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Friday, June 16, 2017

Given that "EHRs are a dying technology," should we kill MU Stage 3?

Picking back up on a recent riff I started pursuant to a young (English major) reporter's assertion that "EHRs are a dying technology." MUfraud

The American Hospital Association now recommends doing away with MU Stage 3.
AHA Calls for Stage 3 Meaningful Use Cancellation and More
AHA is calling for CMS to cancel Stage 3 Meaningful Use as part of recommended changes to federal EHR reporting changes.

The American Hospital Association (AHA) recently submitted a letter [pdf] to CMS requesting reduced administrative complexity as a way to save healthcare providers billions in annual costs, including the cancellation of Stage 3 Meaningful Use.

AHA outlined 29 recommendations to reduce regulatory burden in response to the federal organization’s request for information regarding CMS flexibilities and efficiencies

“The regulatory burden faced by hospitals is substantial and unsustainable,” opened AHA. “As one small example of the volume of recent regulatory activity, in 2016, CMS and other agencies of the Department of Health and Human Services (HHS) released 49 hospital and health system-related rules, comprising almost 24,000 pages of text.”...
Given that explicit references requiring Meaningful Use "Stages" are found nowhere in the ARRA/HITECH statute (P.L. 111-5), this action would appear to be fully within HHS/CMS discretion. Seems to me that HHS Secretary Tom Price could simply order the killing on MU3 himself. The MU incentive money is pretty much all out the door anyway, and Price is documentably no friend of MU. From Healthcare IT News back in January:
Tom Price takes aim at the inefficiencies of meaningful use, questions how to pay for precision medicine
The HHS nominee decries a law that has turned physicians "into data entry clerks." Meanwhile, genomics represents a "brave new world," he said – but "the challenges of how we afford to be able to make that available to our society are real."
Notwithstanding that I am no fan of Dr. Price (see here and here as well), you have to give him his due here:
"Electronic health records are so important because, from an innovation standpoint they allow the patient to have their health history with them at all times and be able to allow whatever physician or provider to have access to that," Price responded. "We in the federal government have a role in that, but that role ought to be interoperability: to make sure the different systems can talk to each other so it inures to the benefit of the patient.”

With regard to the EHR Incentive Program, "I've had more than one physician tell me that the final rules and regulations related to meaningful use were the final straw for them," said Price. "And they quit. And they've got no more gray hair than you or I have. And when that happens we lose incredible intellectual capital in our society."...
Ah, yes, "interoperability." I've been griping about what I have called "interoperababble" for years on this blog.

"We in the federal government have a role ... but that role ought to be interoperability..."
ONC missed the boat on that right at the outset by not requiring "standard data" (i.e., a metadata/dictionary standard) as part of EHR certification. APIs may be just fine for data exchange among lightweight consumer-facing apps comprising few data elements in need of exchange, but EHRs (which are not "dying") typically house around 4,000 variables -- hundreds of which may have to be exchanged during any given "interop" episode of care involving multiple providers on different systems.

Finally (pedantically, for my umpteenth time), no amount of calling n-dimensional "interfaced" point-to-point data translation/exchange "interoperability" will make it so. Had we "Type-O" universal standard data (my "lifeblood of health care" analogy again), we might come closer to conforming to the IEEE definition of "interoperability."


Just updated my March 2017 post "Health Care Needs an Uber Like It Needs Another Gruber."


More to come...

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