Implementing stage three of Meaningful Use Program will be a mistake

This post originally appeared on US News and World Report’s Policy Dose blog. 

The return on the nation’s $30 billion dollar investment in health IT hinges on electronic exchange of health information. The promised benefits of health IT will only be realized when health data is liberated and shared with other entities, including medical providers, public health authorities, payers and patients. As long as this exchange does not happen and information is not shared, electronic health records will continue to have little more to offer than old-school paper records.

The third stage objectives are impossible to achieve

To facilitate health information exchange, the proposed rules for the third (and final) stage of “meaningful use” – a federal incentive program to get doctors and hospitals using electronic health records – require providers to send electronic summaries for 50 percent of patients they refer to others, receive summaries for 40 percent of patients that are referred to them and reconcile past patient data with current reports for 80 percent of such patients.

But the major difference between these requirements and those of the previous stages of the program is that to fulfill them, a medical provider must depend on others. That is, if other providers do not send electronic summaries, the medical provider who was supposed to receive them will fail to meet the second and third requirement.

This scenario is very likely to happen. Roughly a quarter of physicians have attested to the second stage of the program. This tech-savvy minority is already sharing a large portion of their patients with other providers who were not able to meet the second stage of meaningful use, and thus are likely unable to send electronic care summaries. This leads to a situation in which even tech-savvy providers will not be able to fulfill the requirements of the third stage of the meaningful use program, regardless of their intentions and efforts.

The third stage objectives fail to promote meaningful exchange

The other problem with the proposed rule is its focus on patient recall. In new patient encounters, the program encourages providers to ask patients to identify their previous physicians so that their care summaries could be requested. This approach ignores the fact that in many critical instances, patients are unable to recall all of the medical providers whom they have previously visited, and, even if they do, the process of requesting and receiving electronic care summaries will be as time-consuming as requesting paper records. The type and level of information exchange that stage three of meaningful use is aiming to achieve is already happening – via fax machines.

The main advantage of electronic exchange over paper exchange is that complete patient information will be available to medical providers whenever they need it. Completeness of records and timeliness of access are the two key advantages of the electronic exchange; the objectives defined in stage three of this program fail to address both of them. Instead, after implementing the proposed rules, the completeness of the records depends on patients’ ability to recall their previous providers and the willingness of other providers to send care summaries. The timeliness of access to such records depends on other providers’ availability and responsiveness.

Moreover, the third stage of the program, like the previous two stages, ignores the fact that medical providers are very different and that each of them operates within a unique environment. My research documents the salient effects of professional, geographical and organizational characteristics of medical providers on their willingness to engage in information exchange. Ignoring the differences among medical providers and simply requiring all of them to attest to the same measures is not a smart policy.

Given the distance between the proposed rules of the meaningful use program and the reality of the health care market, the program’s success should be considered a miracle. Even if this miracle happens, we will not achieve much in terms of quality or efficiency in the health care system.

Aligning incentives

As I have previously discussed in detail, health information will start to flow naturally between different entities as soon as their economic incentives are aligned. If providers see an actual meaningful reason to exchange information, they will do it, even without the federal incentives. Instead of forcing providers to exchange information through federally-imposed regulations, we should convince them to choose to invest in this effort, by identifying and demonstrating the benefits and value of information exchange for patients, payers and providers.