Today, here's my top 10 list of the bolder aspects of the final rule.
1. Hospital labs must provide results to community clinicians in structured electronic format - paper and fax goes away.
2. A requirement for cross-vendor transition of care health information exchange will force functional interoperability by requiring disparate applications to use common content, vocabulary and transmission standards over the wire.
3. "Incorporate" data after receipt of structured documents combined with a requirement for decision support on this data means that healthcare information exchange will become actionable. Structured medication, allergy and problem list data from outside applications will be reconciled, resulting in a patient centered electronic medical home that improves quality, safety, and efficiency.
4. Coded structured data with one set of standards per domain of medicine - problems, meds, labs, smoking status - will be foundational for innovations in decision support and patient education.
5. Backwards compatibility with CCR and CCD so that next generation approaches using consolidated CDA can evolve while still maintaining the ability to receive the older summary formats.
6. Identity reconciliation as a component of information reconciliation. The rule notes "upon receipt of a transition of care/referral summary is the appropriate point at which to verify that the transition of care/referral summary is being attributed to the correct patient." This will require vendors to implement novel patient matching techniques.
7. Patient online access to audit logs of their own view/download/transmit activities. Innovative yes, but it's doable and a great aid to help ensure patient privacy preferences are respected.
8. Quality measures which are based on EHR data elements and can be computed in real time, with standards to report patient level and aggregate data. The rule notes "we have adopted both the HL7 QRDA Category I standard to support a patient level data submission approach and HL7 QRDA Category III to support an aggregate level data submission approach."
9. Data portability via a summary export capability that enables transition from one EHR to another. This eliminates vendor lock in and empowers the market to evolve more rapidly.
10. ICD 10 was included in the final rule for encounter diagnoses. This was important given that the October 1, 2014 ICD-10 adoption deadline was finalized this morning
Each of these 10 items provides potential for innovation by start up companies that could fill functional gaps in enterprise vendor products. The new certification approach will make such gap filling easier than with stage 1.
Also today the folks at the Advisory Board published booked versions of the rules
It's not only the most exciting time to be in healthcare IT, but with the requirements above, the most exciting time to be an innovator creating new functionality that does not exist in the marketplace today.
Since ICD-10 is not required to be implemented until October 1, 2014, then it would seem that the attestation period for all eligible providers would be October 1,2014 - end of December, correct, or is there a brilliant workaround to this I have not thought of (e.g. Dual coding of the data in production?)
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