In the FWIW column, Chilmark Research submitted its comments on the Draft Recommendations for Meaningful Use, which were released on June 16th. Today at 5pm was the deadline and we barely made it (email time-stamp of 4:59pm). Following is the text of the email/comments we submitted to HHS and we certainly welcome your feedback, e.g. we are totally nuts, reasonable or wimped out and did not push hard enough? Also, we purposely did not try to cover everything, simply not enough time, instead choosing to focus on a couple of areas we felt were critical. Lastly, Chilmark also reviewed, made suggestions to and endorsed comments by a collaborative group that was submitted by the Markle Foundation.
Now time to rest and prepare for round two.
Dear HIT Policy Committee of ONC within HHS
Chilmark Research has followed closely the ongoing developments within HHS as it lays the foundation to successfully fulfill the legislative intent of ARRA and in particular the HITECH Act. We recognize the significant task you have been given, the responsibilities they entail and recognize the numerous challenges that lie ahead. Indeed, the small actions you will take may indeed lay much of the foundation for the success of future healthcare reform efforts.
Core to the successful execution of the HITECH Act is insuring that the significant amount of US taxpayer’s money that will be invested to digitize portions of the healthcare sector achieve objectives that indeed improve health, mitigate if not even lower costs and ultimately, deliver value back to the taxpayer that is readily recognized and appreciated. Therefore, how clinician’s actually “meaningfully use” technology that is relevant to taxpayers is critical.
Also critical to the success of subsidized technology adoption is to set objectives sufficiently high to be meaningful, but not so high where the risk to reward ratio acts counter to adoption.
With these thoughts as a backdrop, our comments to the Draft Recommendations for Meaningful Use are as follows:
The Meaningful Use Workgroup has done an exemplary job of incorporating the intent of the legislation into the meaningful use criteria. We also applaud their efforts to focus on what we wish to see as outcomes from the successful deployment and use of HIT and the tiered approach that is taken to raise the bar on meaningful use over the 2011-2015 time period.
Some aspects of meaningful use criteria however, do not appear to take into account the significant challenges that are present in successfully deploying an IT solution. For example, the requirement for CPOE in 2011 is not reasonable, particularly in the context of a hospital where there are numerous interactions, workflows and processes that must be reconfigured to successfully deploy such a solution, and that does not even begin to address internal training issues as well. Serious rethinking is required regarding meaningful use timeframes that account for process and workflow reconfiguration.
The draft meaningful use criteria do take into account the patient and their family/caregivers with regards to access to medical records, secure communication, use of home monitoring devices etc. But the criteria do not go far enough. Chilmark recommends the following:
- Patient be given access to their complete medical record through a patient portal/tethered PHR or via common standards compliant digital file.
- Patient portal/tethered PHR provide the capability for patient to annotate & make notes to the record, including suggested corrections.
- Patient be provided fully portable medical record whereby they can export PHI from a physician’s tethered-PHR to PHR, data repository, etc. of their choosing, without cost.
- Provide patient, within context of the tethered-PHR, quality & cost metrics of the physician practice/hospital (use metrics collected for reporting in other section of meaningful use) with comparison benchmarks to regional and national averages increasing cost and quality transparency in the market.
- Allow the automated collection and import for analysis of personal, patient device data into the EHR for enhancing care. (Note: we us the term personal patient device data and not “home monitoring devices” as used in the draft recommendations for the future will see smaller, wearable sensors, not confined to a home setting.
Again, we reiterate that the inital draft of meaningful use was an excellent start to the process but unfortunately has many fatal flaws and most importantly, does not provide enough value back to the taxpayer, the citizen. It is our sincere hope that follow-on recommendations more strongly advocate for the patient and their rights to what is ultimately their data .