Thousands of eligible professionals and hospitals will have to meet Stage 2 requirements for the Electronic Health Record (EHR) Incentive Program (“Meaningful Use”) in the coming year. Some hospitals may seek to attest to Stage 2 objectives as soon as 12 months from now. For healthcare providers, failure to achieve objectives can put thousands or millions of dollars of incentive payments at risk. Will health departments be ready to meet them half way in information exchange? The answer depends on whether they are preparing now. Absent a strong project plan in the next few months, the answer may be “no”.
Here is a checklist for health departments to consider:
1. Are you prepared for MORE DATA? The standard for Stage 2 rises to on-going data submission, rather than just sending a test message. Are you ready to receive, parse and use steady streams of data from many healthcare providers? Health departments can still manage the pace of on-boarding new providers, but must do so in a way that does not put providers at risk (see points 6 and 7).
2. Are you ready to accept MORE TYPES of reporting from each provider? In Stage 1 providers could select only one of several “menu” public health objectives. Some menu options in Stage 1 are now required (“core”) in Stage 2. For example, hospitals must submit ALL OF immunization data, electronic laboratory reporting and syndromic surveillance reports to health departments ready to accept them. Eligible professionals must submit immunization data AND select from other menu objectives (including several public health options) to obtain their incentive.
3. Are you prepared to use HL7v2.5.1 messages for immunizations and syndromic surveillance? Two standards to choose from in Stage 1 created confusion and frustration, so there is only one standard for each Stage 2 objective. However…
4. Are you willing to GRANDFATHER providers that have achieved on-going submission of HL7v2.3.1 messages in Stage 1? This option is up to the health department, and can help you avoid having to re-on-board those providers already successfully submitting data using HL7v2.3.1. Any new data providers must use v2.5.1 however.
5. Will you accept CANCER REGISTRY data documents using the Clinical Document Architecture standard specified in Stage 2? Do you intend to sponsor any other SPECIALIZED REGISTRIES in 2014? These are new “menu” options for Eligible Professionals.
6. Do you have a plan to publicly DECLARE READINESS of what public health reporting objectives you will offer for Eligible Professionals and Eligible Hospitals during each reporting period? Because providers need timely and definitive information, Stage 2 rules now allow providers to claim EXEMPTION from public health meaningful use objectives if such a declaration is not publicly available for their jurisdiction. (Public health departments need not receive data for any or all objectives, but if they wish providers to be motivated by Meaningful Use incentives to submit data, they must publicly state in advance of each reporting period which objectives will be accepted.) A closely related issue: if more than one jurisdiction in a state receives Meaningful Use data submission (for example, if there are both local and state level syndromic surveillance or immunization information systems) are state and local departments planning to COMMUNICATE CLEARLY which exchange opportunities and requirements apply to which jurisdictions?
7. How will you manage Eligible Professionals and Eligible Hospitals that intend to initiate data submission during each reporting period? Stage 2 rules require providers to REGISTER their intent to submit data with the appropriate health department. The health department need not then immediately on-board the provider, but has the option to later disqualify a registered provider from receiving incentives if it fails to respond within 30 days to two written requests to take action (i.e., to begin sending test data, or to adjust transmission, structure or vocabulary to the required standards).
8. Do you intend to DESIGNATE a Health Information Exchange to receive some public health data submissions? To ensure good end-to-end transmission of reports, HIEs cannot claim to substitute for health departments unless they are designated to do so.
9. Is there CLOSE COORDINATION and a RESPONSIBLE OVERALL MANAGER linking planning with each of the affected surveillance programs (and jurisdictions), the state HIT coordinator, Medicaid director and HIT Extension Center?
[And 10. for health departments using EHRs and enrolled in the EHR Incentive Program: Will my EHR migrate to 2014 edition certification standards, and can we meet Stage 2 objectives to earn our incentive?]
Obviously, serious planning is needed. Some health departments may be asking: is all this worth the effort? It is critical to remember that:
1. Meaningful use is establishing the de facto standards that will be used for information exchange in the future. The faster health departments adopt the new national standards and on-board data submitters, the faster they can be automating data management and the detection and management of critical events. This can serve both effectiveness AND efficiency. National data and exchange standards will foster the ability of vendors and development of systems to aid health departments with these tasks.
2. Before long, most providers will have electronic health records that are all certified to capture and transmit information in standardized ways. Onerous reporting processes for providers, and incomplete reporting to health departments, can both be addressed to the benefit of both through automation.
3. Health departments can decide the pace at which they enroll providers in Meaningful-Use-specified data exchange. Health department participation is optional, but Meaningful Use incentives (and later, penalties) will induce providers to begin submission whenever the health department is ready. What the new Stage 2 rules demand in return is that health departments communicate clear plans and requirements to providers. It is the latter who then face financial loss if objectives aren’t met.
4. The new rules continue to support the idea of “queuing providers” and on-boarding them at the pace the health department can tolerate. Once providers are registered, they are not at risk of losing their incentive UNLESS they fail to respond timely (30 days) to requests from the health department. The health department can invite registered providers to initiate data exchange at whatever pace is practical, and neither party “gets hurt.”
5. Stage 3 will likely move beyond surveillance to improving preventive care delivery. For example, immunization information systems (which by Stage 3 will be bulging with information submitted by hundreds of thousands of healthcare providers) will likely be able to alert professions to immunizations patients lack, using the EHR during the context of care.
It may be a tough slog now, but there’s much to gain at the far end!
Fortunately, a Stage 2 Task Force of affected public health associations has formed under the leadership of the Joint Public Health Informatics Task Force, the Centers for Disease Control and Prevention (CDC), and the Office of the National Coordinator for Health Information Technology (ONC). It will soon be issuing fact sheets and other tools, which will likely be distributed at the NACCHO ePublic Health Blog among other modalities.