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Archive for February, 2012

CMS Stage 2 Meaningful Use Proposed Rule Released on OFR’s Public Inspection Desk

February 23, 2012 Leave a comment

Earlier this evening, the Centers for Medicare and Medicaid Services (CMS) released its Notice of Proposed Rulemaking (NPRM) for Stage 2 of the EHR Incentive Program (“meaningful use”).  The corresponding NPRM from the HHS Office of the National Coordinator for HIT (ONC) on EHR standards, implementation specifications, and certification criteria has not yet been released, although both documents were filed with the Office of the Federal Register (OFR) on the same date.  Both NPRMs are slated for formal publication in the Federal Register on March 7 with 60-day public comment periods.  The American College of Radiology will release an article on its website tomorrow, with in-depth regulatory analyses coming in the near future.

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Categories: EHR, meaningful use, Medicare

HIMSS 2012 – Stage 2 Proposed Rules Discussed for First Time; Will Be Released Tomorrow

February 22, 2012 Leave a comment

At the Healthcare Information and Management Systems Society (HIMSS) conference today, leaders and staff from the Centers for Medicare and Medicaid Services (CMS) and the HHS Office of the National Coordinator for HIT (ONC) provided an overview of the highly anticipated Notices of Proposed Rulemaking (NPRMs, or “proposed rules”) on Stage 2 of the EHR Incentive Program (or “meaningful use”). The CMS and ONC NPRMs will be viewable tomorrow via the Office of the Federal Register’s Public Inspection Desk, and will be formally published in the Federal Register soon thereafter with 60-day comment periods.

Per today’s CMS and ONC discussion, a number of items specifically requested by the American College of Radiology over the past several years will appear in the NPRMs in some form:

  • Images – The CMS NPRM will include a menu set functional measure related to viewing images, and the ONC NPRM will include a corresponding certification criterion. There will be differences between the Eligible Professional and Eligible Hospital versions of this functional measure.
  • Certified EHR Technology – Certification criteria that correspond with CMS functional measures from which an EP is excluded will not need to be covered by that EP’s technology unless the criteria in question are part of the proposed “base” of criteria needed to meet the statutory definition of certified EHR technology.
  • Encounters – There will be increased flexibility around defining encounters.
  • Registries – The NPRMs will include some requirements pertaining to cancer and specialty society registries.
  • Patient information – The patient information related functional measures will be consolidated and presumably more clear.
  • And more…

Much more was shared during today’s discussion, but it would be best to wait until the NPRMs are publicly available and digested to ensure accuracy. Stay tuned…

Categories: EHR, meaningful use, Medicare

HIMSS 2012 – CMS Town Hall

February 21, 2012 Leave a comment

I am attending the Healthcare Information and Management Systems Society (HIMSS) 2012 Annual Conference to monitor the educational offerings from the various participating federal agencies. During this morning’s Centers for Medicare and Medicaid Services (CMS) Town Hall session, Elizabeth Holland from the CMS Office of eHealth Standards and Services, indicated that the Notices of Proposed Rulemaking (NPRMs) from CMS and the Office of the National Coordinator for HIT (ONC) should be publicly accessible in a matter of days; perhaps as early as tomorrow. She also indicated that the CMS NPRM will likely be over 500 pages in length. When released, the American College of Radiology will review both NPRMs and provide summaries and other information on its website as usual.

CMS and ONC have targeted a February 2012 release of the NPRMs for a few months, but the likelihood it would happen decreased significantly with the late January submissions to the White House Office of Management and Budget (OMB) for review. Thus, it is somewhat surprising that the agencies might still meet the February goal.

I should also note for those unfamiliar with the federal rulemaking process that NPRMs are merely proposed versions of the rules released to solicit public comments. The future final rules from CMS and ONC will undoubtedly be significantly different.

Categories: EHR, meaningful use, Medicare

Meaningful Use Workgroup-Specialist Subgroup Discusses Draft Policy Recommendation on Image Sharing/Access

February 7, 2012 Leave a comment

During this morning’s HHS Office of the National Coordinator for HIT (ONC) HIT Policy Committee-Meaningful Use (MU) Workgroup teleconference, members of the Specialist Subgroup presented a draft recommendation on image sharing/access and MU.  The purpose of the draft is to provide policy direction to the HIT Policy Committee and HIT Standards Committee members as they begin to explore imaging related standards later this year.

Long-term goal: to improve the quality and efficiency of health care by promoting the sharing of clinical images among health care providers and with consumers.

Areas to be addressed in imaging:

  1. Standards 
  2. Viewing technology and incorporation into EHRs 
  3. Sharing of images

Example of the kind of objective that could be put forward for viewing:

Access at least one image using a viewing function that displays the image within the context of the patient’s health record; the viewing technology should have sufficient resolution and function to support in-office viewing.

Example of the kind of objective that could be put forward for sharing images:

Perform at least one test of the capability to exchange images among providers of care and patient authorized entities electronically.

Considerations:

  • The objectives must be assessed for feasibility. E.g., what are the cost implications for small practices? 
  • Consider limiting to “static” images such as X-rays and single shots of MRI scans, as opposed to the more complex 3-D or time series images (full MRI scans, catheterization movies, etc.). 
  • Need to assess the cost benefit of different levels of resolution and function for different uses such as second opinions or patient education. The first functions should be simple viewing without windowing or complex processing. 
  • How should consumer access (viewing and access control) be implemented? Like other HIE? 
  • Several architectures are possible, such as direct transfer of static images or images servers for all images, but we wish to remain neutral on architecture. 
  • How can we ensure sufficient time and resources to go from certification to implementation (standards, training, etc.) before expecting successful use? 
  • The requirements should be for sending as well as receiving (e.g., radiology, cardiology). 
  • The viewer should feel integrated into record, not just a link to sign into a PACS system. 
  • The interpretation should accompany the image for consumers. 
  • The objectives should cover EPs and EHs.
Categories: EHR, meaningful use, Medicare
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