Karen DeSalvo started as the new National Coordinator for Healthcare Information Technology on January 13, 2014. After my brief discussion with her last week, I can already tell she’s a good listener, aware of the issues, and is passionate about using healthcare IT as a tool to improve population health.
What advice would I give her, given the current state of healthcare IT stakeholders?
1. Rethink the Certification Program – With a new National Coordinator, we have an opportunity to redesign certification. As I’ve written about previously some of the 2014 Certification test procedures have negatively impacted the healthcare IT industry by being overly prescriptive and by requiring functionality/workflows that are unlikely to be used in the real world. One of the most negative aspects of 2014 certification is the concept of “certification only”. No actual clinical use or attestation is required but software must be engineered to incorporate standards/processes which are not yet mature. An example is the “transmit” portion of the view/download/transmit patient/family engagement requirements. There is not yet an ecosystem for patients to “transmit” using CCDA and Direct, yet vendors are required to implement complex functionality that few can use. I completely support the idea of “transmit”, but it should have waited until the ecosystem was mature enough to make it an attestation requirement. Another example is the use of QRDA I and QRDA III for quality reporting. CMS cannot yet receive such files but EHRs must send them in order to be certified. The result of this certification burden is a delay in 2014 certified product availability. Certification should focus on rigorous interoperability testing, using mature standards, in practical use cases, supported by the evidence and experience.
2. Evaluate the collective timelines of Meaningful Use, ICD10-CM, ACA and the HIPAA Omnibus Rule – Thousands of pages of regulations are hitting the industry at the same time and it’s clear that like healthcare.gov, haste will make waste. My suggestion – extend Meaningful Use Stage 2 Year One attestation by 6-12 months (not just delay Stage 3 a year as has already been done) to enable clinicians to install certified software, redesign workflows, be properly trained, and educate their patients about the new functionality available. I realize this may be a regulatory leap, but I’ve seen new rule making done as corrective action in the past. Although I believe ICD10-CM requires more testing (the CMS planned March testing is not enough) and most applications will not contain the clinical documentation improvement features needed for clinicians to adequately justify the new codes, most hospitals have put so much time and resources into ICD-10-CM projects that they cannot afford to extend the project beyond October 1. For ACA, re-evaluate quality measure submission requirements per point #4 below. For the HIPAA Omnibus Rule, rethink the accounting …read more
