The November HIT Standards Committee included a comprehensive review of
the CMS Meaningful Use Stage 3/Modification Rule and the ONC 2015
Certification Rule.
We begin the meeting with a presentation from Robert Anthony of the Meaningful Use Stage 3 and Modification Rule
A robust discussion followed. Issued raised as those similar to the ones I identified in previous blog posts.
The main concern was the alignment of the CMS Meaningful Use rule with
future pay for performance criteria that will be part of
MACRA/Merit-based Payment Incentive programs.
Additionally there was significant discussion about the API requirement
and the notion that “an API that can be used by applications chosen by
the patient” implies that there cannot be curation or security review of
patient selected applications. All agreed that CMS and OCR need to
clarify how patient access can be balanced with security imperatives.
The 6 public health requirements apply to providers but CMS has no
authority to standardize communications on the public health side. This
could lead to significant regional variation in public health
transaction flow.
The next presentation from Elise Sweeney Anthony and Mike Lipinski covered the
2015 Certification Rule
Issues discussed included privacy and security criteria, safety enhanced design, field audits, and the API requirements.
As I’ve stated in previous posts and articles, I believe the CMS Stage 2
modifications are good but the Stage 3 requirements could be moved into
merit-based incentive programs and the Meaningful Use program
eliminated.
This blog post on HIT first appeared here: http://geekdoctor.blogspot.com/2015/11/the-november-hit-standards-committee.html
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