- Separates HIT spending from the economic stimulus
- Focuses first on creating a framework for how to handle billions of dollars of HIT funding
- Drives the vast majority of money (90%) through Medicare/Medicaid reimbursement channels
- Focuses the role of state governments on areas that require local coordination, tailoring, and governance
- Moves ONC beyond "coordinator" to actual owner of administrative infrastructure, with all of the programmatic and fiduciary responsibilities that such functions imply
- Makes the Federal government the decision-maker on issues such as technical standards, with input from advisory committees on policy and HIT
I'll admit that I was among those who was getting a little dreamy and even woozy at the thought of billions of dollars flowing into health IT over the next year. Compared to that somewhat heady vision, the House language is surely a disappointment. Yet, like most compromises, it represents progress in certain key areas.
Things I like about the approach are:
- Balance of state-led and federally-led approaches. I like the idea of a network of regional HIT Extension Centers that work directly with ONC rather than through states. State governments have a role as well, but mostly in the areas of coordination, galvanizing health information exchange, promoting quality improvement and public health, and making sure that under-served communities don't get left behind. I like this approach because EHR adoption is not nearly as state- or local-specific as is HIE, which really does need to be tailored to local markets and conditions. Thus, it makes sense to let the Feds drive EHR adoption through regional organizations, and have states focus on state- and local-level HIE concerns.
- Incentives for doing stuff, not just for buying stuff. Focus on incentives that require participants to use the technology, rather than just having systems that are "certified". I like that the incentives are tied to quality reporting and health information exchange because I don't believe that inter-operability standards are enforceable without having activing monitoring by certified HIEs, public health entities, and quality data aggregation entities.
- Resources and authority to ONC to get on with it. Gives the clear message that the federal government has to take a stand on key policy decisions in order for us to move forward. This is not ideal, particularly for standards in a fast-moving, decentralized technology space, but it's not clear to me that other approaches are obviously better. The Federal government needs to set standards for Medicare and Medicaid, so that much makes sense regardless of how standards get determined generally.
Things that I think would improve the House language are:
- Develop a programmatic overlay to the EHR implementations. Inter-operability and robust reporting don't just happen, they get done. And they won't get done if there isn't an implementation program behind the effort, because the systems are too complicated for individual physicians to do this on their own. There's also too much coordination required with other entities, which can only be coordinated by a formalized program. Therefore, we should cement the link between EHR incentives and the HIT Extension Centers. EHR implementations should be executed through or certified by the HIT Extension Centers, otherwise we'll end up with a lot of really bad retail implementations, just like we have today, because we'll only find out about them ex post (ie, after they've failed and can't deliver on their quality and HIE requirements).
- More HIT funding should be made available before 2011. Not necessarily the whole $18B, but there are some parts of the country that are ready to meet the new requirements right away, and we should make funds available to them to build on their momentum while the overall program catches up.
- We should try to go "wholesale" rather than "retail". The current approach to the incentives is to go "retail", meaning physician-by-physician, but there's much more value to be had by going "wholesale", meaning market-by-market. Retail implementations will only mimic, or worse, amplify, the existing entropy of care delivery. Putting a programmatic overlay to "communities" or "markets", such as New York and Massachusetts are doing, creates more effective and efficient vehicles for getting providers to work together, which they do too little of today, and ease the path for them to focus on how to best use technology to improve care across the system, not just in their individual offices.
So, concrete ways to accomplish these goals might be:
- Designate a couple of HIT Extension Centers right away
- Formalize the role of HIT Extension Centers so we get more proactive interventions in government-funded EHR implementations to get better assurance that they get done right the first time, rather than trying to rescue them after they've failed
- Provide additional funding to these HIT Extension Centers for them to provide implementation services to physicians up-front
- Accelerate Medicare and Medicaid incentives to the markets that these HIT Extension Centers cover
- Allow aggregation of incentives by community according to a formula that allows providers who share the same patients to implement in a coordinated way, and perhaps provide a "sweetener" to those who organize themselves this way
One thing we should recognize is that by putting most of this into Medicare/Medicaid incentives, and by delaying most of the money until 2011, HIT could be on a collision course with health care reform. In some ways that's good, because we shouldn't be using technology to try to solve the intractable problems of the current system, we should use technology to enable and enhance a better system. Yet, the reality is that we could get to a point where we push off the 2011 date to align it with health care reform. That would get us even further away from the President-elect's goal of ubiquitious EHRs by 2014.