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Tuesday, March 24, 2015

What? Me Worry? Care Coordination in MeaningfulUse

I've just made it past the Care Coordination section of the Meaningful Use Certification NPRM.  Clearly I'm picking up speed, and hope to be done the rest of the rule today, but thought I'd share what I've learned thus far:

Not to Worry about:

There isn't a thing that you shouldn't worry about some in this section, unless of course your name is Alfred E. Neuman.

Worry about a little:

Transmission of Laboratory Test Reports, and incorporation of Laboratory Test Results both have updated standards.  This isn't really a huge lift, but you will need to pay some attention to the new standards.

Worry about:

Data Segmentation for Privacy is a new requirement, so even though it is fairly easy (tag documents as being more restricted for example), you should pay a bit more attention to this.  

If you are one of those called out on Data Portability for making it hard to use or configure by the customer, you have some work ahead of you, otherwise you'll be just fine.  I'm not too worried about this one.

For Reconciliation, they'll be tightening up the testing.  This is long overdue in my opinion.

Worry about a lot:

There's a technical term for the quantity of change in the Transitions of Care requirements that is NSFW.  We call it a ****-ton in software engineering terms.

First, there's a version change in C-CDA which adds a number of new document types.  That alone is a big effort, but not as big as before the template versioning problem got resolved.

Next there's some stuff about validation checking CCDA documents.  Now, if you haven't been checking whether inputs to your EHR system coming from outside the user organization are valid to begin with, you have quite a bit to worry about (I personally am not too worried about this). However, this is going to involve some product change in a few places because ONC will now be looking over your shoulder at how you do this.

Can your product handle an XDM file in a Direct communication?  If not, you need to worry about this.

Finally, you need to make sure that identities you communicate are well suited for patient matching down the road.

These last two items are small in and of themselves, but they are all wrapped up in one VERY BIG certification criterion.

e-Prescribing is another area where there's a boat-load of changes.  In addition to requiring NEWRX messages, ONC is proposing the testing of five other transactions in NCPDP Script 10.6: RXCHG/CHGRES, CANRX/CANRES, REFREQ/REFRES, RXFILL and RXHREQ/RXHRES. 

Also, they have proposed the use of structured sigs in prescriptions.  No more dumb text which led to this mess in my daughter's prescription.

Lastly, there are Care Plans, which is another completely new thing in C-CDA, and has some serious ramifications.  I'm all for this one, but as a new requirement, you'll need to examine it deeply.


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