CMS, which is charged with issuing regulations to implement portions of the HITECH Act, issued an Interim Final Rule describing the criteria for “EHR meaningful use” of certified EMR/EHR technology. Hospitals and “eligible professionals” are entitled to incentive payments for the demonstrated “meaningful use” of “certified” EMR/EHR technology.
The description of meaningful use criteria for EHRs in the statute is limited:
- It must be meaningfully integrated into the delivery of service, including e-prescribing;
- It must be connected to a health information exchange for improving the quality of care; and
- It must be used to submit information on clinical quality measures.
CMS made certain modifications to the recommendations of its Meaningful Use Workgroup of the Health Information Technology Policy Committee, the advisory committee established to propose regulations and policies to implement the HITECH Act.
The new Standards are to be implemented in 3 Stages, and the Interim Final Rule covers only Stage 1, applicable to systems implemented in 2011 and 2012 – or until Stage 2 Standards are issued.
The Stage 1 Standards reduced the number of objectives for meaningful use of EHR technology, and clarified various measures. CMS is supposed to issue Stage 2 Standards by the end of 2011, but has given itself an out by proposing that providers must meet the Stage 1 Standards until the Stage 2 Standards are issued and finalized – even if that goes beyond 2011.
The Meaningful Use Criteria Rule covers:
- The initial meaningful use criteria that a provider must meet to qualify for incentives in the HITECH Act;
- How the incentive payment amounts will be calculated;
- Payment adjustments for providers who fail to meaningfully use certified EHR technology by 2015; and
- Other program participation requirements.
The Stage 1 Criteria cover 3 Health Outcome Policy Priorities, sorted into 10 Care Goals and 24 Objectives for Eligible Professionals and 21 Objectives for Hospitals.
- Many of the Objectives are the same or similar to the Objectives in the original draft.
- A few new ones have been added, such as checking eligibility electronically from both public and private payers.
- The Measures for each Objective have also been clarified. Most require 50 to 80% compliance, and the requirement for clinical decision support rules have increased from 2 to 5.
- In 2011, providers must attest to meeting the Meaningful Use criteria for at least 90 consecutive days. In subsequent years, providers must meet Meaningful Use criteria for the entire year.
CMS has published this Rule as of January 12, 2010, and is soliciting comments for the next 30 days. The Interim Rules become effective on February 12, 2010, and will become final when CMS issues the Final Rules sometime after March 2010.
There are many other issues addressed in this Rule, with many more standards and regulations to come. If you have not already started planning for selection and implementation of an EMR/EHR system, now is the time to start! EHR Vendors do not believe they will keep up with the demand as more and more providers decide the incentives and disincentives are motivational enough to go through the process, so starting early is vital.
There are also many consultants out there who are aspiring to be EHR consultants. If you are considering an EHR consultant, make sure they have the experience and expertise to get you through the process. And make sure any EHR vendors you consider are committed to meeting the Meaningful Use criteria, and can tell you exactly how their software will do it!
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