Is HealthIT getting lost in the weeds?
The NPRM and IFR are by design tightly linked. But the NPRM on meaningful use is primarily a set of instructions for doctors and hospitals about how to participate in the incentive payment programs established statutorily under ARRA/HITECH. The rule on EHR technology certification criteria, on the other hand, is a playbook intended for vendors and developers who want to qualify their products to meet the expected demand by meaningful users in those programs.
The revolution in the marketplace, if it occurs, will come from the changes to EHR technology blueprinted in the IFR, regardless of when, which, or how many doctors and hospitals become meaningful users. Let me explain.
Oh yes, do. (Picture from Coding Horrors, a blog by Jeff Atwood. Too bad there is no book like this.)
NPRM is a Notice of Proposed Rule Making. This is a key document sent out last December, on which comments are due this month. It's the process document by which government agencies implement the laws of the Congress. It turns legislative language into rules people must follow.
ARRA/HITECH is the stimulus bill, specifically the HealthIT portion. That $19.2 billion chunk of change was originally dubbed the HITECH Act, for marketing it among Congresscritters.
EHR is an Electronic Health Record, the subject of all this money. If we have electronic records on patients then they don't have to fill out papers each time they come in, and we can gather statistics that help doctors change their practice and show researchers what works.
IFR stands for Interim Final Rule. When a government agency is in a hurry and doesn't want to go through the NPRM process, it will publish an IFR alongside the notice so everyone gets one shot at making changes to it, and it goes through faster.
Simple enough, if you live in the sausage factory. Simple enough if you're a bureaucrat or a lobbyist or an academic or an expert, maybe even if you're a reporter.
Not so much if you're a doctor, working 16 hours a day, trying both to keep your patients alive and your head above water.
Several commenters on Kibbe's blog post pointed this out, noting they were getting lost in the jargon, and Kibbe responded with a handy guide to the acronyms.
But what will result? That's my problem. NPRMs and IFRs defining EHRs and "meaningful use" are how government works. There is no getting around them. Republicans have to go through the same dance to turn their laws into rules and regulations.
The problem is that English is not used until the process is over, and I worry that it won't even be used then.
The idea here is simple -- put in computers that let you collect data which helps you and your patients and Uncle Sam will pay you back.
But simple ideas have to be broken down into complex, precise language, then re-built, just as computer programs are broken down into specifications, then coded, then given manuals.
I just don't think doctors are going to read the equivalent of computer manuals, do you? Vendors can, and insurers can, that's their job.
But that's not what doctors do. Doctors take their stethoscopes out of the refrigerator and make you jump while you wear a gown open at the back. Doctors have their own complex jargon, get lost in their own weeds, but it's different jargon and different weeds from computerese or bureaucratese.
So how fast can someone put out "Meaningful Use for Dummies?"