Early NPRM questions

March 27, 2012 by MassDevice

As HIT stakeholders review the Meaningful Use Stage 2 NPRMs in detail, questions about the intent of the language are circulating throughout the industry.

The two most common questions I've heard are related to image display (is it viewing via an EHR, through an EHR, DICOM required etc.) and Healthcare Information Exchange transport standards.

Here's a very thoughtful blog post from David Clunie that summarizes the issues of image viewing in the Stage 2 NPRMs.

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Healthcare Information Exchange transport is now required per this provision in the CMS NPRM:

"The EP, eligible hospital, or CAH that transitions or refers their patient to another setting of care or provider of care electronically transmits a summary of care record using certified EHR technology to a recipient with no organizational affiliation and using a different Certified EHR Technology vendor than the sender for more than 10 percent of transitions of care and referrals."

Many are asking what standards and what architecture will be required, since the Standards and Certification NPRM offers a few options.

The HITSC NwHIN Power Team will continue to make recommendations to ONC, but here's my suggestion: