Request for
Comment on Recommended EHR Stage 2 Meaningful Use Objectives
January
27, 2011
Dear
Colleague:
This
advocacy request is different from the usual advocacy emails you receive
from ASGE. Instead of asking for you to write your legislators, we would
like your input in response to a request for comment (RFC) from the
Department of Health and Human Services’ (HHS) Health Information
Technology Policy Committee (HITPC).
The
HITPC is looking for clinician guidance on a preliminary set of
recommendations regarding Stage 2 and 3 meaningful use objectives for the
Electronic Health Record (EHR) Incentive Program. While this RFC includes
objectives for Stage 3, at this time the HITPC is primarily interested in
comments on the proposed Stage 2 objectives. The possible Stage 3
objectives were included to give context to some of the Stage 2
objectives.
ASGE
is planning a comment letter and would like your input based upon your
knowledge and experience to help shape those comments. The comments
received by HITPC will be taken into consideration as HHS develops its
proposed rule for Stage 2 EHR meaningful use, which is expected to be
published this fall. Implementation of Stage 2 EHR meaningful use begins
in 2013 and Stage 3 in 2015.
ASGE
is most interested in your feedback on the proposed Stage 2 objectives
along with your experiences in attempting to fulfill the Stage 1
objectives. ASGE shares the concerns of many in the physician community
that HHS will move forward with proposing Stage 2 objectives without
having completed a thorough analysis of successful participation by
physicians in Stage 1 meaningful use.
ASGE requests that you submit your
comments by February 15. Comments should be sent by email to
Lakitia Mayo at lmayo@asge.org.
In
the American Medical Association Meaningful Use Objectives Matrix,
we have highlighted in purple those objectives on which ASGE would
particularly like your feedback.
In
addition to the proposed Stage 2 and Stage 3 objectives, the HITPC has
also presented 10 questions in which they would welcome additional public
comment. Among those questions, ASGE would be most interested in your
responses to the following:
What are providers’ experiences with
incorporating patient-reported data into EHRs? (e.g., data self-entered
into personal health records)
For future stages of meaningful use assessment,
should CMS provide an alternative way to achieve meaningful use
based on demonstration of high performance on clinical quality
measures? (e.g., drug-drug interaction checking)
Should Stage 2 allow for a group reporting option
to allow group practices to demonstrate meaningful use at the group
level?
In Stage 1, as an option menu objective, the
presence of an adverse directive should be recorded for over 50% of
patients 65 years of age or older. We propose making this objective
required and to include the results of the advance-directive
discussion, if available. We invite public comment on this proposal,
or to offer suggestions for alternative criteria in this area.
What are the reasonable elements that should make
up a care plan, clinical summary, and discharge summary?
What additional meaningful-use criteria could be
applied to stimulate robust information exchange?
I
thank you in advance for your attention for this important request. We
look forward to hearing from you.
