Deven McGraw, Project HealthDesign Regulatory and Assurance Advisory Group, Center for Democracy & Technology
Recently, the federal Health Information Technology Policy Committee sent its official recommendations on Meaningful Use Stage 2 to the Office of the National Coordinator for Health IT (ONC) and the Centers for Medicare and Medicaid Services (CMS). In a bit of good news for patients and their advocates, these recommendations significantly increase requirements on providers and hospitals for sharing data electronically with patients.
For example, in Meaningful Use Stage 1:
- Providers and hospitals must provide patients electronic copies of their health information upon request and within three business days.*
- Hospitals must provide electronic copies of discharge instructions to patients upon request.*
- Providers must provide clinical summaries of each office visit to patients upon request, but these do not have to be in electronic format.*
- Providers have the option of providing at least 10% of their patients electronic access to their health information within four days of the information becoming available to the provider.
For Stage 2, the Policy Committee’s recommendations place greater emphasis on providers and hospitals providing patients direct electronic access to their information. If the recommendations are accepted, patients will not have to request an electronic copy of their health information; they will instead have the capability to electronically view — and securely download on demand — relevant portions of their health information. This could significantly increase the demand for personal health records (PHRs) and applications that help individuals securely store, share and make use of their personal health information.
Specifically, in Meaningful Use Stage 2:
- Providers will be required to provide their patients access to view and download longitudinal health information within 24 hours of an encounter, or within four days of the provider having received the information from a lab or other external clinical site.**
- Hospitals will be required to provide patients access to view and download information about a hospital admission within 36 hours of the encounter.**
Providers will still be required to provide patients clinical summaries of office visits, and hospitals will still be required to provide patients electronic copies of discharge instructions, but both will be able to use the view and download functionality described above to meet those objectives in Stage 2.
The Policy Committee also recommended that providers offer secure messaging to patients in Stage 2; at least 25 patients must be using this service in order for the provider to qualify for the Stage 2 payment. This is one of several instances in which the threshold is deliberately low in order to give providers time for implementation and to get patients accustomed to using the service.
The Policy Committee also adopted recommendations to deal with the privacy and security issues raised by the view and download functionality in Stage 2. For example, patients must be able to download information securely, and the information must include information on data provenance so that any subsequent users, including other providers, can know the data’s origin and the date it was created. Providers and hospitals also must establish processes to properly identify and authenticate patients who use view and download functionalities.
Additionally, in a move that’s sure to interest patients, the Policy Committee once again signaled its intent to include in Stage 3, which is scheduled to begin in 2015, requirements that deal with accepting electronic data from patients.
The Policy Committee’s Meaningful Use Stage 2 recommendations are not the final word on Stage 2. The final Meaningful Use criteria are set by CMS, and CMS’ proposed rule for Stage 2 likely will not be released until the end of the year. However, CMS relied significantly on the Policy Committee’s recommendations for Stage 1, so these recommendations are a strong signal of what’s to come in the very near future.
Do you see these recommendations as good news for patients and patient advocates? Tell us what you think by leaving a comment.
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* Providers and/or hospitals must successfully execute these processes in response to at least 50% of patient requests in order to qualify for the Meaningful Use Stage 1 payment.
** Providers must provide this functionality to at least 10% of their patients in order to qualify for Meaningful Use Stage 2 payment.
