The "proposed" rules will be officially published on March 30. The good news is that comments will be received for a couple of months.
The bad news is that if the Office of the National Coordinator for Health Information Technology is anything like every other regulatory body I've ever dealt with [e,g., the ACGME's Residency Review Committee for Surgery], the "proposed" rules will be the real rules and the comments will be simply a way for disgruntled physicians to vent.
If you don't believe me about the venting, take a look at the 185 mostly negative comments posted on Medscape’s story about Stage 3.
Here are a few of the new rules that will be in effect by 2017 or sooner.
More than 25% of patients seen by an eligible professional (EP) or discharged from a hospital or emergency department (ED) must "actively engage" with their electronic health records (EHRs).
When I was practicing, I had trouble getting some patients to take their medicine or even get out of bed. I don’t know where the people making these rules live, but most of my former patients were highly unlikely to actively engage with their electronic records. I suppose as is the case with unplanned readmissions of noncompliant patients, penalties will be handed out if only 24% of one’s patients engage their records.
Patient-generated data from a nonclinical setting must be incorporated into the EHR for more than 15% of patients seen by the EP or discharged from a hospital or ED.
A “nonclinical setting” is something such as home health care or physical therapy. How anyone is going to be able to track this? Did they mandate only 15% because they know this will be nearly impossible to comply with?
EPs and hospitals must use their EHR to create a summary of care and electronically exchange it with other providers for more than 50% of transitions of care and referrals. In more than 40% of these transitions of care, the provider has to incorporate in its EHR a summary of care from an EHR used by a different provider. In more than 80% of transitions of care, the provider has to perform a "clinical information reconciliation" that includes not only medications and allergies, but also problem lists.
EHRs from different vendors lack "interoperability." They don't communicate very well with each other. “Copy and paste” is out of control now. Wait until you see what happens when people try to comply with these transition of care rules—assuming that EHRs from other doctors can even be opened. This is going to be a monumental amount of work, all of which of course will be uncompensated.
I retired more than two years ago. In social situations, I’m often asked, “Do you miss being a doctor?” I miss the satisfaction that came from helping patients and most of the people I worked with, but I don’t miss the ever-expanding bureaucracy, regulations, and busywork associated with practicing and teaching surgery.
Old age has its rewards. One of them is not having to deal with Stage 3 or even Stages 1 and 2 of Meaningful Use.