Health Information Exchange in the NPRM

ONC Mostashari keeps saying it and I keep quoting it. “We can’t wait 5 years to get standards based exchange”. The stage 2 meaningful use proposal doesn’t close the deal but it is real exchange. There are key changes related to health information exchange (HIE) in the Notice of Proposed Rulemaking for Eligible Professionals (EP).

Stage 1 meaningful use core objective, “Exchange of key clinical information” saw its share of difficulties to achieve despite how it was envisioned in the current final rule. Stage 2 meaningful use proposes to remove this objective beginning in 2013 and replace with a stronger transition of care core objective for EPs, eligible hospitals, and CAHs. It also outlines four options for the objective and is soliciting comments on all four.

Stage 1 meaningful use core objective “provide patients with an electronic copy of their health information” and “provide patients with timely electronic access to their health information” are also up for proposed changes. Stage 2 meaningful use is proposing new ways patient information will be available. This will include viewing online along with downloading and transmitting. The two stage 1 objectives will be replaced with proposed objective, “Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP.”

Submitting health information data for public health priorities make up core and menu objectives in stage 1. Stage 2 proposes adding the phrase “except where prohibited” to regulation text for Public Health (PH) objectives under 42 CR 495.6. This change is to encourage submission of public health data even if it is not required by the provider’s local or State laws. The cases of prohibiting data to immunization registries are in sovereign tribal areas and other cases where registries only accept specific age groups.

Several of stage 2 meaningful use proposed objectives and their measures will facilitate electronic health information exchange capabilities for EPs. These would include more demanding requirements for eRx, incorporation of structured laboratory results, and expectations of electronic transmission of patient care summaries.