Doug Fridsma presented the S&I update. Importantly, a new initiative has been launched to coordinate decision support and clinical quality measures as related activities. EHRs should provide alerts and reminders from pathways, protocols, and guidelines intended to improve quality. Also, a new initiative will connect EHRs and the Prescription Drug Monitoring Program (PDMP) to improve workflow, hopefully supporting single sign on and patient context passing so that PDMP data is one click away from any EHR.
Steve Posnack reviewed the 2015 Certification Notice of Proposed Rule Making, highlighting the changes from 2014. He noted that the concept of the Complete EHR is no longer needed. Providers buy the certified technology they need to attest and it may be that modules, an EHR, and an HIE meet all the attestation needs, not a single monolithic product. The Implementation Workgroup will review the impact of the 50 new proposals in detail and we will discuss them at the April meeting.
I presented a task force review of the 19 Meaningful Use Stage 3 proposals.
Below are a few comments from the task force and the Standards Committee members. Although the bulk of our comments focused on standards maturity, we also commented on provider impact and development difficulty, hoping to offer helpful “in the field” feedback to the Policy Committee.
Clinical decision support - it would be very challenging for an EHR to track every response to every decision support intervention and no standards exist for such tracking. Maybe the best way to encourage decision support is via payment reform which links outcomes to pay.
Order tracking - there are standards for closed loop lab ordering but not closed loop referral workflow. The Harvard Risk Management Foundation recently funded a project to define all the steps in closed loop referral management, pictured below. Given the lack of standards and the development burden of this workflow, a focus on lab seems most appropriate.
Demographics/patient information - although standards exist for occupation and industry, other new demographic standards such as gender identify and sexual orientation are a work in process. Here’s a great reference describing one approach. There could be a significant impact on EHR development if new demographics selections affect patient education materials, decision support, and quality measures.
Advance directive - a pointer to an advanced directive such as a URL would require little development and the standards are mature.
Electronic notes - Although the standards to transmit free text within a clinical summary are mature, the “high threshold” (likely over 50% of patients to have notes) could be a high burden first step.
Hospital labs - The HL7 2.51 standards are mature but a minority of hospital reference labs support comprehensive LOINC codes.
Unique device identifiers - The standard is well described but the implementation difficulty could be high if the electronic record had to validate the UDI against a national database and enable reporting on UDIs in the case of recalls.
View, download, transmit - the standards for clinical summaries are mature except for the representation of structured family history. The requirement to make data available to patients within 24 hours could present workflow challenges.
Patient generated health data - certifying multiple methods of data capture creates a burden on developers. Maybe a less prescriptive approach, focusing on the ability to receive patient data in some fashion would be best.
Secure messaging - overly prescriptive workflows could force the retooling of existing high functioning products. Maybe a less prescriptive approach, focusing on the ability to support effective patient communication would be best.
Visit Summary/clinical summary - the nature of the clinical summary text (structured, unstructured, timeliness) could have workflow and development implications.
Patient education - the requirement is for only one language other than English and the Infobutton standard can support this. A single language other than English may not achieve the policy outcome desired.
Notifications - although the HL7 admit/discharge/transfer standards are mature, the notion of gathering the Direct addresses of care team members and sending event data via Direct is a novel workflow.
Medication Reconciliation - identical to stage 2, no concerns
Immunization history - The HL7 2.51 content and CVX vocabulary standards are mature. The transport specification created by the CDC (SOAP) is well tested. The questions we raised - is there a role for Direct in transmitting immunization data to registries since Direct is used for other transmissions in Meaningful Use? Is REST an alternative to all Meaningful Use “push” and “pull” transactions. The public health community is passionate about the use of SOAP. There are pros and cons to using something different for public health transport than other areas of Meaningful Use, so it is likely there will be further discussion.
Registries - the development effort required to submit provider chosen data elements to registries would be significant. Standards do not exist for this purpose.
Electronic lab reporting - identical to stage 2, no concerns
Syndromic surveillance - identical to stage 2, no concerns
There will be more discussion in upcoming meetings as both FACAs recommend iterative improvements as input before rule making.
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