04 March 2010

ISDS Seeks Comments on the Proposed Rules for Meaningful Use

Two proposed regulations from ONCHIT and CMS provide certification criteria and measures for implementing the first stage of electronic health record (EHR) incentive programs enacted under the American Recovery and Reinvestment Act of 2009 (Recovery Act). These programs will provide reimbursements to hospitals and providers who become "meaningful users" of EHR technology. Under the proposed regulations, one goal of meaningful use (MU) is to improve population and public health.

The ISDS Board will submit comments on the proposed regulations by the March 15, 2010 deadline. In particular, ISDS Board wants to focus their comments on two proposed certification criteria and measures (or tests) that impact the ability of public health authorities to conduct surveillance using syndromic or electronic health care data. These can be viewed in this document.

ISDS is currently seeking input from ISDS membership and the Distribute CoP on these criteria and measures. Input will be completely voluntary and confidential, and the information will be used to assemble a well informed and robust commentary from the ISDS Board. Please take 5-10 minutes to complete our on-line comment collection form.

To learn more about Meaningful Use, please register for our 30 minute webinar, "Meaningful Use: What it is and why it matters" This webinar will help you gain a better understanding of Meaningful Use, how it may impact your surveillance work, and how you can work with ISDS to represent your perspective and that of your local or state health agency.

Please let us know your thoughts by submitting your comments, attending the webinar, or replying to this blog post.

Best Regards,
Charlie Ishikawa
Community of Practice Coordinator, Distribute

1 comment:

  1. THIS IS GREAT!!! I'm glad to see that we're taking a stance. I see this EHR effort as really having dramatic impact on Public Health. In my mind there are 3 issues:

    1) This will re-define how public health interacts with the medical community. If they spend millions on creating a portable medical record and working out transmitting data to HIEs and Public Health Authorities, they will no longer be ok with us calling them up and saying, "can you please fax over that disease report?" Nor will they be ok with creating a separate comma separated text file from their ED system that is prone to failure. The major risk here is if we don't get into this conversation now and make it clear what we want and work with the players involved, they will either give us what THEY see fit or worse - nothing at all.

    2) I think ISDS is poised to put together a group from our membership that can put together a straw man document of requirements for states defining syndromic surveillance. Currently most of us have systems and requirements that are based on what was most widely available in ED systems 6 years ago. We don't have a good handle on what the EHR will have to offer or better yet, what we would want from this record or what has true public health value. There is a spectrum in my mind. On one end there is an aggregated view of things - like the traditional groups we've used - a GI pile of complaints for example. On the other end there is every single test and procedure that ever happened to every patient. I don't think we want the old GI model - in fact I think we've discovered nearly all of its limitations over the past 6 years. I also don't think we want the specific health records of every patient. However, I think that ISDS is poised to put together members who have done research on this topic and who regularly practice in this area. That group should come together to define a reasonable well informed straw man set of requirements that states and localities can use when approached by their medical providers. Soon we'll have them beating on our door to "test their syndromic surveillance feed". We'd better know what our requirements look like by then (which is 2011 as the current meaningful use requirements read - and that is around the corner).

    3) Most public health departments do not have the infrastructure to handle these informatics issues. And in many cases there is a lack of understanding about what is required. In many cases it is thought of as an "IT" project where you can just hire a contractor off the street to plug in machines and rev them up. I see this as an information management issue that needs thought, personnel, and training. A message needs to come to our State Health Officers from the national level that spells out how important it is to invest in this future with staff who know public health and informatics.

    So I hope after this webinar, we all get engaged and push for increased awareness, increased definition of requirements, and build the case for the resources we'll need to accommodate all of these new data.


    Michael A. Coletta, MPH