Meaningful Use Stage 3 – Society for Participatory Medicine Comments on Proposed Objectives

The Health IT Policy Committee of the Office of the National Coordinator of Health IT released its proposed Stage 3 objectives for Meaningful Use.  “Eligible Providers” that meet these objectives share in the federal electronic health record incentive program under the HITECH Act.  (Learn more at; here’s some more background on the Stage 1 Meaningful Use regs.)

The Committee wrote that it saw the release of these draft objectives as an opportunity “to begin to transition from a setting-specific focus to a collaborative, patient- and family-centric approach.”

The Society for Participatory Medicine filed comments on the draft Meaningful Use  Stage 3 objectives (PDF), saying: “We endorse the proposals that further this goal, and offer some focused recommendations intended to ensure that the final regulations are in fact designed to help achieve this goal.”

One of the key issues presented in this draft is the opportunity afforded to patients to correct misinformation in their medical records.  The Society’s comment:

We feel that patients should be involved in amending, reconciling, and correcting errors in their medical records. Making this possible will require EHRs that support patient assistance, patient portals or other mechanisms for patients to do this online, and workflow tools for both providers and patients. We propose that ONC establish additional working groups or technical expert panels to study these issues and establish relevant standards.

The Society also responded to the Committee’s request for information on the use of patient-generated data, endorsing its use, and noting that: “The patient is the most highly qualified expert on his or her own health, and his or her own experience of the health care system.”

I invite you to peruse the proposal and comment letter linked to above. Again, the perspective on these matters espoused by the U.S. government agency is that we need to focus on enabling provider-patient collaboration. The Society approves.

A special thanks to Adrian Gropper, M.D., of the Society’s Public Policy Committee, and to the members of the Society’s Executive Committee, for their contributions to the review and comment process.

David Harlow is a health care lawyer and consultant at The Harlow Group LLC, and chairs the Society for Participatory Medicine’s public policy committee.  You should follow him on Twitter: @healthblawg


Posted in: general | policy issues | pt/doc co-care | reforming hc




2 Responses to “Meaningful Use Stage 3 – Society for Participatory Medicine Comments on Proposed Objectives”

  1. The critical CEO position at the newly built public Parkland Hospital in Dallas is vacant. Various “experts” explain how patient centeredness and patient safety will be reached.

    Here’s one example:

  2. David Harlow says:

    In response to an inquiry on the S4PM listserv …

    What does this mean?

     103 – EHR batch export to reduce vendor lock-in.
    Batch import capability should be required as well.

    … Adrian Gropper responded. His response is reproduced below with his permission:

    Vendor lock-in is a business model / technology strategy where prices are artificially inflated by high switching costs. Many have experienced this before phone number or email address portability. EHR market strategy is almost universally on the basis of vendor lock-in. The elements include up-front license fees (as opposed to monthly payments), high training costs (as opposed to ease-of-use), unnecessary customization (as opposed to defaults that follow free and open standards), and high installation costs that charge up-front for every HL7 and related interface (as compared to DICOM or Web interfaces that have zero installation costs).

    The net result of vendor-lock in is not just inflated prices (particularly for upgrades) and expensive or non-existent interoperability. It also results in bad customer service because the vendor is more interested in selling another system to lock in another customer rather than putting resources into keeping existing customers happy.

    A major element of the vendor-lock in business practice is the cost of transferring thousands to millions of health records to a new system. In smaller practices, this is typically done by re-entering key demographic information and then keeping the old and new systems on each desktop for months or even a year so that important data can be moved by re-typing as needed. You can imagine the opportunities for error in this scheme.

    Batch export would force the incumbent EHR vendor to export some or most of the database wholesale and would mostly eliminate the cost and risk of re-keying. Unfortunately, it’s not guaranteed that vendors would implement batch import or that the export would be in a standard format. In a market where patents are not particularly valuable, vendors will do absolutely everything they can to increase switching costs.

    Comment IEWG 103 is suggesting that if both export and import is required there would be a greater chance that vendors will reduce this cost. I stopped short of suggesting a standard format because, can you believe it?, no such formats exist.

    The only sure-fire solution to this problem is open source software. The rest of clinical practice is open source (even drugs and devices that are patented are still not secret). Open source systems have little ability to lock in the customer because it is easy to add any import or export function as needed even without a standard. Also, open source software creates a much larger market for commercial services by reducing the barrier to entry into the customer support business. Open source software is therefore effectively, pay as you go and if a service provider disappoints then you can simply switch to another service provider.

    In other words, open source software reduces switching costs by reducing the reasons to switch (missing features and bad service) to begin with. With open source software you still have installation and training costs but these can be sourced competitively because the software is open.

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