The American Hospital Association (AHA) submitted to ONC its recommendations for changes to the Interim Final Rule on Monday, March 15. All the comments are in. Since the IFRs were released, we've been mucking around in the details (along with the devil, so to speak). As we wait for ONC to sift through the recommendations and figure out which to incorporate, we as an industry need to ask ourselves: What's the end goal? I believe the consensus is that we want health IT to enable providers to deliver high-quality care, reduce medical errors and lower the cost of care through efficient processes.
Based on the comments about the IFRs on the meaningful use criteria and standards and certification, however, how we get to that end goal is up for grabs. Everybody understands that it's going to be a painful journey. ONC will need to figure out how to get as many stakeholders on board without jeopardizing the end goal. Likewise, the stakeholders need to understand the differences among the numerous camps and appreciate the task facing ONC.
Specific details aside, I want to focus on AHA's comments in the area of EHR certification criteria modifications. AHA is right on target when it says ONC should set up the regulatory steps as soon as possible so when those final regs come out participants can hit the ground running and not smack into any hurdles. Some would argue that this is all ONC should do and let the private market work out meaningful use and measurements. That's an extreme view, but we share the set-up of regulatory steps.
AHA is also requesting that ONC remove the electronic claims submission and electronic verification of insurance eligibility certification criteria. Part of lowering the cost of healthcare is automating as many processes as possible. Integration of administrative/financial data with clinical data is a critical component to streamlining processes. The Holy Grail is to integrate those two silos of information. The technology may exist to be able to do that, but we don't have large-scale, real-world experience in that area. To make it a requirement for 2011 may be a stretch. While it's not advisable to get rid of it completely, perhaps ONC should reintroduce it in level or stage 2 of the meaningful use criteria.
Including certification criteria for any new objects in CMS' EHR incentive program's final rule seems to be a given, but one that AHA felt important to recommend. It also makes sense for ONC to include the certification criteria for the generation of the associated measure.
ONC will not be able to accommodate everyone's recommendation or please every stakeholder. Even if ONC could, it should not. The end goal stays the same. Getting everyone on board without sabotaging the end goal will be the hard part. I don't envy the task ahead.
Patty Enrado blogs daily at EHRWatch.com.
