The Department of Health and Human Services (HHS) has released a Draft Strategy titled “Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs.” As required by the 21st Century Cures Act, the draft strategy identifies an overall goal of reducing burden related to the use of EHRs and Health IT technologies and proposes strategies and recommendations to reduce their associated clinical burden. The draft strategy reflects a joint effort between HHS, Centers for Medicare & Medicaid Services (CMS), and The Office of the National Coordinator for Health Information Technology (ONC).
Comments on the final strategy are due on January 28, 2019. Comments must be submitted electronically at the webpage for the draft strategy.
HHS acknowledged that administrative burden hinders quality healthcare by increasing the time and expense required to interact with electronic health information. The agency identified increased burden in four areas related to electronic products used by clinicians: clinical documentation, health IT usability and the user experience, EHR reporting, and public health reporting. Additionally, HHS outlined that burden reduction strategies should be achievable within three to five years, implemented through the existing authority or programs, and should improve patient care overall.
A final version of the strategy is expected to be released in late 2019.
HHS Identifies Three Burden Reduction Goals
HHS notes that documenting health measures and patient encounters should be seamless, accessible, high-quality, and be captured within easy-to-use interfaces; information silos should be non-existent, allowing health data can be shared across multiple interfaces, settings, and appropriately capture the health of the patient. This focus on burden reduction hopes to increase interoperability overall and reflects initiatives within existing regulations. HHS named three goals which they believe will result in widespread reduction of burden:
- Reduce the effort and time required to record information in EHRs.
- Reduce the effort and time required to meet regulatory reporting requirements for clinicians, hospitals, and health care organizations.
- Improve the functionality and intuitiveness (ease of use) of EHRs.
Current Clinical Documentation Requirements Necessary, but Increase Administrative Time
Focusing on how clinicians document services and patient encounters for administrative purposes, HHS noted that the use of EHRs posed specific challenges resulting in increased administrative time required to meet regulatory requirements. Specifically, HHS acknowledged that documentation is often different for reimbursement purposes, obtaining prior authorization and ordering procedures and services, and recording steps and outcomes of a patient encounter. To address these issues, CMS discouraged the use of ad hoc strategies and suggested the following three strategies to increase the uniformity of clinical documentation within EHRs:
- Reduce regulatory burden pertaining to documentation requirements for patient visits.
- Adopt best practices related to documentation requirements.
- Leverage health IT to standardize data for prior authorization processes.
HHS wants to use these three strategies to accomplish tasks such as waiving documentation requirements in the testing or administering APMs, using stakeholder input to update reporting requirements, and incentivize the adoption of technologies that support efficient clinical documentation.
Streamlining Health IT Usability May Improve Clinical Workflow
HHS identified that usability challenges, such as poor configurations, challenging interfaces, and lack of alignment across IT products can increase clinician burden. To reduce these user challenges and promote increase ease of use, HHS listed the following options:
- Alignment of EHRs.
- Improvements to graphical user interface.
- Standardization of clinical content within EHRs.
- Improved configuration within EHRs to increase usability.
HHS suggested that adoption of common interfaces within EHR systems would improve documentation and efficiency; clinical decision making could be improved if EHRs were standardized or had standard components. Well designed, easier to use and intuitive software would also decrease the amount of time spent documenting, resulting in a more streamlined clinical workflow, ability to order labs and prescribe new services or pharmaceuticals, and collect comprehensive patient data. HHS recommended the use of existing security technologies, such as facial recognition, as a solution to often cumbersome security measures necessary to protect patient information.
HHS Proposes New Interoperability Quality Measures
The draft strategy acknowledges that timelines across federal regulations often are inconsistent and misaligned, causing administrative work within practices. Requirements are frequently updated, creating administrative and financial burden upon facilities to ensure compliance. HHS also recognized that EHRs can be prohibitively expensive and many do not have the technologies that integrate clinical documentation with mandated reporting requirements. To address these issue, the draft strategy includes the following three strategies:
- Address program reporting and participation burdens by simplifying program requirements and incentivizing new approaches that are both easier and provide better value to clinicians.
- Leverage health IT functionality to reduce administrative and financial burdens associated with quality and EHR reporting programs.
- Improve the value and usability of electronic clinical quality measures while decreasing health care provider burden.
HHS also suggested simplifying the scoring model for the Promoting Interoperability performance category, continuing to provide stated with federal Medicaid funding for health IT systems, and developing new health IT measures that focus on interoperability.
Use of Health IT Systems to Support Electronic Prescibing of Controlled Substances
Federal and state requirements within public health infrastructure may impose burden for clinicians. Specifically, HHS found the following:
- Lack of automated, standards-based public health reporting requirements across federal programs.
- Burden related to electronic prescribing of controlled substances.
- Insufficient interoperability between state prescription drug monitoring programs (PDMPs) and EHRs.
HHS put forth the following two strategies to decrease burden associated with public health reporting strategies:
- Increase adoption of electronic prescribing of controlled substances (EPCS) and retrieval of medication history from state PDMP through integrated health IT systems.
- Inventory reporting requirements for both federal and public health care programs to reduce multiple collections of the same data.
Specifically, HHS suggested that federal agencies should partner with state agencies to improve the ability to electronically prescribe controlled substances while maintaining HIPAA compliance. HHS also urged state and federal policymakers to develop electronic prescribing methods supported by health IT systems that allow a physician access to past prescribing data to better support the dismemberment of controlled substances.