Guerra On Healthcare: Weighing In On Meaningful UseGuerra On Healthcare: Weighing In On Meaningful Use

Whether a thing is determined to be good or bad depends on perspective. Who does the individual making the judgment represent? What are the criteria they are applying to their evaluation? While I've been sitting here for the last six months criticizing the heck out of the HIT Policy Committee, surely the individuals on that committee feel pretty good about their work, but when they do, what basis are they using in their evaluation, and what basis am I using in mine?

Let's start with me. I use as my yardstick the degree of difficultly for the average-sized hospital at the average level of HIT sophistication to surmount the Meaningful Use bar. Using that measure, I've determined that the proposed requirements and timelines for compliance are almost completely ridiculous. But as I was reminded by John Glaser -- former senior adviser to National Coordinator David Blumenthal, M.D. -- in an interview last week, those regulations are still merely "proposed," because the government (HHS/CMS/ONC) has yet to finish absorbing the many comments it received before issuing final guidance.

The members of the HIT Policy Committee each have their own yardstick for measuring success. Many of the individuals on the committee represent specific organizations with specific agendas for moving policy forward in one area or another. Some are pushing patient-centric care, some privacy and some payer concerns. Some want to move the country down the HIT path rather quickly (usually those not working at provider organizations) while others want to take things slower (usually those working at provider organizations). Each views success by the yardstick of how deeply the recommendations bear their stamp, how loudly they can go back to their supporters and shout: "Look at that requirement -- that was all me. We did it!"

Is there anything wrong with that? Not on an individual basis. This is exactly how our Congress works, and the horse trading required to move legislation along is a necessary part of democracy in action. When putting together the HITECH legislation almost overnight, that same Congress came up with the concept of HIT Policy and Standards Committees to put off to tomorrow what it had no time (or expertise) to craft that day. But it turns out those committees alone would not have produced a workable plan. There's one last rule-making process that may still save the day.

The recently-closed comment period on the above-mentioned regulations -- specifically the process by which the government evaluates those letters -- is where HITECH will succeed or fail.

While each individual on the Policy Committee may have determined whether "good work" was done based upon the depth of their individual imprints, someone must look at the whole. David Blumenthal's review of the recommendations from his Policy Committee must have been tinted with an appreciation that such diverse people came up with any agreement at all. CMS must have been thrilled that ONC reached consensus on a plan, and HHS must have thought it was great that CMS and ONC were all on the same page. But as each entity signed on to the plan, the plan still represented a hodgepodge of concessions to diverse interest groups.

The comment period is a brilliant device because it allows the many constituencies who were not at the table to weigh in on the regulations. I think it's clear that industry groups representing the bulk of healthcare-provider organizations are dead against the current plan.

Through the comment period, the government has heard what the rest of the stakeholders think about Meaningful Use and Certification. Now it's up to the government to decide just what stays and what goes. After speaking with Glaser, I'm hopeful that the comments may act as sandpaper on this rough work, smoothing out the edges and turning a cobbled piece of hardware into a work of art.

Anthony Guerra is the founder and editor of healthsystemCIO.com, a site dedicated to serving the strategic information needs of healthcare CIOs. He can be reached at [email protected].