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The release of two notices of proposed rulemaking on the incentive program for the Meaningful Use of electronic health record technology marks a major, positive step forward in the nation’s efforts to improve health and health care by putting modern information technology tools at the fingertips of medical professionals and consumers alike. Markle Connecting for Health, a public-private collaborative, applauds the U.S. Department of Health and Human Services for proposing an important set of regulations to improve health outcomes, increase the cost-effectiveness of care, encourage innovation, and protect privacy. In this set of collaborative comments, advanced by a diverse array of health leaders, we offer our comments and recommendations on the proposed rules in four distinct categories: Health goals and quality measures Patient engagement Care coordination Privacy and security
Markle Connecting for Health is pleased to provide feedback on the general direction of the U.S. Department of Health and Human Services’ (HHS) implementation of the Meaningful Use (MU) program under the Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as part of the American Recovery and Reinvestment Act of 2009. This letter summarizes comments from the Markle Connecting for Health community on some of the proposed requirements for Stage 2 of this important program. Markle Connecting for Health is a public-private collaborative with representatives from organizations across the spectrum of health care and information technology. In general, we support a reasonable approach of phasing “menu” requirements into “core” requirements over the course of the program without creating new burdens for manual counting by participating physicians and hospitals. We discuss four areas that present significant opportunities for Stage 2 Meaningful Use requirements: Patient engagement as a key public benefit of the program, including the ability of individuals to view and download key personal health information online as a core requirement in Stage 2. A strategy that includes options and flexibility for participating doctors and hospitals to deliver information that satisfies MU requirements for coordination of care. The need to align quality-reporting requirements with various initiatives to improve health and health care, to emphasize automation of data collection and reporting, and to require summary statistics only for MU quality measures. The importance of defining a comprehensive set of privacy and security safeguards as part of MU requirements.
April 23, 2010 Dear Secretary Sebelius, Dr. Blumenthal, Ms. Frizzera, and Mr. Trenkle: The final federal regulation of Meaningful Use of health information technology (health IT) under the Recovery Act will be a powerful signal for the future of US health care. By and large, the US Department of Health and Human Services (HHS) has drafted a regulation with the right priorities. As the department prepares its final rules by which providers and hospitals may qualify for health IT incentives, it is critical not to lose sight of the core goals of Meaningful Use: improving health and efficient use of health care resources protecting privacy encouraging innovation and broad participation across many health care settings By emphasizing the term “meaningful use,” Congress clearly intended that the subsidies not cover the mere purchase of technology. Increasing the number of doctors’ offices or hospitals with health IT systems is not enough; the technology must be a tool to achieve specifically articulated and achievable health improvement and cost-effectiveness goals. The Meaningful Use incentives also can be a powerful driver to help physicians and hospitals prepare for implementation of recently enacted health care reform legislation. That will require the Government to retain core values that are currently well-drafted in the Notice of Proposed Rulemaking (NPRM), such as: declaring that the goal of health IT is to improve health quality and efficiency embracing patient engagement as a key aspect of Meaningful Use establishing goals, objectives, and metrics for health improvement rather than focusing merely on acquiring technology adopting a phased approach to allow for step-wise provider and hospital adoption of health IT, as well as technology development and testing at initial stages making progress on aligning various HHS quality reporting initiatives and eliminating the need for duplicative reporting Through extensive collaboration, the Markle Foundation, the Center for American Progress, and the Engelberg Center for Health Care Reform at Brookings have recommended several modifications to the NPRM that would adjust several of these metrics and streamline administrative overhead for providers while retaining critical foundational, process, and outcomes measures that will lead to health IT being used meaningfully to improve health care. We have submitted comments intended to balance the very real implementation concerns of providers with the needs of patients and families to rapidly experience more effective, efficient, and quality-driven care aided by health IT. For providers to merit the taxpayer-financed subsidies, HHS must insist on using the Phase I period to begin the pathway toward improved results: reducing hospital readmissions improving medication management (safe medication use and effective medication management for heart disease, diabetes, asthma, mental health conditions, and hospital procedures) providing individuals with electronic copies of their personal health information improving care coordination and reducing gaps in care improving chronic care management, including blood pressure, diabetes, and cholesterol control improving preventive care, including healthy weight and smoking cessation improving patient safety reducing disparities increasing efficiency and appropriate use of resources improving active engagement of patients in their care To justify the public investments in health IT, it is vital that HHS establish a Phase I Meaningful Use rule that puts technology adopters on a pathway for measurable progress against these critical objectives. Our collaborative comments, supported by leaders of a diverse group of 56 organizations, are available here. Effective use of information is what keeps a patient from suffering a medical error, helps a doctor prescribe the right treatment at the right time, and allows a care team to provide the best possible care in the most cost-effective way. These are the expectations we have for health IT. With enactment of the Recovery Act and health care reform, HHS is in the best position in decades to transform the nation’s largest sector to meet these long unmet expectations. Phase I of Meaningful Use is the right time for a strong start with ambitious but achievable requirements. With appreciation, Zoë Baird, President, Markle Foundation Carol Diamond, MD, MPH, Managing Director, Markle Foundation Mark McClellan, MD, PhD, Director, Engelberg Center for Health Care Reform at Brookings Peter Basch, MD, FACP, Senior Fellow, Center for American Progress
On behalf of a broad range of health leaders, the Markle Foundation, Center for American Progress, and the Engelberg Center for Health Care Reform at Brookings offer recommendations on measuring and demonstrating meaningful use of health IT under the American Recovery and Reinvestment Act of 2009. The Department of Health and Human Services (HHS) has a critical opportunity to set clear priorities that will foster the adoption of heath IT to demonstrably improve the quality and cost-effectiveness of care. The process to demonstrate meaningful use can engage patients, build capacity for quality improvement, lower administrative burdens on providers and patients, and, if done strategically and in service of these goals, send a clear market signal that the focus is on using technology to improve care.
These comments are a response to the request for comment on the meaningful use definition released by the United States Department of Health and Human Services (HHS). They are the result of a joint effort by the Markle Foundation, the Center for American Progress, and the Engelberg Center for Health Care Reform at Brookings. On April 30, 2009, the three organizations participated in a forum to issue a Markle Connecting for Health consensus paper on ‘meaningful use’ and ‘qualified or certified EHR’ —pivotal concepts for determining how more than $30 billion in health information technology (IT) incentives should be paid out under the American Recovery and Reinvestment Act of 2009 (ARRA). Representatives from 70 organizations supported the consensus paper. This collective response is organized according to the five key implications derived from the Markle consensus paper: Set Clear and Achievable Health and Cost Goals Tie Payment Tightly to Results Engage Patients in Achieving Meaningful Use Goals Focus on Information Use, Not Technology Functions or Features Ensure that Standards and Certification Directly Support Meaningful Use and Foster Innovation
In this letter to HHS and OMB leaders, Markle Connecting for Health collaborators provide recommendations for the pending federal rule on 'meaningful use' of health IT under the Recovery Act.
The release of proposed federal health information technology (IT) “meaningful use” regulations and standards marks a major, positive step forward in the nation’s efforts to improve health care by putting modern IT tools at the fingertips of medical professionals and consumers alike. The public comment period is critical for ironing out workable details, and clearly we believe some important revisions will be necessary in the final regulation. But we must not lose sight of the urgent priorities of this effort: to improve health, increase cost-effectiveness, protect privacy, and encourage innovation and broad participation across many health care settings. The Markle Foundation, the Center for American Progress, the Engelberg Center for Health Care Reform at Brookings and three dozen diverse leaders in the health sector send a letter commending federal agencies for their work drafting proposed health IT "meaningful use" regulations and standards.
By and large, the US Department of Health and Human Services (HHS) has drafted a regulation with the right priorities. As the department prepares its final rules by which providers and hospitals may qualify for health IT incentives, it is critical not to lose sight of the core goals of Meaningful Use: improving health and efficient use of health care resources protecting privacy encouraging innovation and broad participation across many health care settings This letter to the US Department of Health and Human Services is an introduction to the Collaborative Comments on the Centers for Medicare and Medicaid Services’ Notice of Proposed Rulemaking for the Electronic Health Record Incentive Program (CMS-0033-P) made by Markle Connecting for Health, the Center for American Progress, and the Engelberg Center for Health Care Reform at Brookings.
WASHINGTON, DC—The Markle Foundation, the Center for American Progress, and the Engelberg Center for Health Care Reform at Brookings today emphasized the importance of new federal rules on health information technology. The U.S. Department of Health and Human Services today released regulations on implementing an incentive program for Meaningful Use of electronic health records (EHRs). The program, authorized under the 2009 economic stimulus Recovery Act, represents the largest investment in modernizing health information technology in U.S. history. “These regulations provide a promising foundation for encouraging the effective use of health information to improve patient care. With coming payment reforms, these incentives will give doctors and hospitals needed support for improving health care quality and efficiency,” said Mark B. McClellan, MD, PhD, Director, Engelberg Center for Health Care Reform and Leonard D. Schaeffer Chair in Health Policy Studies at the Brookings Institution. “The two words are critical together—‘meaningful’ and ‘use,’” said Carol Diamond, MD, MPH, managing director of the Markle Foundation. “The final rule has added flexibility to encourage providers to participate in the first phase of this critical effort to improve health, promote efficiency, drive innovation, and protect privacy. Now providers and patients can strive for meaningful use of modern information tools.” “This marks a new beginning in the effort to infuse the health sector with the power of information,” said Peter Basch, MD, senior fellow at the Center for American Progress. “In the long run, there is much more to be done to align quality and efficiency in care through health care and payment reform,” Basch said. “But today, this incentive program provides a vital boost for doctors and hospitals to invest now in health IT and its optimal use for improving outcomes, coordinating care, and engaging their patients in health improvement.” For the past 18 months, the three organizations convened a broad collaboration of experts and organizations to advise HHS on the new rules, focusing on setting ambitious but achievable targets for the following priorities: Establishing goals and metrics in terms of improving health and efficiency, not mere purchase of technology. Embracing patient engagement as a key aspect of Meaningful Use. Adopting a phased approach to allow for technology development and testing at initial stages. Prioritizing requirements for reporting quality results to avoid unnecessary burdens on physicians and hospitals. Shaping technology requirements in a way that encourages innovation. “We congratulate the many people who worked on the essential details to govern this program,” Markle, the Center for American Progress, and the Engelberg Center at Brookings said in a joint statement. “The requirements must be ambitious enough to make the investments worthwhile, but not so onerous that they discourage large numbers of doctors and hospitals from participating. We look forward to reviewing the final rule in detail.” The Markle Foundation works to realize the full potential of information and information technology to address critical public needs, particularly in the areas of health and national security. Markle collaborates with innovators and thought leaders from the public and private sectors whose expertise lies in the areas of information technology, privacy, civil liberties, health, and national security. The Markle Health Program is committed to accelerating the ability of patients and consumers to use information technology to improve their health and health care, while protecting patient privacy. The Center for American Progress is a nonpartisan research and educational institute dedicated to promoting a strong, just and free America that ensures opportunity for all. We believe that Americans are bound together by a common commitment to these values and we aspire to ensure that our national policies reflect these values. We work to find progressive and pragmatic solutions to significant domestic and international problems and develop policy proposals that foster a government that is "of the people, by the people, and for the people.” The Engelberg Center for Health Care Reform at Brookings is committed to producing innovative solutions that will drive reform of our nation’s health care system. The Center’s mission is to develop data-driven, practical policy solutions that promote broad access to high-quality, affordable, and innovative care in the United States. The Center conducts research, makes policy recommendations, and facilitates the development of new consensus around key issues and provides technical support to implement and evaluate new solutions in collaboration with a broad range of stakeholders.