Meaningful use regulations: Thinking outside the box in order to create additional linkages between public health and clinical care systems

Background: Federal and state funding for public health infrastructure is being cut deeply despite increasing demands. This threatens individual lives as well as population health. Ethnic minorities suffer disproportionately, especially from diseases such as tuberculosis, HIV/AIDS, and diabetes. In December 2012, Health and Human Services invited comments on proposed regulations for Stage 3, Meaningful use. The Massachusetts' Medical Advisory Committee for the Elimination of Tuberculosis (MACET)—an independent group of volunteer experts advising on TB prevention and control efforts—decided to submit comments.

Objective: To strengthen linkages between public health and clinical care.

Method: Based on a review of literature, grey literature and expert opinion, MACET composed comments with an emphasis on how proposed regulations—which target clinicians, hospitals and clinics—would or could impact infectious disease prevention and control efforts. TB often served as a case in point. A draft was reviewed by a coalition that included representatives from the Centers for Disease Prevention and Control, National TB Controllers Association, and StopTB USA.

Results: We submitted specific comments on 20 of the 83 items from two of three sections, i.e., Meaningful Use Objectives and Measures and Quality Measures. Items commented on included: 1. SGRP115—Regarding condition-specific lists; 2. SGRP118—Regarding availability of imaging, essential for diagnosing diseases impacting public health such as TB; 3. SGRP305—We questioned if the mandated test results sharing went far enough given the need to close referral loops between public health experts, primary care doctors, case managers, etc.; 4. QMWG02—We suggested measures impacting population health should be prioritized.

Discussion: MACET identified at least 12 options for comment beyond the obvious “public health” items, (e.g. vaccine registries and syndromic surveillance), which may impact or create new support for and linkages with public health efforts. Future requests for comments can serve as opportunities to increase the likelihood of creating such linkages.