I’m still really disturbed by the fact that we have so few practical meaningful use details. Sure, we have a lot of guidelines and a lot of prognosticators guessing at what they mean and how they’ll be measured. We even have a certifying body trying to guess what the EHR certification will be. Sadly, they’re all still guesses.
Let’s just take a simple example for a second and see some of the complexities.
Objective: Generate and transmit permissible prescriptions electronically (eRx).
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.
This certainly seems pretty straight forward. Probably about as straightforward as it comes as far as objectives. Basically, 75% of the prescriptions have to be ePrescribed using a certified EHR technology to meet the meaningful use guidelines.
Of course, the real question’s going to be around the word “permissible.” What’s considered a permissible prescription? I imagine this was added because currently you aren’t allowed to ePrescribe controlled substances. If I remember right, controlled substances make up about 15-20 percent of prescriptions. Certainly it wouldn’t be fair to include something that you’re not legally allowed to prescribe electronically in the requirements. Are there other exceptions under the “permissible” rule?
What’s going to happen once ePrescribing of controlled substances is allowed? Will doctors then be required to flip a switch and start sending controlled substance prescriptions electronically as well? Once they’re allowed, they’ll be considered permissible, no?
Let’s also not be surprised if the technology is built to do eprescribing in 2 systems (controlled vs not controlled). Of course, this adds a bit more complexity to measuring the 75% of prescriptions done electronically.
Also, does it give anyone else a bit of angst that the EHR software is basically going to spit out a report saying, “Yes, I ePrescribed 75% of my prescriptions.” I’m not sure how you scale a more sophisticated solution, but just taking some report from an EHR seems plenty gameable to me.
Will ONC be going around and doing some audits of the submissions to ensure that the data was actually good and not messed with? Can you imagine the challenge of having to audit some 300+ EMR vendors. Good luck with that.
I also love how the ePrescribing has to be done with a certified EHR system. A part of me really feels for those specialists that only write a few prescriptions a week. They get to learn the fun thing we call ePrescribing and they forget what they learned by the next time they have to ePrescribe.
UPDATE: Thanks to Russ in the comments, he pointed out the issue of calculating a percentage when your EMR won’t know if you just handed them a paper prescription instead of ePrescribing. I guess the criteria assumes they’re going to order the script and then print it out instead of sending it electronically? So, maybe the criteria should say 75% of scripts ordered in the EMR sent electronically. Just makes me laugh to think about it.
Lest ye think paper scripts don’t happen with an EMR, we can at least argue for them happening during EMR downtime (or printer or workstation or internet or…downtime). Although, they happen other times as well. How will an EMR calculate that percentage of prescriptions? Are they going to translate the freetext note that was entered into the EMR about the paper script that was given? Ideally the doctors will just enter in the script after the fact, but that’s not always the case.
I’m sure I’m missing other intricacies. My point is that there’s still a lot of unanswered questions around meaningful use. It would be nice to get some answers. It would be nice if ONC had a way to get and provide practical answers. You’d think they’d want that type of interaction as well.