mHealth is coming of age, thanks to meaningful use Stage 3.
That's the consensus of thought one week after the release of the proposed guidelines by the Centers for Medicare and Medicaid Services. The 300+ page document, in fact, makes clear for the first time that mHealth technologies – from secure messaging platforms to mobile devices – play a specific role in bringing the provider up to speed with today's healthcare landscape.
"MU 3, welcome to the 21st century," Ricky Bloomfield, MD, Duke Medicine's director of mobile technology strategy – who's working with Apple's HealthKit platform – recently wrote in his blog, "The Mobile Doc."
But some are also wondering whether legislating mHealth – or putting overworked providers under more pressure to change their workflows – will make them any more willing to adopt it.
Patient-generated data had long been considered by the Office of the National Coordinator for Health IT in this third round of incentives for healthcare providers. And the proposed rule, issued March 20, expands the avenues by which providers can converse with patients to include apps, portals and direct messaging. It also makes provisions for provider use of patient-generated data – from apps and wearables, for example.
Some experts are wondering, though, whether the ONC is being too specific in pushing mHealth on the provider community. Former ONC chief medical officer Jacob Reider took the feds to task for jumping in. "This is a great example of the government getting their hands into defining and requiring a 'best practice' process expectation when it's not even clear what the best practice is," Redier told Politico.
The intersection of mHealth and MU3, as it's come to be known, occurs primarily in one segment. In an analysis by John Halamka, MD, CIO of Beth Israel Deaconess Medical Center and Massachusetts eHealth Collaborative CEO Micky Tripathi, three measures of "active patient engagement" were highlighted:
- 25 percent of a provider's patients must access their records through View/Download/Transmit or an ONC-certified app;
- 35 percent of patients must receive a clinically relevant secure message; and
- Providers must incorporate information from patients on "non-clinical" settings from 15 percent of their patients.
"These measures do require patient action, though there is some flexibility because provider-initiated messages now count toward the secure messaging measure, for example," Halamka and Tripathi wrote. "The most challenging measure will be the last one, which requires patient-generated data or data from non-clinical settings such as home health, physical therapy, etc."
And while some have decried that requiring 35 percent of patients to use a secure messaging platform, Bloomfield praised the move. "It's critically important that we encourage direct engagement and interaction between patients and providers, and this measure intends to do just that," he wrote.
Bloomfield said Apple's HealthKit and SMART on FHIR aren't widely adopted, but "will undoubtedly be critical to ushering in the learning health system."
In an interview with Healthcare IT News, Pam McNutt, senior vice president and CIO of the Dallas-based Methodist Health System, voiced concerns that providers would be burdened by the expectation that patients would have to do their part. The requirements that 25 percent of patients view, download or transmit their own health information and 15 percent of data be generated by data be generated by the patient requires actions "on someone else's part," she said.
Halamka and Tripathi call the MU3 proposal "a good first draft" for streamlining and consolidating what had been included in stages 1 and 2, and say APIs are emphasized in "a judicious and thoughtful way." But they also worry that providers will be overwhelmed by all these guidelines.
"The sheer number of requirements may create a very high, expensive and complex set of barriers to product entry," they wrote. "It may stifle innovation in our country and reduce the global competitiveness for the entire U.S. health IT industry by over-regulating features and functions with complicated requirements that only apply to CMS and US special interests."
One group expecting to benefit greatly from MU3, meanwhile, are the mHealth vendors.
"Contrary to providers, those in the health information technology or digital health industry should be quite pleased with the rule as it may provide them with additional customers and markets as providers try to interface with and collect data from patients’ health wearables (e.g., smartwatches with heart rate sensors)," Eric A. Klein and Vinay Bhupathy, of the Sheppard Mullin Richter and Hampton law firm, wrote in The National Law Review.
