As I first looked over the meaningful use matrix (PDF) that was created by the HIT policy committee I thought that the requirements listed were reasonable and doable. Then, I realized that I was only looking at the first page of a seven page document.
For now, I’ve focused on looking at the 2011 objectives. I wanted to really focus on it since that’s the bar with the most stringent timeline for those wanting to get the EHR stimulus money from ARRA.
I’ll talk in more detail about the various items in a future post. However, as I look through the list of objectives to show meaningful use for 2011, I don’t think any of them sound unreasonable. On their own, each objective listed seems to be something that is completely doable. I might question why some are on the list, but I don’t see any of them individually as too much to accomplish in that time frame.
The problem is that the 22 meaningful use 2011 objectives as a collective whole would be daunting for any practice. I previously wrote about the challenge hospitals face implementing an EHR quickly, but I think this list of objectives would be hard for a practice of any size. I guess some of the reporting could be centralized for a hospital system and save them some time. For a small office, they’d have to do all the reporting themselves and that could be time consuming. No wonder David Blumenthal, ONC head, sent the meaningful use matrix back to the HIT Policy Committee.
I see two other major problems I see with the meaningful use matrix. First, some of the requirements don’t even have established standards yet. Sure, it’s a nice concept to say that doctors should have to “exchange key clinical information.” That’s kind of one of the points of the legislation. Unfortunately, we don’t have any real established standard for sharing key clinical information between providers. CCR seems to have some merit, but is far from becoming THE standard for sharing clinical information. Seems like we’re getting cart before the horse when we ask people to do something for which there is no established and recognized standard.
Second, how is HHS/ONC going to measure accomplishment of these objectives? There not going to go around to each clinic to verify that they actually have an “active medication list” or that they “incorporate lab results in the EHR.” Maybe it’s just the practical side of me. It’s nice to have these objectives, but if we don’t have a way to meaningfully measure that the objectives are being accomplished then it will be abused. I think ONC and HHS might be responsible for deciding how to do this, but I think it would be naive of the HIT policy committee to make these recommendations without good ways to measure them.