Overview of Meaningful Use Comments HIT Policy Committee July 16, 2009

Public Comments Public Comment  Published in the Federal Register  Comment period was ten (10) days  Deadline for comments June 26, 2009  792 comments were received July 16, 2009

General Themes Majority concurred that the focus of meaningful use must be on objectively measurable improvement of health outcomes and actual effective use, not simply to promote the adoption of technology for its own sake. Commenters generally applauded the emphasis on quality. More than a third of commenters expressed general support for the initial guidance. Some suggested more aggressive timeline; some suggested less aggressive timeline. Many asked for clarification of terms.

July 16, 2009 Measures Additional measures More measures targeted to specialty providers Do not create measures de novo – use existing measures

July 16, 2009 Sources for Existing Measures NQF Hospital Quality Alliance Healthy People 2020 CMS Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) CMS Physician Quality Reporting Initiative (PQRI) Joint Commission Core Measures NCQA Healthcare Effectiveness Data and Information Set (HEDIS) measures AMA Physician Consortium for Performance Improvement (PCPI) measures for physicians

July 16, 2009 Privacy and Security Concern with proposed inability to achieve meaningful use status for organizations under investigation for HIPAA violations  Large provider organizations are often subject to complaints for alleged violations  Unintended consequences (e.g., hospitals and providers will be reluctant to report potential breaches)  Redundant with HIPAA

July 16, 2009 Certification Many suggested that certification standards should support meaningful use Additional suggestions:  Include the ability to adopt modular systems  Criteria should promote interoperability  Include specific functions for EHR  Include certification for specialty provider EHRs