Thoughts about the proposed Meaningful Use definitions

Looking at what’s in the proposal of Meaningful Use (MU), I see good intentions but also a risk of requiring so many changes that it may end up burdening the clinical process with metrics which cannot be derived automatically from the currently available EHR applications.

The June 16 draft focuses on CPOE, large-scale integration of currently diverse systems, patient safety metrics, use metrics, electronic health information exchange (with the patient/family and other healthcare providers), and security.

Current clinical documentation systems are in many ways still in their infancy. Companies are still learning how to adapt the user interface to the clinical workflow. Good interfaces, like the evolution of computerized spreadsheets, will take a while to crystallize. Much of what is available now, was designed to mimic our current documentation process and was not designed to collect the information proposed in the draft MU.

Just looking at how long RHIOs have taken to get establish and settle on HIE formats makes me rather dubious that we have enough time before 2011 to promulgate, let alone implement and use the EHRs. To achieve the stated timetable we must:

1. Publish final MU definitions (End of 2009)
2. Publish final HIE definitions and formats (End of 2009)
3. Allow the vendors to program and test the needed changes (say 6 months: June 2010)
4. Have the certification body certify the application (say 3 months: September 2010)
5. Let the users evaluate and purchase (say 3 months: December 2010)
6. Implement and start using (hospitals will be setting records if they get this done by December 2011)

This accelerated schedule above would still have many if not most users miss out on the first year of CMS reimbursements.

I see two options:
1. Delays to the CMS reimbursements are enacted and we retain the proposals.
2. The current MU proposal for 2011 is scaled back to focus more on implementation and use of the current versions of EHR, and less on patient safety metrics and HIE. At the same time as the 2011 MU requirements are published, clear definitions for 2013 MU must be promulgated as well to allow vendors and users to prepare with adequate lead-time.

Because of the nature of HIE, it may still be possible to have available as an add-on to existing EHR by the 2011 deadline though attention to all necessary security could end up slowing down this process.