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Meaningful Use and Public Health: The Never-Ending Saga

Physician chatting with patient

Noam Arzt, PhD

The HIMSS Interoperability Showcase, part of the Public Health Informatics Conference, demonstrates interoperability – the ability for different technology systems to communicate – in real-time with actual products in the marketplace. The following guest post shares the impact seamless data exchange can have on patients, providers and caregivers.

Ever since the start of the Centers for Medicare and Medicaid Services (CMS) Electronic Health Record (EHR) Incentive Programs – now known as Promoting Interoperability – public health reporting has had a prominent place in the objectives and measures for interoperability.

Over the years the program has morphed and changed, added new requirements and removed others. The latest Notice of Proposed Rulemaking (NPRM), titled Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program, was released just a few weeks ago. The purpose of this NPRM is to address proposed changes for Year 3 of the Merit-based Incentive Payment System (MIPS), the provider (as opposed to hospital) side of the Quality Payment Program. The part that is most relevant to public health is the Medicaid Promoting Interoperability (PI) Program for Eligible Professionals (EP). A major goal of this NPRM is to synchronize as much as possible the EP program with the inpatient prospective payment system hospital-based program (see my earlier comments on that NPRM and corresponding Final Rule).

RELATED: A Work in Progress: Takeaways from the ONC Interoperability Forum

Here’s a quick review of the proposals that most directly apply to public health. Apologies in advance as some of what’s here may be cryptic to anyone who has not been exposed to this before:

  • For core public health measures, this NPRM seems to be an improvement over the current Year 2 guidelines with two public health measures required. On the other hand, an eligible clinician (EC) could choose less central public health and/or clinical registries and avoid major public health measures like immunization or laboratory reporting.
  • If an EC claims exclusion for both public health measures, the points associated with this measure would be redistributed to the provide patients electronic access to their health information measure instead. It seems to me that before an EC should have public health points redirected that all possible public health reporting measures should be exhausted.
  • There is an expansion of the definition of eligible syndromic surveillance ECs, which seems appropriate.
  • Any expansion in the definition of EC or “opt-in” for low-volume ECs should not have a significant negative impact on public health or its ability to onboard provider sites for participation.
  • CMS stated their intent to remove public health measures altogether for calendar year 2022 and beyond. Public health must continue to resist any future plans by CMS to eliminate public health reporting altogether.

One final note: As this NPRM was released, the CMS Administrator, Seema Verma, published an open letter to doctors focused on reducing the burden on doctors so they can spend more time with patients. HL7 has begun a similar initiative on reducing clinical burden. So the key question is: Does this NPRM go far enough to reduce provider burden in the spirit of Verma’s letter?

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