Archive for March, 2012

ONC Releases Tools and Comment Template for Stakeholders New to the NPRM Process

March 30, 2012 Leave a comment

The HHS Office of the National Coordinator for HIT (ONC) released resources and an optional public comment template for stakeholders new to the federal rulemaking process.  The tools are specific to ONC’s recent Notice of Proposed Rulemaking (NPRM) on the 2014 Edition EHR Certification Criteria, Standards, and Implementation Specifications.  CMS does not currently offer similar resources for its NPRM on Stage 2 of the EHR Incentive Program.

Federal agencies are required by law to review public comments received on NPRMs.  ONC rulemaking staff believe they will receive higher quality feedback by making the organizational resources available.

Categories: EHR, meaningful use, Medicare

ONC HIT Policy Committee-Quality Measures Workgroup Meeting

March 29, 2012 Leave a comment

On March 28, the HHS Office of the National Coordinator for HIT (ONC) HIT Policy Committee Quality Measures Workgroup held a teleconference to discuss specific aspects of the latest proposed rules regarding the EHR Incentive Program (or “meaningful use”).  The workgroup is one of several HIT Policy Committee subgroups and tiger teams expected to provide the full committee with draft comments on the rulemakings next week.

The Quality Measures Workgroup was primarily concerned with the alternative clinical quality measure (CQM) reporting mechanisms in CMS’ proposed rule, particularly the group reporting and Physician Quality Reporting System (PQRS)-related reporting options.

For group reporting, the workgroup would prefer to see batch file reporting of the CQMs (like the proposed alternative reporting option for the MU functionality objectives) instead of group-level measurement.  This preference would be the opposite of the HIT Policy Committee’s recommendation to the agencies last summer which called for exploration of group measurement options for all MU requirements, including the CQMs piece.

For the PQRS reporting-related alternative, the workgroup would prefer MU CQM reporting to be a substitute for PQRS and not the other way around.  CMS could decide to remove the reporting option from the future final rule, but the workgroup’s recommended “flip” would be unlikely to materialize without a separate rulemaking.

Categories: EHR, meaningful use, Medicare

Major Specialty Societies Meet with CMS Staff

March 23, 2012 Leave a comment

On March 21, the American Medical Association (AMA) convened the major specialty societies for a meeting with Centers for Medicare and Medicaid Services (CMS) staff regarding the agency’s Stage 2 EHR Incentive Program Notice of Proposed Rulemaking (NPRM).  CMS staff presented a similar slide deck to those used in other events and  provided an opportunity for questions and concerns. Staff from the Office of the National Coordinator for HIT were unfortunately not present to discuss the NPRM on the 2014 Edition EHR certification criteria, standards, and implementation specifications.

Several specialty societies have assigned “meaningful use”-related issues to their quality measurement staff, who are often not in the same department that handles regulatory affairs. Typically, these are the staff for the National Quality Forum endorsement and Physician Consortium for Performance Improvement processes.  So, many comments at the meeting were focused on the clinical quality measure component of CMS’ Stage 2 MU NPRM and various items having to do with the Physician Quality Reporting System reporting-related proposals.

I commended CMS staff for deviating in several key areas from the June 2011 ONC HIT Policy Committee recommendations, which did not factor in the robust recommendations and concerns from AMA and major specialty societies.  I thanked them for the addition of the imaging data access menu objective, but noted a specific problem with the language that will need to be addressed in the final rule.  I also suggested it would be better to remove the “no face-to-face” and “no followup” requirements for the non-proposed prospective fourth significant hardship exemption/exception category, as not being enabled by one’s facility with requisite technology/data constitutes a compliance barrier for hospital-located (but not “hospital-based”) EPs who may or may not have face-to-face interaction with patients.

Categories: EHR, meaningful use, Medicare

HIT Policy Committee and Meaningful Use Workgroup Meetings

March 8, 2012 Leave a comment

On March 6, the HIT Policy Committee (HITPC) Meaningful Use Workgroup held its first teleconference since the release of the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for HIT (ONC) Notices of Proposed Rulemaking (NPRMs or proposed rules) on Stage 2 “meaningful use” and 2014 Edition EHR certification criteria, standards, and implementation specifications.  The conversation about the CMS NPRM sometimes became heated as the workgroup members heavily scrutinized deviations from their June 2011 recommendations to the agencies.

Of note, during the discussion of CMS’ proposed Stage 2 clinical decision support (CDS) objective, workgroup members agreed that it would be better for at least one of the five CDS interventions to be tied to efficiency, particularly for prescriptions and image ordering.  It will be interesting to see how they plan to shape this recommendation, which is aligned with the American College of Radiology’s testimony on appropriateness CDS at the workgroup’s hearing regarding “MU and Specialists” on May 13, 2011.

On March 7, the full HITPC met to discuss the NPRMs and other issues.  The National Coordinator for HIT, Dr. Farzad Mostashari, began the meeting by passionately denouncing the Health Affairs article that claimed electronic access to images caused more tests to be ordered.  His criticism was published the night before on the Health IT Buzz Blog administered by ONC.

ACR Releases Draft Summary of Stage 2 Meaningful Use and 2014 Edition EHR Certification Criteria Proposed Rules

March 1, 2012 Leave a comment

Earlier today, the American College of Radiology released a draft-in-progress summary of the latest Notices of Proposed Rulemaking (NPRMs or proposed rules) from the Centers for Medicare and Medicaid Services (CMS) and the HHS Office of the National Coordinator for HIT (ONC) regarding the Medicare/Medicaid EHR Incentive Program (“meaningful use”).  ACR’s document will be regularly updated with edits and additional findings about the NPRMs.

As a reminder, NPRMs are merely intended to solicit public comment and should not be used by stakeholders for any other purpose, such as implementation planning or product development.

Categories: EHR, meaningful use, Medicare
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