As each week passes, more and more commentary, expert opinion and conferences emerge regarding one of the key stipulations of the HITECH provisions of the stimulus package.  Specifically, what does it mean to be a “meaningful user” of a certified EHR?  While such debates have existed for a while, never before has there been $19 billion attached to the answer.  While many have described the HITECH provisions as largely a subsidy for EHR companies, the “meaningful user” criteria offer a range of requirements that will significantly impact of other sectors in the industry, including quality reporting, work flow redesign, business process management, electronic prescribing and health information exchange.

The debate is only beginning, and the HIT Policy Committee and CMS will have the final say.  Nonetheless, health information exchange capacity, if not actual activity, is an expectation of both physicians and hospitals if they are to earn incentives for “meaningful use”.  HIMSS has already offered its interpretation of meaningful use, stating that hospitals must demonstrate,

“Electronic exchange of standardized patient data with clinical & administrative stakeholders using the Healthcare Information Technology Standards Panel’s (HITSP) interoperability specifications and Integrating the Healthcare Enterprise’s (IHE) frameworks
 
As hospitals move through the incremental phases, they require interoperability tools that, as of this writing, do not yet exist.”

In discussing this recommendation with HIMSS informally, HIMSS states a primary goal is to recognize the work that HITSP and IHE have already done regarding interoperability, including specific use cases.  Similar to likely connection between ARRA’s term “certified” and the CCHIT, HIMSS supports leveraging existing work in HIE.  Importantly, the recommendation was not meant to ignore or discount solutions that are designed to accomplish this exchange in a practical way, even though HIMSS may not be aware of them.  While so called “interoperability tools” are not yet widely used, they definitely do exist and are beginning to enjoy increasing adoption.

John Halamka, Chair of the US Healthcare Information Technology Standards Panel (HITSP), summarized the testimony of several experts participating in a recent NCVHS meeting regarding meaningful use and HIE, stating,

“Health Information Exchanges will evolve locally based on business cases in communities. The services offered may include e-prescribing, diagnostic test results delivery, quality data warehousing, data normalization into common formats and vocabularies”

The College of Healthcare Management Executives (CHIME) has also weighed in on “meaningful use” and health information exchange.  Specifically CHIME recommends,

• exploring alternative means to connectivity in the short term and connection to an HIE over time;
• and consideration of alternative means to use of CCD for exchange of health data.

There seems to be consensus developing that practical approaches to HIE are what is necessary, and that local health information exchange solutions (proprietary or “LHIO” type) may emerge as reasonable and early demonstrations of HIE meaningful use.  For hospitals and physicians looking for practical solutions, a cost effective appliance that can receive data, normalize it, and exchange it with trusted trading partners is a compelling way to proceed.  Time will tell whether the political process reaches practical interpretations for meaningful use or not, but moving vital clinical information between clinical partners will always be a compelling priority.