Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.
The 60-day comment period on the Proposed Rule for Stage 2 Meaningful Use ends today. If the length and depth of the comments published so far are any indication, CMS will have a lot of reading and thinking to do between now and August, when the Final Rule is expected.
The tone of the comments is somewhat consistent—general support for the direction and spirit of the rule, but concern that the bar is being raised too high, too quickly. One fear is that if providers perceive the requirements to be unachievable or impractical, they could be discouraged from even trying to meet them.
These are some of the common themes that are already emerging:
- Although MU Stage 2 was postponed to 2014, the timing is still very challenging. Several groups have already recommended a 90-day reporting period for the first year of MU Stage 2, which would provide for a phasing-in of the increased requirements, similar to MU Stage 1.
- Meaningful Use Stage 2 is considerably more complex than Meaningful Use Stage 1, with the introduction of new measures and the addition of sub-components to Stage 1 measures. Many would require physicians and staff to implement new and more complex workflows.
- The core and menu structure continues, but the menu options are fewer and would leave many providers with no real choices since several of the menu measures would not apply to their practices.
- While increased patient engagement is recognized as an important goal, providers are expressing concern about having their incentives be dependent on actions by patients—actions over which they have no real control. For example, one proposed measure would require that 10% of patients access their information on the physician’s portal, and another that 10% of patients send a secure e-mail message to their physician.
- Some measures could have significant cost implications for physicians—for example, there are often costs associated with developing the interfaces necessary to send data to registries and/or HIEs.
- Clinical quality measure reporting, described in one set of comments as “daunting,” is eliciting detailed comments. Developing a reasonable set of requirements that are harmonized with other government programs will require a great deal of work.
More to come, as more comments become publicly available.