CORHIO Submits Formal Comments on Meaningful Use Stage 2

Date: May 9th, 2012Category: CORHIO e-NewsletterTopics: Meaningful Use

Colorado Health Care Stakeholders Collaborate With CORHIO to Submit Comments, Expressing Support for Program’s Evolution and Concerns About New Potential Burdens

In early March, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) published the proposed rules for Stage 2 of Meaningful Use and encouraged public feedback through May 7. For the past two months, CORHIO worked with various health care stakeholders from across the state to collect and synthesize comments for submission.

CORHIO’s comments express an appreciation for the emphasis CMS has placed on patient engagement and increasing expectations for health information exchange between electronic health record (EHR) systems. However, Colorado stakeholders also express concern over some of the requirements and believe there are areas within the proposed rules that require further consideration and clarification.

 > Click here to read CORHIO's comment letter (PDF)

Challenges of Proposed Stage 2 Meaningful Use Requirements

Several proposed requirements in Stage 2 caused concern for a significant number of Colorado stakeholders. For instance, CMS proposed that more than 60 percent of medication, laboratory and radiology orders created by licensed health care professionals are recorded using CPOE (computerized provider order entry).

Colorado stakeholders are concerned that introducing CPOE for laboratory and radiology orders at the 60 percent threshold may be prohibitively difficult. Instead, CORHIO suggests that the measure should be split to include a 60 percent threshold for medication orders and a lower threshold for laboratory and radiology orders. This will give providers the time to invest in long-term solutions, such as through a health information exchange hub, rather than build out expensive point-to-point interfaces to meet the needed volume within a relatively short period of time.

Another measure that CORHIO and its stakeholder partners commented on is the proposed objective to require eligible professionals and hospitals to provide an electronic summary of care record for more than 65 percent of patient transitions or referrals to another care setting. CORHIO strongly supports this emphasis on real and actionable exchange of patient health information; although there was some concern about the second part of this measure, which requires that this exchange of summary of care records occur across certified EHR technology vendors at least 10 percent of the time.

“While CORHIO and its partners agree with this strong incentive to encourage EHR vendors to focus on interoperability and exchange, we are concerned about how providers will track which transitions occur across which EHR vendors,” explained CORHIO Policy Director, Liza Fox-Wylie. “It would be very difficult for a physician to know which EHR vendors her colleagues utilize and track how many times she sends patient information to providers who use vendors that are different from her own.”

To address this concern, CORHIO’s comments propose that CMS allow providers to demonstrate the capability to exchange across EHR vendors through participation in a health information exchange organization such as CORHIO and, in doing so, be exempted from the 10 percent tracking requirement.

Benefits of Proposed Stage 2 Meaningful Use Requirements

Colorado stakeholders also took the opportunity to express their appreciation for many components of the proposed rules. For example, there is strong support for the requirement of successful ongoing submission of electronic reportable laboratory results and electronic immunization reporting to public health agencies. Lisa Miller, MD, director of disease control and environmental epidemiology at the Colorado Department of Public Health and Environment commented, “We are happy to see this ongoing support of public health reporting as a recognition of how medical providers and public health agencies need to work together to maximize opportunities to improve and protect the public’s health.”

Multitude of Stakeholders Offer Input on Proposed Rules for Stage 2

In order to collect a representative and comprehensive set of comments on the proposed rules for Stage 2, CORHIO engaged with a variety of stakeholders across the state. Each group was given a presentation on the proposed rules and a set of draft comments to solicit feedback. The stakeholder groups include:

  • Colorado Regional Extension Center (CO-REC) partners, including Colorado Community Managed Care Network, Colorado Foundation for Medical Care, Colorado Rural Health Center, ClinicNET, Health Team Works (formerly known as Colorado Clinical Guidelines Collaborative), Physician Health Partners and Quality Health Network
  • Representatives from more than 20 Colorado-based organizations involved across the health care continuum and from communities across the state that participate on CORHIO’s Policy Committee
  • Colorado CIO Communication Collaborative (C4)/CORHIO Technical Advisory Committee, comprised of 75 individuals from approximately 40 organizations.
  • CORHIO technical, implementation, outreach and policy experts
  • CORHIO board of directors, including over 20 recognized health care leaders from provider, health plan, state agency, professional and advocacy organizations
  • Individual health care providers, provider groups, and partner organizations providing feedback to comments posted for public review

Stakeholder comments were compiled and shaped using guidance from CORHIO’s board of directors. For proposed rules in which there was minimal feedback, discrepancy between stakeholders, and/or little relation to CORHIO’s mission and vision, comments were omitted by CORHIO and stakeholders were encouraged to submit comments individually. The final comments were then made available to the community via the CORHIO website for continued feedback through the end of April.

The final rules for Stage 2 expect to be published either in late summer or early fall. For questions regarding Meaningful Use Stage 2 or CORHIO’s process to develop and submit comments, please contact Liza Fox-Wylie at