The Centers for Medicare and Medicaid Services released the long-awaited definition of “meaningful use” of healthcare information technology on December 30th, providing new guidance for providers and hospitals to qualify for billions of dollars in federal incentives.
The announcement, in the form of agency rule making, marks a critical advance in the stimulus package passed last February as part of the American Recovery and Reinvestment Act (ARRA), according to the following article: http://www.healthcarefinancenews.com/news/cms-releases-long-awaited-definition-meaningful-use-it-federal-incentives
The CMS “meaningful use” document release, which is over 500 pages long, certainly represents an advancement in the sense that much swirling speculation has now been quelled. Providers and vendors can now move forward on an illuminated path. The proverbial ball will start to roll.
My concern is the path is extremely narrow – a lengthy set of detailed requirements and measurements that are clearly derived from existing systems’ technology and functionality. Over 500 pages of requirements and measurements derived from a look at what was and what is, not what can be or what might be? By contrast, the United States Constitution and Bill of Rights is 12 pages using the same font size, page size, and margins. Regardless of your opinion of the current state of affairs in our fine country, the Constitution has certainly withstood the test of time.
Here’s the difference and my primary issue: CMS’s guidance for “meaningful use” is analogous to a specific recipe written much like the treatment plan for a patient. It’s simply too specific. Its specificity eliminates opportunities for flexibility and thus stifles the opportunity for true innovation. Any innovation must be made within the boundaries of CMS’s very narrow path of “guidance”.
The Constitution, on the other hand, provides a framework within which certain principles must be upheld. As a result, there is great room for creativity, innovation, invention, and critical thinking. I submit the CMS guidance for “meaningful use” should be just that – guidance. CMS should deliver its guidance in the form of guiding principles within which participants must operate. As I read all the materials leading up to the delivery of the CMS document on December 30th, I thought I clearly understood the guiding principles – what I call the four pillars of “meaningful use”: improve patient care, improve patient – physician relationships, reduce costs, and improve measurability to ensure accountability. Those are well articulated guiding principles. Add a five to 10 page “CMS Bill of Action”, and I believe CMS can provide sufficient leadership and guidance. A 500 plus page document used for this purpose is, in MBA-speak, micro-management, not thought leadership.
