Are the 2014 certification requirements for electronic health records (EHRs) and the health information exchange (HIE) Meaningful Use measures set forth in the Stage 2 final rules enough to drive the electronic exchange and use of this information at the point of care?
My answer is no. It is up to providers and their staff to embrace the technology and modify business processes to enable true interoperability.
Upgrading to the 2014 Certified EHR Technology (CEHRT) and meeting the Stage 2 measures in a calendar quarter period make it extremely difficult to achieve interoperability for care coordination in 2014. However, providers should take advantage of the 2014 CEHRT and Meaningful Use HIE measures to move in the direction of interoperability for future care coordination.
Here are a few recommendations to consider during the 2014 CEHRT upgrade and the Stage 2 Meaningful Use period:
Structured Lab Result Delivery. It is possible to meet the Stage 2 measure of incorporating 55% of ordered lab tests as structured data by manual entry, option selecting, scanning, or other means. Structured data does not have to be received via health information exchange. This approach does not promote interoperability but does promote duplicative data entry. Providers should seek out laboratories supporting electronic structured lab result delivery and consider manual entry as a last resort. In Michigan, several of the HIE-qualified organizations within the Michigan Health Information Network (MiHIN) provide lab result delivery. Providers should check with the qualified organizations to see if the HIE supports integrated lab result delivery with their CEHRT.
Transition of Care. To meet the summary of care objective third measure, in place of conducting one or more successful electronic exchanges of a summary of care document with a recipient who has a different CEHRT vendor, providers can send one or more successful tests to Centers for Medicare and Medicaid Services (CMS) designated test EHR. The option of sending one test message to CMS should be a last resort. This does not measure the sharing and use of the summary of care. This does not facilitate care coordination. Providers should test the interoperability of the summary of care with providers in their existing referral network. I highly recommend this testing is conducted during the 2014 CEHRT implementation. This activity could be included in the service contract with the vendor to ensure true interoperability exists with an EHR in the provider’s care delivery system.
Public Health Reporting. Stage 2 eliminates the senseless measure of submitting one test message to the public health agencies and forces the coordination needed for interoperability between providers and public health agencies. Providers can attest "yes” to meeting the public health measures if they are engaged in testing and validation with each of the public health systems supporting the objectives (immunizations, syndromic, cancer, and specialized registry reporting). Testing and validation is a crucial step in achieving interoperability. However, providers could potentially be caught between a rock and a hard place during testing and validation. CEHRT products are certified to meet the message structure standard required for the measure (HL7 2.5.1, CDA), not certified on the content or the data that populates the message. Interoperability requires the information received to be usable. If the content of the message does not meet the requirements of a complete record, the message will not be acceptable to the public health agency and may require adjustments to the CEHRT to ensure the appropriate data is captured and sent to the registry. The changes to the CERHT may require vendor assistance. The timing for making the changes becomes dependent on the vendor’s schedule. Providers should include public health interoperability completion in their vendor service contracts. True interoperability with the public health agency can reduce duplicate data entry for mandated public health reporting.
In 2014, we may not experience volumes of information exchanged and used at the point of care, but there are steps providers can take now to get the interoperability ball rolling for the future of care coordination.
Contact us for assistance with understanding your entire story. M-CEITA stands ready to help all providers state-wide achieve meaningful and efficient use of EHR technology in patient care.