Well, its at least a move in the right direction, but ultimately pretty toothless and not likely to generate much movement. To really get anywhere its going to take a hardline on decert of EHRs that don't seamlessly integrate (what that means and the how-to will require CMS dictate terms) and some kind of counterbalance to the economic incentive to NOT share data.
Every step is an incremental step even if imperfect and potentially incorrect path/choice. We learn each time but keep moving.
There was plenty o pushback on their requirement on the chargemaster requirement but there are at least 3 hospitals pushing out real info setting the bar higher for everyone (if I recall was El Camin Hospital Mountain View)
Sure that's small but its progress and imho it only takes one industrious individual to start writing tools/data analysis and share this to help everyone make sense of the info
Same with this - I bet there's plenty to moan about but its a whole lot moe than before and importantly sets a precedent that says you can't charge to produce the access as well as a charge for the care that paid in part for the production of the medical record
After 35B in EHR incentives we have barely moved the needle on interoperability. We've bought a lot of EHR's and put lots of hospitals and clinicians on them but most did more tweaking to their reports than their processes in order to minimally meet the criteria. Almost nothing has been done to help the patient manage their healthcare data across the spectrum. The proposed rules are patient-focused, well coalesced with one another and take into account the burden of implementation. . .and they demand something of payers who have been noticeably absent from any attempts to assist patient's in sharing their data. The cherry on top is the inclusion of the post-acute space which has been a glaring gap even within some closed systems.