HIT Standards CommitteeHIT Standards CommitteeMeaningful Use Workgroup Meaningful Use Workgroup UpdateUpdatePaul Tang, Palo Alto Medical Foundation, ChairGeorge Hripcsak, Columbia University, Co-Chair

April 20, 2011

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Workgroup MembershipCo-Chairs:Paul Tang Palo Alto Medical FoundationGeorge Hripcsak Columbia University

Members:• David Bates Brigham & Women’s Hospital• Michael Barr American College of Physicians• Christine Bechtel National Partnership/Women & Families• Neil Calman Institute for Family Family Health• Art Davidson Denver Public Health• Marty Fattig Nemaha County Hospital• James Figge NY State Dept. of Health• Joe Francis Veterans Administration• David Lansky Pacific Business Group/Health• Deven McGraw Center/Democracy & Technology• Judy Murphy Aurora Health Care• Latanya Sweeney Carnegie Mellon University• Karen Trudel CMS• Charlene Underwood Siemens

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Agenda

• Overview of MU WG’s work plan• High-level summary of comments• Review HITECH statutory constraints• Discussion of timing options

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MU Stage 2 Recommendations Work Plan• Hearings on stage 2 in 2010:

– Specialists; smaller practices and hospitals– State issues– Health care disparities– Patient and family engagement– Population and public health– Care coordination

• Dec, 2010 HITPC feedback on initial stage 2 draft criteria• Jan, 2011 Request for Comment (due Feb 25, 2011)• Mar, 2011 ONC summarizes 422 organizational comments• Apr/May: MU WG revises draft recommendations in response to RFC input,

other WG recs (e.g., IE, P&S, PCAST, QM)• May 11, 2011: Present revised set of stage 2 MU recommendations to

HITPC• May 13: Hearing on specialists and feedback from field• June 8, 2011: Final stage 2 MU recommendations for HITPC approval

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High-Level Summary of Comments -- 1 • 422 organizations submitted comments• Changes to existing objectives generally supported

– Some question as to degree (such as increasing threshold and broadening the definition, e.g., CPOE)

• Strong support for these new objectives:– eRx for discharge prescriptions– Electronic clinical progress notes– Electronic medication administration record– Patient-provider secure messaging– Recording patient preferences for communications

• Mixed support for these new objectives:– Advanced directives for EPs– View & download longitudinal record– List of care team members– Longitudinal care plan

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High-Level Summary of Comments -- 2

• Concerns about new objectives often related to:– Clarity of definitions/expectations– Timeline for developing and implementing new functionality

• Request for recording structured family health history data

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HITECH Statutory ConstraintsImpact on Meaningful Use Stages Timeline

• Medicare incentives are front-loaded (max for EP: 2011-12; Hospitals: 2011-13) and diminish over time; In Medicaid, can receive full payment as long as 6 qualifying years of payment by 2021

• No incentives if not meaningful user by 2014 for Medicare• Final payments in 2016 for Medicare, 2021 for Medicaid• Medicare penalties for failing to qualify as meaningful user

begins in 2015 for Medicare; no penalties under Medicaid• Criteria for qualifying as meaningful user can be raised by HHS

beyond 2015

Incentive policy lever is front-loaded; Medicare penalties persist

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Timing of Stage 2

• Some support current timeline (e.g., consumers /purchaser, health plans, disease management organizations)

• Some propose lengthening timeline (e.g., hospitals, physicians, EHR vendors)

• Timing issues:– EHR vendor development time (e.g., specification, development, testing, deployment)– Provider implementation and training time– HIE governance time (e.g., trust-building, policy development, standards

implementation)

• For new functionality:– Final Rule/Certification criteria vendor development provider implementation

reporting period MU qualification for incentives

• For existing functionality (already certified):– Final Rule provider implement increment reporting period MU qualification

for incentives

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Illustrative Timing Options for Stage 2

1. Maintain current timeline and one-year reporting period; or2. Maintain current timeline and permit 90-day reporting period (gain up

to 9 months delay); or3. Delay transition from stage 1 to stage 2 by one year (providers could

get third-year payment for meeting stage 1 expectations); or4. Phase-in approach that separates existing from new functionalities

1. 2013: Stage 2a using existing certified EHR functions with all-core objectives, increased performance thresholds and new quality measures

2. 2014: Stage 2b objectives requiring new EHR functionalities take effect

5. Other?

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Summary

• General support for stage 2 recommendations• Some new requirements need further clarification and

attention to some detailed questions• Significant concern about time required for

development and implementation of new functionality• MU WG is working on reconciliation of comments and

addressing details of new requirements• Will present full draft recommendations at May 11

HITPC meeting for feedback prior to final recommendations on June 8

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