CMS/OCN Issue Proposed Definition of “Meaningful Use”, Set Standards for Electronic Health Records
By now, everyone knows (or should know) that under the Stimulus Bill, health care providers are required to make “meaningful use” of electronic health records (EHRs) by 2011 or face penalties in the form of reduced Medicare/Medicaid payments. What has been unknown until recently is what exactly “meaningful use” actually means.
The Centers for Medicare and Medicare Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) issued two proposed regulations December 30, 2009 outlining the terms of the EHR incentive programs, and identifying how providers can make “meaningful use” of EHR and the standards and specifications that will be used to develop “certified” EHR technology.
Both regulations are open to public comment until on or about March 2, 2010 and will take effect sometime in early 2010.
Here are some highlights from the regulations:
Definition of Meaningful User
CMS’s proposed rule defines the term “meaningful user” as an eligible professional or eligible hospital that, during the specified reporting period, meets the following three requirements:
(1) Demonstrates use of certified EHR technology in a meaningful manner;
(2) Demonstrates to the satisfaction of the Secretary that certified EHR technology is connected in a manner that provides for the electronic exchange of health information to improve the quality of health care such a promoting care coordination, in accordance with all laws and standards applicable to the exchange of information; and
(3) Using its certified EHR technology, submits to the Secretary, in a form and manner specified by the Secretary, information on clinical quality measures and other measures specified by the Secretary.
Both the CMS and ONC guidelines make clear that a major consideration of whether “meaningful use” is achieved will be a provider’s ability to securely exchange information among providers, and between providers and patients, using standardized data elements and technologies. The interim final rule issued by ONC set forth these standards and specifications on how to achieve meaningful use; for example, one recognized problem is how providers using EHR actually report patient data. For instance, one provider’s EHR program may list patient demographic information as (PatientAge, Patient Sex, Patient Address), while another provider’s may list similar information in a different way (Date of Birth, Gender, City/State). In order to achieve maximum interoperability, these information models must be reconciled.
After the jump - a phased approach to implementation
Moving Ahead With the Incentive Program
CMS’s proposed rule creates three “phases” for eligible professionals, eligible hospitals, and critical access hospitals to demonstrate meaningful use. Under this phased approach, CMS will update the criteria of meaningful use through future rulemaking (the initial CMS/ONC meaningful use criteria – i.e. the proposed rule and interim final regulation released on Dec. 3 – is referred to as “Phase One”). Stage 2 criteria is currently slated to be released by the end of 2011 and Stage 3 by 2013.
The current State 1 criteria focuses on electronically capturing health information in a coded format; using that information to track key clinical conditions and communicating that information for care coordination purposes; implementing clinical decision support tools to facilitate disease and medication management; and reporting clinical quality measures and public health information.
The Stage 2 criteria is expected to expand upon the Stage 1 criteria to encourage the use of health IT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible, such as the electronic transmission of orders entered using computerized provider order entry (CPOE) and the electronic transmission of diagnostic test results (such as blood tests, microbiology, urinalysis, pathology tests, radiology, cardiac imaging, nuclear medicine tests, pulmonary function tests and other such data needed to diagnose and treat disease).
Finally, the Stage 3 criteria will focus on promoting improvements in quality, safety and efficiency, focusing on decision support for national high priority conditions, patient access to self management tools, access to comprehensive patient data and improving population health.
Alright, Already – How EXACTLY Do I Become “Meaningful” EHR User?
The CMS Proposed Rule contains a proposed Federal Regulation, §495.6, which lists the Meaningful Use Objectives and Measures for eligible professionals, eligible hospitals, and critical access hospitals. These include implementing drug-drug, drug-allergy, and drug formulary checks; maintain active medication lists; recording and charting changes for certain vital signs; etc.
The complete Meaningful Use and Objectives list can be found on pages 467-476 of CMS’s proposed rule, which is available online at: http://www.federalregister.gov/OFRUpload/OFRData/2009-31217_PI.pdf
ONC’s Interim Final Regulation is also available online at: http://www.federalregister.gov/OFRUpload/OFRData/2009-31216_PI.pdf
