Meaningful Use Stage 2 and 3 Comment Period Comes to a Close

On 2/25/2011, the HIT Policy Committee closed the comment period on Meaningful Use stage 2 and 3 standards.  

A few of the measures apply directly to what many Pharmacy Informatics professionals are dealing with today, including:

1.  CPOE for med orders - This objective is still fairly easy to obtain if you have any manner of CPOE in place.  It only requires 1 med order for 80% of patients to be electronically entered (not transmitted)

2.  Drug-drug/drug- allergy interaction checks - lack of standards among data vendors, as well as practice differences makes this one very difficult.  Luckily there are no real measurements, save stating they must be enabled on "appropriate evidence-based interactions".  I am assuming the interpretation of "appropriate" is up to the individual institution.  

3.  ePrescribing - Stage 3 is proposed at 80% of outpatient and discharge prescriptions.  Depending on current levels of adoption, this could be difficult.  

4.  Maintain active medication list - This is somewhat ironic, requiring 80% of medication lists to be up to date.  The irony entails the fact that most often the longer institutions have been live with physicians managing medication lists, the more inaccurate they become.  Therefore those adopting closer to the stage 3 requirements will actually have cleaner lists, unless major cleanup efforts are undertaken.  A great deal of work is ahead of institutions that have been live for years.  Of course we can interpret the "up to date" requirement to mean someone has looked at it, but personally I would take it one step further and state it must be both accurate and up to date.  

5.  Maintain active med allergy list - Similar to #4, this objective gets worse the longer you are live, unless corrective measures are in place.  Not to mention the lack of standardized allergy nomenclature in information systems.  I apply the same comments regarding "up to date" as in #4.  

6.  Implement drug formulary checks - ePrescribing is becoming more common at facilities, but as we have seen in recent commentary, it still presents a standards challenge.  If you would like a copy of Mark Siska's wonderful comments on ePrescribing in general, please email me.  

7.  [NEW] Inpatient med orders are tracked via eMAR - The proposed stage 3 requirement includes 80% of medication orders.  Take into consideration floor stock items, flushes, and those that even currently use eMAR may have to do some work to meet the requirement.  For those that still print paper Medication Administration Records, start talking with your IT department now.  

8.  Patient centered electronic access to medical information - Although not directly related to medication, Personal Health Records currently allow for medication lists to be viewed.  When you implement patient portals, be sure to work with your IT department to review the accuracy and usability of the medication information shown.  

9.  Medication Reconciliation - In Stage 3 the requirement rises to 80% for transitions of care.  The interesting verbiage here places the burden on the receiving provider during a transition of care, not the sending provider.  Some system re-engineering may have to take place if EHRs only support the latter.  

10.  Immunization data submitted to IIS -  Immunization records can be difficult to tame, and transmission of data entails some data quality measures to keep things in order.  Like # 3 and 4, the longer lists have been allowed to be populated without quality monitoring, the more cleanup required.  

Overall, the progression of objectives is fully supported by this Informatics Pharmacist.  However, the lack of standardization, challenges of EHR workflow in practice, and shear amount of work needed to meet the requirements is daunting.  Best of luck to us all, but we can certainly agree we are headed in the right direction.  

MU_Stage 2_RFC _2011-01-12_final.pdf View this on Posterous

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