Our Thoughts on the Draft Meaningful Use Certification Testing Criteria
The Health IT branch of the National Institute for Standards & Technology (NIST) has been hard at work publishing draft certification procedures for hospitals, doctors, and vendors looking to achieve each of the Meaningful Use requirements. You can see what they’ve published so far here: http://healthcare.nist.gov/use_testing.
We recently found these wonderful documents, and after reading through the ones that pertain to Nimbus eRelease, we realized a couple of them require the use of explicit data formats where none are warranted. Namely, they require health information that must be presented to patients in an electronic, human-readable format, be done so via a CCD or CCR.
We wrote up our thoughts and posted them to email@example.com today. For anyone interested, our comments are below. We’ll let you know what they say.
To whom it may concern:
We have a question regarding the test procedures for the “Electronic copy of health information” criteria. According to the Meaningful Use Interm Final Rule, the objective of these criteria is to “Provide patients with an electronic copy of their health information.” While the IFR mentions the use of CDs, USB drives, and providing online access to the information, it neither mentions nor requires the use of a particular health record format when storing, transmitting, or displaying the information to patients.
Knowing that, we were surprised by what appears to be, an explicit requirement in the test procedures (§170.304 (f) & §170.306 (d)) to structure the underlying health information in the HL7 CCD or ASTM CCR formats.
Question: Assuming all of the required information (e.g. diagnostic test results, problem list, medication lists, allergies, discharge summary, and procedures) is shared with the patient electronically in a human readable format, does it matter what the underlying format of the data is?
Note: the testing procedure for “Electronic copy of discharge information” (§170.306 (e)) has the same electronic delivery and human readable requirements, but appropriately, in our opinion, does not explicitly require the use of a particular standard for the underlying data.
Why We’re Asking
We have a module that enables sharing health information with patients from any EHR, even if the EHR doesn’t know how to produce CCD or CCR-formatted data. We’re able to do this by offering an online service that redirects printed output from EHRs to our secure portal, where is it turned into a PDF that is accessible by the patient. With this service, providers can securely share health information with patients electronically online, and in the same human-readable format as if it was printed directly from the EHR.
Due to the “plug-and-play” nature of the service, and to ensure it works for all EHRs (even ones that will see little investment going forward), we cannot customize the service to build a CCD or CCR out of the data, en-route to creating a PDF. Not only would it be prohibitively expensive, it would ultimately be of little value since the final objectives are only that the health information be complete, electronic, and human readable. Clearly, all of these objectives can be met without requiring a specific format for the underlying data.
Please let us know if we’re misinterpreting the draft procedures or if there’s an opportunity to adjust them before they are finalized.
Thank you for your time, and for the great work you’re doing preparing providers and vendors for certification.
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