Time to Overthrow Meaningful Use Regulations?
Whether you call it evolution or revolution there is a groundswell among the peasantry calling for sweeping changes to the CMS EHR Incentive programs. Now, even the royals are calling for change. Last week I authored a post entitled: We Have Entered Zombie Land. My screed reflected on the confusion I was seeing that has been caused by the recent CMS Proposed Rule rule offering relaxation in the requirements to achieve meaningful use in 2014. I must have hit a nerve as I received more emails and the article was reposted more times than any other I have written in the past four years. To quote the American sage, Bob Dylan, “something is happening here”. Here’s hoping the Powers That Be or Powers Yet To Arise are in motion to address the underlying reality of a need for a comprehensive bold move.
There are not too many credible voices with experience in the area of healthcare, technology, and related policy. John Halmka, MD, is at the vanguard of that group. His credentials are beyond impressive as he serves as the CIO of Beth Israel Deaconess Medical Center, Chairman of the New England Healthcare Exchange Network (NEHEN), Co-Chair of the HIT Standards Committee, a full Professor at Harvard Medical School, and a practicing Emergency Physician. If anybody knows what is going on and would be able to articulate a vision for moving forward on meaningful use it would be him. This week he authored a post I encourage you to read. In it he outlines specific current and future problems he sees with meaningful use requirements and offers positive suggestions to address the concerns of providers. However, in an “editorial comment” he cuts to the core with Zen like clarity.
“….at some point we need to recognize that layering fixes on top of existing Meaningful Use regulation, some of which was written by CMS and some of which was written by ONC creates too much complexity. I have direct access to the authors of the regulations and email them on a daily basis. It’s getting to the point that even the authors cannot answer questions about the regulations because there are too many layers. I realize that we are reaching the end of the stimulus dollars, but as we head into Stage 3, I wonder if we can radically simplify the program, focusing on a few key policy goals such as interoperability, eliminating most of the existing certification requirements, and giving very clear direction to hospitals and professionals as to what must be done when.”
What can a CIO, healthcare provider, or anyone concerned about the current status and direction of the meaningful use program actually do? Well, other than trying a little voodoo hex I would suggest a public comment on the Proposed Rule. The public comment period is open until July 21, 2014 at 11:59 PM ET. The early you comment the better. As of midnight last night (May 28, 2014) only 8 comments had been posted. A little on the anemic side if you ask me. Submission of a comment is incredibly easy. Go to http://www.regulations.gov/#!documentDetail;D=CMS-2014-0064-0002, click on “Comment Now” on the right side of the page and have at it. Anonymous comments are allowed.
