Posted by: DonFluckinger
CMS, health IT, HIMSS 2012, Meaningful use, meaningful use stage 2, ONC
LAS VEGAS – Sometimes on the glorified karaoke exhibition known as American Idol on U.S. television, a fan favorite gets voted off the show because viewers assume that the obviously most-talented contestant will surely get enough votes to remain in the competition during the voting periods – and not enough votes come in.
The same principle works for public comments the Office of the National Coordinator for Health IT and Centers for Medicare and Medicaid Services receive for meaningful use proposed rules, said Steven Posnack, ONC federal policy division director, presenting at a HIMSS 2012 symposium.
Therefore, if something in the proposed meaningful use stage 2 rule really works for you – or seems simple and straightforward to implement because you’re already doing it in a similar fashion – tell them about it. Otherwise, Posnack said, the agencies will only see the negative comments and perhaps unfairly assume that a “fan favorite” idea isn’t feasible.
Policy leaders take each comment seriously, he said, and try to address the concerns of stakeholders. Hearing feedback from health care providers along the lines of “we’ve been doing this for six months, it works well, etc.” gives regulators a signal that a particular criteria or aspect of a proposed rule isn’t unfairly onerous or burdensome, he told SearchHealthIT after his presentation.
It also helps confirm that what ONC is proposing isn’t too far off from what health care providers can achieve, he added. If a particular rule gets a lot of negative comments, ONC begins to think that a rule might be too challenging to the industry. Furthermore, he said, suggestions on alternative ways of accomplishing a particular objective or “partially positive” comments help give regulators and idea of how to potentially reshape rules to ease compliance.
“If it’s a multi-part proposal and parts one and two out of three are really feasible but part three really will cause a significant challenge to folks, splitting those out is important to us in a public comment,” Posnack said. “If you just say ‘this requirement in its entirety is too challenging,’ then it’s hard to know if we’ve reached [too far].”
His main point: Don’t let the easy meaningful use compliance mandates get voted off the show in favor of ones that might be more difficult to achieve because you didn’t speak up for them when you had the chance.
At the time both the CMS and ONC stage 2 rules were about to be issued, regulators had planned to release them in the form of a Microsoft Word documents, enabling stakeholders to make comments in their own copies of it, with revisions in running text if they chose to do so. Regulators also have designed a new means to standardize comments on their end, which they hope will enable deeper analysis and discussion once they collect and concatenate all the public comments.