HIT Policy Committee

1. HIT Policy Committee Adoption/Certification Workgroup Comments on NPRM, IFR Paul Egerman, Co-Chair Retired Marc Probst, Co-Chair Intermountain Healthcare February 17, 2010

2. Administrative Burden of 16 EP Metrics CPOE Usage Percentage Percentage of relevant prescriptions transmitted electronically with e-prescribing Percentage of unique patients with electronic up to date problem list Percentage of unique patients with active medication list maintained Percentage of all unique patients with an active allergy list Percentage of all unique patients with recorded demographics Percentage of all unique patients with vitals recorded and charted Percentage of patients 13 years and older with smoking status recorded in EHR

3. Administrative Burden of 16 EP Metrics (continued) Percentage of EHR records with structured laboratory data  Percentage of all unique patients sent reminders Percentage of patients whose eligibility status is electronically checked Percentage of claims submitted electronically Percentage of patients provided with electronic copies of medical records Percentage of patients with timely access to health information Percentage of office visits in which clinical summaries are provided    Percentage of relevant encounters with med reconciliation

4. Detailed Recommendations • Greater detail needed on how to calculate reporting metrics for items involving the percentage of electronic usage versus manual usage. Specifically, for each metric: • Are rough estimates accepted or is the metric expected to be precisely calculated? • Is manual review and counting of records expected, and if so, over what time period? • Can a statistical process be used? For example, is it acceptable to review all encounters for a single week to extrapolate percentages?

5. Detailed Recommendations (continued) The IFR should include certification criteria for a section called “Reporting Metrics,” which would ensure automatic calculation of all metrics that are required to be reported. 3. The reporting process for Stage 2 of Meaningful Use should not require manual review of records or subjective judgments.

6. 2009 Cert/Adopt WG Recommendations (reminder) • Focus Certification on Meaningful Use • Leverage Certification process to improve progress on Security, Privacy, and Interoperability • Improve objectivity and transparency of the certification process • Expand Certification to include a range of software sources: Open source, self-developed, etc. • Develop a Short-Term Transition plan

7. Pleased with Response to many WG Recommendations • IFR did focus on MU (recommendation #1) • Specifying LOINC and RxNorm is a significant forward step toward interoperability (recommendation #2) • Pleased to see Privacy and Security emphasis (recommendation #2) • We applaud the emphasis on modular systems (recommendation #4)

8. Concern about IFR Interoperability Statement IFR:”We will consider adopting implementation specifications, though, for any or all adopted standards provided that there is convincing evidence submitted in public comment of the specifications’ maturity and widespread usage.”

9. Leveraging Certification for Interoperability • Government needs to provide leadership in critical areas where use of mature standards may not exist— e.g., Laboratory. • Evolving implementation specifications (guides) should be designated with a plus, indicating that subsequent revisions also meet regulations. • This WG supports the Information Exchange WG’s recommendations to extend use of HL7 2.5.1 for laboratory exchange.

10. Greater Specificity of Interoperability Standards For each function with more than one standard, we recommend the adoption of a single standard for exchange. Alternatively, we request that ONC explain why more than one standard was specified and the circumstances for which a particular specification should be used. This comment refers to: Submission to Public Health Agencies for Surveillance or Reporting (Table 2a, Row 7) Submission to Immunization Registries (Table 2a, Row 8) Problem List use of ICD 9 or SNOMED-CT (Table 2a, Row 1) Use of Vocabularies LOINC, UCUM, and SNOMED-CT for laboratory reporting (Table2a, Row 6-Stage 2)

11. Transition Plan to New Certification Process Establish a transition plan, or make a transition statement about how Certification will be handled until the new process is put into place.

12. HIT Safety Hearing Thursday, February 25, 2010 Topics for review Identifying the Issues Stakeholders Possible Approaches

13. Appendix

14. Lab Recommendations—Agree with Info Exchange WG 1. For laboratory transactions, adopt the implementation guide for HL7 2.5.1 which has been approved by the HIT Standards Committee. 2. For Hospitals, extend the certification criteria for HL7 2.5.1 for the submission of lab results to other providers (in addition to state public health agencies). 3. Extend the certification criteria for HL 7 2.5.1 to also include receipt of laboratory data.   

15. Additional Detailed Recommendations 4. When there exists an important interoperability need and there does not exist mature standards or Implementation Specifications (guides), the government should adopt standards and implementation specifications (guides) with a “plus sign”. The “plus sign” indicates that future revisions also meet regulations.