Meaningful Use of Patient-Generated Health Data

This week the NPRM for Meaningful Use 3 was made available in "unpublished" form on the Federal Register site. It seems that one of of the primary aims for MU 3 is to streamline the set of objectives applicable to eligible providers (EPs), eligible hospitals (EHs) and critical access hospitals (CAHs).

The new item most interesting to me is Objective 6: Coordination of Care through Patient Engagement (starts on page 103 of the linked document).

This proposed objective aims to "Use communications functions of certified EHR technology to engage with patients or their authorized representatives about the patient's care" and employs three measures:

Measure 1: >25% of all unique patients "actively engage with the electronic health record made accessible by the provider" either by 1) viewing, downloading or transmitting to a third party their health information; or 2) "access[ing] their health information through the use of an ONC-certified API that can be used by third-party applications or devices."

I've previously discussed the Argonaut Project Implementation Program and its relation to the SMART on FHIR project. The FHIR APIs and added functionality of the SMART project (OAuth, OpenID) will dramatically lower the barrier for third-parties to easily add functionality and significant value to current EHRs. While these APIs are already enjoying broad support even before they are complete, seeing this emphasized in the MU 3 NPRM is a testament to their importance.

Measure 2: For >35% of all unique patients, a secure message should be sent using electronic messaging function of CEHRT to the patient, or in response to a secure message sent by the patient.

It's critically important that we encourage direct engagement and interaction between patients and providers, and this measure intends to do just that.

Measure 3: "Patient-generated health data or data from a non-clinical setting is incorporated into the certified EHR technology for more than 15 percent of all unique patients."

This is exciting. While patient-generated data can come in many forms, including manual entry by patients, this measure will only be achievable if we employ technologies that reduce or remove such barriers. Apple's HealthKit is by far the easiest-to-deploy tool to facilitate this data handoff currently, and it's available right now. We're hopeful an Android-equivalent will be available soon for patients with those devices (Google Fit doesn't yet ... fit that purpose).

Neither SMART on FHIR nor HealthKit are yet widely deployed or adopted, but these technologies will undoubtedly be critical to ushering in the learning health system, and it's great to see APIs and patient-generated data being emphasized in the latest NPRM.

MU 3, welcome to the 21st century!

2015-03-24 UPDATE: Just to make sure this is clear, MU 3 is still draft at this stage, and the content is subject to change. Also, attestation for objective 6 will require meeting only 2 of 3 of the measures listed above.