CMS HIT Policy Commitee Comments on the IFR... they want to bring back Progress Notes!

In a letter addressed to David Blumenthal, National Coordinator for Health Information Technology, the HIT Policy Committee (HITPC) members developed several recommendations to communicate to the Centers for Medicare & Medicaid Services (CMS) in response to its Notice of Proposed Rule Making (NPRM) regarding CMS’s incentive program for the meaningful use (MU) of electronic health records (EHRs). Here is the condensed version. Bottom line, the MU definition is still a moving target.

RECOMMENDATION 1: REINSTATE HITPC RECOMMENDATION TO INCLUDE PROGRESS NOTE DOCUMENTATION FOR STAGE 1 MU DEFINITION FOR EPs.DRAFT 2
Recommendation 1.0: Include “Document a progress note for each encounter” for Stage 1EP MU definition.
Recommendation 1.1: Signal clinical documentation as a required MU criterion in Stage 2 for hospitals.

RECOMMENDATION 2: REMOVE CORE MEASURES FROM STAGE 1.

RECOMMENDATION 3: REINSTATE HITPC RECOMMENDATION TO STRATIFY QUALITY REPORTS BY DISPARITY VARIABLES.
Recommendation 3.0: Providers should produce quality reports stratified by race, ethnicity, gender, primary language, and insurance type.

RECOMMENDATION 4: PROVIDERS SHOULD MAINTAIN UP-TO-DATE LISTS OF PROBLEMS, MEDICATIONS, AND ALLERGIES
Recommendation 4.0: EPs and hospitals should report the percentage of patients with up-to-date problem lists, medication lists, and medication allergy lists
In order to support quality of care and care coordination, key patient summary information (e.g., active problem lists, active medication lists, medication allergy lists) must be maintained in the electronic health record.

RECOMMENDATION 5: REINSTATE HITPC RECOMMENDATION TO INCLUDE RECORDING OF ADVANCE DIRECTIVES FOR STAGE 1 MU DEFINITION FOR EPs AND HOSPITALS.
Recommendation 5.0: EPs and hospitals should record whether the patient has an advance directive as part of the Stage 1 MU criteria.

RECOMMENDATION 6: REINSTATE BUT AMEND HITPC RECOMMENDATION TO INCLUDE PATIENT-SPECIFIC EDUCATION RESOURCES FOR STAGE 1 MU DEFINITION FOR EPs AND HOSPITALS.
Recommendation 6.1: EPs and hospitals should report on the percentage of patients for whom they use the EHR to suggest patient-specific education resources.

RECOMMENDATION 7: REINSTATE HITPC RECOMMENDATION TO INCLUDE MEASURES OF EFFICIENCY FOR STAGE 1 MU DEFINITION FOR EPs AND HOSPITALS.
The committee had recommended two high impact efficiency measures dealing with use of generic medications and coding of indications for high-cost imaging services. Recommendation 7.0: All EPs should report to CMS the percentage of all medication, entered into the EHR as a generic formulation, when generic options exist in the relevant drug class.
Recommendation 7.1: CMS should explicitly require that at least one of the five clinical decision support rules address efficient diagnostic test ordering.
The NPRM states that EPs and hospitals need to: “implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering.” In order to highlight an important area of health care system efficiency, the committee recommends that the wording should be amended to: “implement five clinical decision support rules relevant to specialty or high clinical priority, at least one of which should be aimed at improving the efficiency of diagnostic testing or the ordering of appropriate treatment.”

RECOMMENDATION 8: CMS SHOULD CREATE A GLIDEPATH FOR STAGE 2 AND STAGE 3 MU EXPECTATIONS
Recommendation 8.0: CMS should advance its timetable for the release of future MU NPRMs in order to allow adequate ramp-up time for vendors and providers.
To the extent possible, CMS should consider publishing the Stage 2 MU NPRM well before its anticipated December 2011 timeframe because vendors need more time to develop the appropriate functionality and providers need more time to integrate it into the clinical workflow.

RECOMMENDATION 9: CPOE SHOULD BE DONE BY THE AUTHORIZING PROVIDER.
Recommendation 9.0: The numerator for the CPOE measure should define a qualifying CPOE order as one that is directly entered by the authorizing provider for the order

RECOMMENDATION 10: AMEND PREVENTIVE/FOLLOW-UP REMINDERS CRITERION TO APPLY TO A BROADER POPULATION AND ALLOW FOR PROVIDER DISCRETION FOR WHERE TO FOCUS REMINDER EFFORT.

RECOMMENDATION 11: CLARIFY “TRANSITIONS OF CARE” and “RELEVANT ENCOUNTER”

RECOMMENDATION 12: ALLOW SOME FLEXIBILITY IN MEETING MEANINGFUL USE CRITERIA
Recommendation 12.0: Eligible professionals and hospitals should be given the flexibility to defer up to 6 meaningful-use criteria as described in the table below, but must meet all mandatory objectives.