Deven McGraw, Project HealthDesign Regulatory and Assurance Advisory Group, Center for Democracy & Technology
Just before Thanksgiving, the Office of the National Coordinator for Health IT (ONC) released a formal Request for Comment (RFC) on potential objectives for Stage 3 of the meaningful use program. Although Stage 2 of the program has not yet begun, the RFC provides a very early opportunity for members of the public to weigh in on the next set of objectives and measures providers and hospitals will need to meet in order to qualify for the final phase of HITECH EHR incentive payments.
The RFC proposes potential Stage 3 objectives and asks more open-ended questions in the following areas:
- Improving Quality, Safety, and Reducing Health Disparities;
- Engaging Patients and Families;
- Improving Care Coordination;
- Improving Population and Public Health;
- Information Exchange; and
- Assuring Privacy and Security of Health Information.
The potential objectives and questions in the RFC were developed by the Health IT Policy Committee, and the response from the public will be used by the Committee to inform its final recommendations with respect to Stage 3. To date, CMS and ONC have relied significantly on the Policy Committee’s recommendations in developing the meaningful use objectives and certification criteria. Consequently, this is an important opportunity for interested stakeholders to help shape the future of meaningful use.
The final rules for Stage 2 make significant strides in assuring that patients have prompt electronic access to health data generated in the course of an office visit or as part of a hospitalization, and that patients can securely e-mail their health care providers. Increasing the flow of health information to patients is critical to achieving better individual and population health and a more patient-centered health care system.
But improving the flow of information from clinical care teams to patients will not by itself facilitate a more collaborative, patient-focused health care system. Electronic health records also should enable clinical care teams to receive relevant information from patients, and providers unaccustomed to receiving electronic data from patients may need incentives to adopt more three-dimensional models of patient engagement. The RFC asks for public input on how the meaningful use and EHR certification programs can enable, or even provide incentives for, the collection and use by clinical care teams of “patient-generated data.”
Specifically, the RFC proposes the following Stage 3 meaningful use menu item for providers and hospitals:
Item SGRP 204B: “Provide 10% of patients with the ability to submit patient-generated health information to improve performance on high priority health conditions, and/or to improve patient engagement in care (e.g., patient experience, pre-visit information, patient created health goals, shared decision making, advance directives, etc.). This could be accomplished through semi-structured questionnaires, and EPs and EHs would choose information that is most relevant for their patients and/or related to high priority health conditions they elect to focus on.”
The RFC further asks for public input on the “readiness of standards to include medical device data from the home,” and on the following more open-ended questions:
- What information would providers consider most valuable to receive electronically from patients?
- What information do patients think is most important to share electronically with providers?
- How can the HITECH incentive program support allowing doctors ad patients to mutually agree on patient-generated data flows that meet their needs, and should the functionality to collect those data be part of EHR certification?
The RFC further asks for “published evidence or organizational experience” to support responses to the above questions.
In addition to responding to the Stage 3 proposal and the corresponding questions, stakeholders should provide feedback on the Policy Committee’s decision to propose this objective as a “menu” item, which will make it only optional for providers and hospitals participating in the meaningful use program. The RFC notes that the Committee decided to propose this objective as a menu item based on concerns raised by the Health IT Standards Committee that most EHRs do not have the “essential functionality” to accept patient-generated data.
The Policy Committee’s Meaningful Use Workgroup hosted a hearing on patient-generated data several months ago. Patricia Flatley Brennan, Project HealthDesign National Program Director; Nikolai Kirienko, Chronology.MD co-project director; and I all presented testimony on the Project HealthDesign grantees’ experience with incorporating patient-generated data – specifically, observations of daily living - into clinical workflows. This testimony will help inform the Committee’s deliberations on Stage 3 criteria, but more input from the public is needed on the above questions as well as others that are focused on improving health and health care for patients. Now is the time to weigh in; comments can be submitted electronically at http://www.regulations.gov/#!docketDetail;D=HHS-OS-2012-0007 and are due by 11:59 pm ET on Monday, January 14, 2013.Read more posts about legal and policy issues