Update: 10 minutes after I posted below, the ONC NPRM was issued!
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Hello! I, like many of you, are in the midst of reviewing the Medicare and Medicaid Programs; EHR Incentive Program - Stage 2 Proposed Rule (NPRM) on Meaningful Use Stage 2 (MU2), which was published late yesterday afternoon but was probably not seen by most people until today. The reason I titled this post as I did was because MU2 needs to be “married” to the Standards, but we’re all limited by the fact that the ONC NPRM on Standards and Certification Criteria was not published on the same day as the CMS NPRM. We’re still waiting... So for MU 2, we don’t have the actual standards in our hands yet, which we need in order to understand the criteria and assess their effects on providers, vendors, and others. Since I’ve been following the HIT Standards Committee for months, and there were sneak previews given at HIMSS, I know about many standards that ONC supposedly included such as Consolidated CDA, NwHIN Direct, and SNOMED-CT. But I’d sure like to see the details ASAP.
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Hello! I, like many of you, are in the midst of reviewing the Medicare and Medicaid Programs; EHR Incentive Program - Stage 2 Proposed Rule (NPRM) on Meaningful Use Stage 2 (MU2), which was published late yesterday afternoon but was probably not seen by most people until today. The reason I titled this post as I did was because MU2 needs to be “married” to the Standards, but we’re all limited by the fact that the ONC NPRM on Standards and Certification Criteria was not published on the same day as the CMS NPRM. We’re still waiting... So for MU 2, we don’t have the actual standards in our hands yet, which we need in order to understand the criteria and assess their effects on providers, vendors, and others. Since I’ve been following the HIT Standards Committee for months, and there were sneak previews given at HIMSS, I know about many standards that ONC supposedly included such as Consolidated CDA, NwHIN Direct, and SNOMED-CT. But I’d sure like to see the details ASAP.
From CMS’ NPRM, many data elements in the “summary of care record,” “clinical summaries,” and “view and download” overlap but aren’t quite the same. As worded they don’t exactly match terms used in standards. Hopefully someone in ONC did the mapping to translate from the HIT Policy Committee’s and CMS’s phrases into the right “data buckets” in Consolidated CDA, for example. If not, I’m available to help through efforts like ONC’s S&I Framework Transitions of Care workgroups.
Margalit Gur-Arie wrote a helpful MU2 summary that helps distinguish what’s the same, what’s slightly new, what’s really new, etc.
As an interoperability champion, I see that ONC really means it when it talks about a big push for interoperability in MU2. MU2 has no more of those “check the box” tests without real exchange that characterized much of MU1! But stage 1 still has a few more years of life in it, for at least some providers, even if it is just a stage setter, Farzad Mostashari spoke of the “massive river flowing” of advances HIT, and I’ll be glad when real information exchanges flow abundantly among providers and patients, as I wrote about in some of my very first blogs.
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