Changes to View, Download and Transmit under the 2015 MeaningfulUse Certification Criteria

This is a big one by itself, and so deserves its own post.  To be fair, they didn't change anything else in this section (Patient Engagement), but beyond Secure Messaging, there wasn't much else there beyond this one.

First of all, they updated the standard to C-CDA 2.0.  But there's a lot of additional features here:

1. Patients need to be able to view their imaging and laboratory reports 
2. They ask for comments on whether patients (Apps really) should have access to the API mentioned elsewhere in the rule.
3. They add addressee to the Audit History (this is minor)
4. They want to know if they should focus only on CCD creation (rather than any other kind of document allowed in C-CDA).
5. They ask again about the maturity of an as yet unpublished specification from HL7 (Data Provenance)... you can guess my answer on that one.  
6. They dropped specification of a Clinical Summary (mostly I think it moved to the Penalties Rule*)
7. On Transmit, they wonder if adding the Trust Bundle Distribution Specification is worth doing.
8. Finally, they wonder if they should add a WCAG 2.0 Level AA requirement (they are already at Level A)

Some feedback on these: First, with regard to access to other reports, I'm all for it, but I would suggest these need not be conformant YET to any published specifications.  I'd be OK with some optional criteria around this (e.g., Diagnostic Imaging Report in C-CDA, or use of XD-LAB for Laboratory results), but at the moment, there are plenty of these that simply aren't available in this format.  Patients need the data, let's not get in their way.

App access to an API is basically what Blue Button Plus Pull was about, and I think that would be a good place to start.  They could build on FHIR and Mobile Access to Health Documents, but given FHIR's readiness, I think a functional requirement is sufficient.  The industry will likely choose FHIR and MHD without any further prompting from ONC.  I think document access is the right place to start.

On the whole CCD question, my answer is thus: Vendors who haven't figured out that it is the section templates that they need to worry about, and NOT the document templates are few and far between.

DPROV is clearly not mature, having not yet even been born by HL7 as a DSTU.  That's still out in HL7 for reconciliation, although they don't note that in the NPRM as they did with everything else.  I still have comments that have yet to be reconciled on that one (now scheduled for early April), and the major delay for me has simply been conflicting schedules.  As I said in a tweet, the metadata on that project should tell you something about its provenance.

On dropping the clinical summary, I think some functional work is necessary here, but unfortunately, the HL7 Pertinent and Relevant project is still being developed and has yet to be approved as a project (we are targeting before HIMSS).

I'll let John Moehrke take on the Trust Bundle stuff, that's not up my alley.

With regard to Level AA, I'm not so sure about that, mostly because of mobile.  Level AA can be challenging in a desktop browser.  With mobile, it could be more so.  I have to think about that one.

   -- Keith

* I used to call the CMS rule the Incentives Rule, but that no longer applies in most cases.