The Office of National Coordinator for Health Information Technology’s Policy Committee is seeking comments on proposed Stage 2 and Stage 3 standards for meaningful use of certified electronic health records by hospitals, physicians and other eligible providers to continue receiving incentive payments in 2012 and beyond. Comments are due to the Policy Committee by February 25, 2011.

The proposed Stage 2 and Stage 3 standards steadily increase the implementation of Stage 1 requirements.  For example, in Stage 1, collection and documentation of demographic information, including race, ethnicity and primarily language, in the electronic health record, is required for 50% of an eligible provider’s unique patients. That percentage would increase to 80% in Stage 2 and then to 90%, plus the use of more granular categories recommended by the Institute of Medicine, in Stage 3.

Similarly, electronic copies of  hospital discharge instructions, now required to be offered to 50% of patients, would be required to be offered to 80% of patients in Stage 2 and to 90% of patients in Stage 3.  However, rather than similarly requiring electronic copies of office visit clinical summaries to be offered in Stages 2 and 3, the proposed standards would require the electronic health record systems to allow patients to view and download such summaries from a patient portal within 24 hours of the office visit.  Other health information (such as test results) would not have to be available through the patient portal for four days after being available to the provider.

The request for comments also asks the following specific questions (meaning that these issues have been identified as important considerations but the Policy Committee has yet to make any specific proposals to address them):

  • For patient/family access to personal health information, what standards should exist regarding accessibility for people with disabilities (e.g., interoperability with assistive technologies to support those with hearing, visual, speech, or mobile impairments)?
  • What strategies should be used to ensure that barriers to patient access – whether secondary to limited internet access, low health literacy and/or disability – are appropriately addressed?
  • What are providers’ and hospitals’ experiences with incorporating patient-reported data (e.g., data self-entered into PHRs, electronically collected patient survey data, home monitoring of biometric data, patient suggestions of corrections to errors in the record) into EHRs?

This is a pre-regulatory process being conducted by the ONCHIT Policy Committee, which is a federal advisory committee to the ONCHIT.   The ONCHIT Policy Committee will then hold additional public hearings in the spring prior to finalizing its recommendations to the ONCHIT.  The ONCHIT and the Centers for Medicare and Medicaid Services, which administers the incentive payments, will then issue proposed regulations for formal public comment, probably in the summer or early fall.  

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