Wednesday, June 17, 2009

Meaningful Use - The Start

The initial suggestions for Meaningful Use (MU) definitions have begun. This Matrix reviews the different categories and the Goals, Objectives and Measures in each one.

My initial thoughts were that the objectives were much too specific - they were defining the "means", not the "ends". However, with input from others, I then understood the gold is in the column titled "measures" - that is actually what will be defining whether someone gets their incentive bonus. At a high, strategic level- those seem closer to "ends" rather than "means" - which is satisfying since it allows for much more creativity and innovation in getting to those means.

On the other hand, I am not saying that they can all be done without many of the objectives- but hey, that is part of the cool thing about innovation – we don’t know yet what new ideas and technologies might pop up to better solve these problems. For example, instead of a doctor maintaining a med list at the point of care, perhaps a Data Warehouse collects all the billing codes, lab results, and meds from the pharmacies – and then uses some artificial intelligence to auto-create a problem list which can be used to create registries. In fact, that might be more accurate than relying on physician entered problem lists that are often pretty poor. In other words, there has to be some access somewhere to electronic data to make this work, but it does not all have to be physician entered into a single EMR…

So now we can dig into the details and ask some obvious questions:
- Are these the best measures, some are easily defined (eg % diabetics with HbA1C), but others do not have metrics captured in such an objective fashion (eg % smokers offered smoking cessation).
- We need more details about the format of these reports, and how we report them
- Will the government require all of them, or just a limited amount of the reports listed (similar to PQRS in which we only have to report 3 from a larger list).

I'll also make one suggestion - to include the concept of physician to physician messaging, both within an EMR, and across EMRs. I think that may be as or more important than sharing things like medication lists! But I did not see anything in any column in any year that talked about this really important functionality… they talked about access to shared data, but not about ability to send messages to doctors within your direct organization, or within your greater organization. I realize this may be looked at as more of a functionality, and thus contradicts my aversion to focusing on the “means” – but I hope somehow this is included.

Finally, the CCHIT folks have stated they will expand their defintions of certified EHR technologies- which is a good thing (assuming they set the standard to be used by HITECH). The result is that a variety of innovative approaches can then be taken to achieve meaningful use: Some docs will use a full functioning unified EMR, others might use a home grown system that patches together multiple components, and still others might just use HIT on the backend to reach the majority of the metrics required. In other words, it will be interesting to see how many of the measures could be achieved without requiring a physician to touch a keyboard at all (eg no data input). If we can accomplish that - then we may get both significant and meaninful use!

The HIT Policy Committee will accept public comment through June 26 on the just-released draft description of "meaningful use" of electronic health records. Comments should not exceed 2,000 words in length. Electronic comments are preferred and should be addressed to meaningfuluse@hhs.gov, with the subject line "Meaningful Use."

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