ONC – HLN Consulting, LLC

ONC EHR Reporting Program RFI: A Public Health Perspective

by Noam Arzton September 12, 2018

On August 24, 2018, the Office of the National Coordinator for Health Information Technology (ONC) released a Request for Information (RFI) related to the EHR Reporting Program. This RFI is required by the 21st Century Cures Act and its primary purpose is to gather ideas and suggestions related to how ONC might provide better information about Certified EHR Technology (CEHRT).

Apparently, the initial intention was to create a “star rating” like the type used in Consumer Reports to use to rate EHRs, but that seems to have been abandoned in favor of some kind of measurement system. But it is far from clear exactly how this would be done. There may be something to learn from the Immunization Information System (IIS) community: with guidance from the CDC, the American Immunization Registry Association (AIRA) initiated a process to help assess compliance of IIS with national functional standards through a formal measurement and improvement initiative. “Validation,” rather than “certification” or “compliance,” is the carefully-chosen term to signify a system meeting the designated measures through formal testing. The process is interactive, and the results are only made public with the agreement of the IIS program. Perhaps some of the concepts and processes in this initiative can be useful for the EHR Reporting Program.

Frankly, there is not much of interest in here for public health, which is not in the business of worrying about CEHRT. Of course, the quality and functionality of EHR products does impact their effectiveness in supporting interoperability with public health registries. To that end, the RFI does as some questions towards the end (p. 42918) about additional information that might be useful for prospective purchasers of CEHRT, including “Submitting, editing, and retrieving data from registries, such as clinician-led clinical data registries.”

ONC asks for how they might prioritize including information related to this in EHR Reporting as well as data sources for reporting about this. It may be useful for public health to weigh in on these questions; comments are due no later than 5 p.m. on October 17, 2018 at the Federal eRulemaking Portal.

CMS MIPS PI NPRM: A Public Health Perspective

by Noam Arzton September 6, 2018

See my HIMSS blog and our formal comments on this NPRM!

Well, here we go again.

The Centers for Medicare and Medicaid Services (CMS) has now released a new Notice of Proposed Rulemaking (NPRM), titled Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Re visions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program. The purpose of this NPRM is to address proposed changes for Year 3 of 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)” (the EHR Incentive Programs have been renamed). A major goal of this NPRM is to synchronize as much as possible the EP program with the hospital-based program that was addressed in a previous NPRM just a few months ago.

CMS IPPS Final Rule: A Public Health Perspective

by Noam Arzton August 17, 2018

On August 2, 2018 the Centers for Medicare and Medicaid Services (CMS) released the 2019 Inpatient Prospective Payment System Final Rule to Quality Payment Program. We earlier released thoughts on the Proposed Rule as well as our formal comments.

The Final Rule affirmed most of CMS’ proposed changes, with some notable exceptions:

Required public health measures were reduced from three (Stage 3 requirement) to just two, but Syndromic Surveillance will not be a requirement for hospitals covered under the rule.
While CMS continued to be unclear about its plans for the removal of public health measures altogether for CY2022 and beyond, they did express some openness to consider continuing public health measures and to study the issue over the next few years.

It is clear from the comments discussed in the final rule that comments submitted supporting public health requirements were received, noted, and had a positive impact on the final rule. Kudos to public health advocates for their strong voice!

Thoughts on the CMS IPPS NPRM: A Public Health Perspective

by Noam Arzton June 1, 2018

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program (one from AMIA, one from CDC). Here are just a few additional tidbits I picked out of the NPRM.

Of course, this document is written like stereo instructions so I welcome any corrections or comments to my interpretation of what’s in the rule. I put page numbers (from final FBO version referenced above which has just been released) where relevant in parenthesis.

HITAC USCDI Task Force Delivers its Recommendations

by Noam Arzton April 19, 2018

On April 18, 2018 the HHS Health Information Technology Advisory Committee (HITAC) US Core Data for Interoperability Task Force delivered its recommendations on the draft US Core Data for Interoperability (USCDI) and Proposed Expansion Process which had been published for public comment back in January 2018. HITAC promptly accepted the Task Force’s recommendations.

The Task Force focused almost exclusively on the process for identifying the USCDI rather than the proposed USCDI data itself. I especially appreciated their introduction of some key concepts related to how USCDI should be organized and understood. It has always bothered me that the current Common Clinical Data Set (CCDS) upon which the current draft USCDI is based contains a variety of types of data at different levels of analysis: for instance, a single discreet data element (like date of birth or sex) sits alongside more complex data constructs (like address, which contains many discreet data elements within it) which sit alongside even more complex data types (like immunizations or procedures). The Task Force introduces a notion of hierarchy to make this more sensible: data classes (high level topic like “demographics”), data objects (a single item within a class, like “address” within the class “demographics”), and data object attributes (a specific data element within a data object, like “zip code” within “address”).

From a process standpoint, the Task Force recommended an expanded set of steps which has an emphasis on more stakeholder participation and less ONC pronouncement. This includes a recommendation for patient input as well. These are welcomed additions and I certainly hope they will be operationalized by ONC.