Tuesday, August 28, 2012

Are we Final yet for MeaningfulUse Stage2? Perhaps Not

Apparently not.  I missed something pretty important in my review of the Standards rules with respect to quality reporting.  All I can say was that it was late...

These are two standards cited for quality reporting:

(h) Clinical quality measure data import, export, and electronic submission. Standard. HL7 Implementation Guide for CDA® Release 2: Quality Reporting Document Architecture, (incorporated by reference in § 170.299).

-- AND --

(k) Clinical quality measure aggregate electronic submission. Standard. Quality Reporting Document Architecture Category III, Implementation Guide for CDA Release 2 (incorporated by reference in § 170.299).

These are the references in 170.299:
(12) HL7 Implementation Guide for CDA® Release 2: Quality Reporting Document Architecture, DTSU Release 2 (Universal Realm), Draft Standard for Trial Use, July 2012, IBR approved for § 170.205.

(14) Quality Reporting Document Architecture Category III, Release 1, Implementation Guide for CDA Release 2 (US Realm) Based on HL7 CDA Release 2.0, August 2012, IBR
approved for § 170.205.

Note that Number 14 is different from number 12, and that document that is still in ballot, in HL7.  So, ONC apparently cited a standard that hasn't gone through the consensus process for Meaningful Use Stage 2.  

I was saddened originally by the selection of QRDA III because I'd though what they had selected was still the early DRAFT in the Release 2 DSTU content, and we'd have to make a muddle of it to coordinate the two.  Now that it's the later draft, I'm actually happier.

I'm currently reviewing that standard now, which is why I bring this up.  So far, I have a few negatives that would require changes [following the consensus process].  I'm rather concerned that some would oppose changes because the DRAFT has been named in US Federal Regulation.  I hope that isn't the case, because the US Federal government has a process to fix a broken rule (they used it last time around for the misnamed PHIN Guide).

So, are we really final yet?  Perhaps not.  This does give me hope that we can address the language problem at the same time, but that might just be wishful thinking.

-- Keith


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