working, what’s not, and where they need to pay attention going forward. Common themes included:

  Complexity of the rules, resulting in many interpretations and unofficial guidance, such as
     FAQs and clarifications, that affect vendor development cycles and provider implementation
     and adoption efforts

  Specific objectives and requirements that fundamentally change existing practices and
     workflow, and require extensive process redesign and training

  Clinical quality measures that require data collection that surpass the Stage 1 requirements
     and rely on untested and problematic e-specifications. Some of these specifications are
     based on immature data standards not widely implemented, and do not align with similar
     measures used in other programs

  Clarity of long-term goals, objectives and desired outcomes are needed urgently for
     better planning within the industry

With so many mandates coming down in rapid succession, having a clear roadmap toward a unified destination will make the journey easier. In my recent testimony I urged the ONC to harmonize the selection of requirements and measures for the various programs related to health reform. For care to become more consistent, effective and efficient, the changes to delivery and payment systems must occur simultaneously, along with the Health IT infrastructure to support them. Stage 2 should serve as an achievable stepping stone to these reform goals.

Stage 2 Projected Timeline
The HIT Policy Committee submitted its final recommendations for Stage 2 to the Centers for Medicare & Medicaid (CMS) in the summer of 2011, and the proposed rule is expected to be published in early 2012. While no one can say whether CMS will adopt all of the recommendations, they do provide clear direction. General characteristics expected to be included are:

  Few new items, but all Menu items are anticipated to be converted to Core Requirements
  Greater focus on electronic exchange of information across care settings
  More requirements related to security and privacy

To alleviate a time crunch for providers who qualified for Stage 1 incentives in FY2011, CMS has adopted a Committee recommendation to allow a one-year delay in the start of Stage 2 for these providers only. And while the Clinical Quality Measures were not addressed in the final round of Committee recommendations, various workgroups have been scrutinizing them to resolve issues uncovered during Stage 1.

Make Your Voice Heard
To help ensure that policies can be implemented in the real world, I and several other McKesson executives have testified before and met with the ONC on an ongoing basis. Ken Tarkoff, senior vice president and general manager of RelayHealth, is on the Implementation Workgroup, and Arien Malec is on the HIT Standards Committee. While it’s important that McKesson and other vendors continue the dialog, no one can advocate for physicians, clinicians, patients and families better than the provider.

Following publication of the proposed rule, there will be a public comment period. This is a critical step in the policy-making process, and all comments provided by the public will be read. Take advantage of this opportunity to make your voice heard. With the added burden of ICD-10 fast approaching, it’s important to share your firsthand experience and recommendations for making Stage 2 efforts more efficient. Industry organizations including HIMSS, CHIME and AHA have strong advocacy programs designed to help members learn how to effectively influence policy.

We will know much more once the proposed rule is published. Even if we see substantially improved clarity and definition, however, we know the bar will be raised. So we encourage providers to continue defining and refining their roadmap, building adoption, and expanding e-reporting abilities with an eye not only on Stage 2 but also ICD-10, Stage 3 and health reform beyond.

Michelle S. Freed is vice president of McKesson's ARRA/Achieve HIT Program Office. She is charged with leading company-wide activities relative to ARRA and the broader healthcare reform activities. She is directing the interpretation and influence of policy, assessment of business impacts and opportunities, and optimization and delivery of solutions to our customers. Freed has more than 30 years of experience in the healthcare industry.



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