Wednesday, April 27, 2016

The MACRA Notice of Proposed Rulemaking

This afternoon, the MACRA Notice of Proposed Rulemaking was released.  I'll publish a comprehensive analysis of the 900+ pages next week, but in the meantime, a few thoughts.

The major ideas are:

*The ONC 2015 Certification Rule applies to all technology used to satisfy MACRA requirements

*Meaningful Use is being replaced by a more flexible construct that is tailorable to specific workflows and specialty practices

*Quality Measures can be selected by each practice to be relevant and aligned with their goals.

This NPRM applies to physician practices only, not hospitals, so we do not yet have clarity on the future of Meaningful Use for hospitals.

Many of the concepts are good - reducing documentation burden, enabling flexbility, focusing on outcomes/quality, engaging patients in novel ways, and emphasizing connectivity/interoperability.

However, the use of  the ONC 2015 Certification Rule is probably not a good idea.      The 2015 Rule is a kitchen sink of standards, many of which are not ready for production deployment.   The Rule is an example of regulatory overambition - instead of narrowing the scope to specific goals or workflows, it includes a cornucopia of use cases unrelated to Meaningful Use.    I highly recommend that we use the Standards Advisory concept to provide a constrained list of standards  but then let vendors innovate as needed to support the workflows desired by patients, clinicians, and hospitals.   Using the 2015 Certification Rule as written will have 3 bad consequences:

*The burden of certification will consume  developer resources that could be used for innovation
*The standards listed in the certification rule have varying degrees of maturity and we'll be setting in concrete some technologies that should not be used
*The certification rule did not envision the kinds of products or services the private sector would develop 2016-2018

I applaud a focus on outcomes and quality.  Meaningful Use has run its course and achieved its goals.   It needs to be replaced.     Along with replacing Meaningful Use, let's rethink the certification concept too.     More to come next week!

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