This page will be used to begin developing our collaborative comments on the Meaningful Use Stage 2 NPRM and Standards & Certification criteria.

Working Documents:
ONCStandardsCertRule_CommentsNotes032712.docx (March 27, 2012)
LTPAC_MU_Review(032012).doc (March 20, 2012)
Text from CMS MU Stage 2 proposed rule-Comments031212.docx (March 13, 2012)

Discussion (March 13, 2012)
Larry: Exchange- CMS doesn't want walled-gardens. Looking for transitions of care from one provider to another to be electronic. Only get credit if sending the information to someone outside your organizational structure and using a different EHR program than you are. Not a great way to define policy. Disincentive for 2 providers using the same EHR.

Good goal, but is there a better way to define what we're looking for?
Option1: Everyone required to have a unique ID.
Option2: Required to be connected to a HISP.
Risk of people creating closed networks can be a big problem.

Shelly: Some providers may be excluded from the network.
-Willing providers not part of the network would still be able to accept and exchange with it. If willing, then able to connect.

Networks being built that may not include hospice, home care, labs, etc. Add a layer to use additional networks that could interface with the higher level networks? Simple solution of a Direct Connect?

If we want to encourage exchange w/ our providers, is there a measure of activity that we want to put out there that would demonstrate that we weren't being excluded? How can we define it without saying "outside of the network" or "different EHR vendor"?

Regardless of whether the discharge summary is ready, if there is an identified source of referral.

Can send a summary right at the time of discharge that includes as much info as you have at the moment. Then send subsequent discharge summary when completed.

Want the high bar, as opposed to setting the bar low.

Doesn't seem fair to penalize providers for sharing information if it's in-network, even if the information is good.

Could consider counting only exchanges of information that are standards based, rather than just any exchanges at all. Overcomes the issue of in-network vs. out of network.
Goal #1 - We don't care how it happens, we just care that it happens.

Goal #2 - Don't exclude any docs/providers because they're not part of your system. More than just 10% of data needs to be moving.