EHR Meaningful Use Overview
Armed with a definitive checklist of requirements from the final rule, we are confident that our examination of the Meaningful Use guidelines can result in ensuring your success.
What are the Goals of the Meaningful Use Program?
By focusing on the effective use of EHRs, the HITECH Act makes clear that Meaningful Use is not an end-goal; instead it is the ongoing use of EHRs to achieve advanced care coordination and delivery within the following Meaningful Use guidelines:
- Improve the quality, safety and efficiency of care while reducing disparities.
- Engage patients and families in their care.
- Promote public and population health.
- Improve care coordination.
- Promote the privacy and security of EHRs.
In the context of the EHR incentive programs, "demonstrating Meaningful Use" is the key to receiving the incentive payments while achieving quality, efficiency and patient safety in the healthcare system through the use of certified EHR technology.
Making Meaningful Use a Reality
The Meaningful Use guidelines for participation in the Meaningful Use program were released on July 13, 2010. The final rule definitively outlines specific requirements of Stage 1 and clinical quality measure reporting to receive the incentive payments. The HITECH Act specifies three main components of Meaningful Use:
- The use of a certified EHR in a meaningful manner (e.g.: ePrescribing).
- The use of certified EHR technology for electronic exchange of health information to improve the quality of healthcare.
- The use of certified EHR technology to submit clinical quality and other measures.
The definition of Meaningful Use harmonizes criteria across Centers for Medicare and Medicaid Services (CMS) programs and coordinates with existing CMS quality initiatives. It also closely links to the certification standards criteria by the Office of the National Coordinator for Health Information Technology (ONC) and provides a platform for a staged implementation over time.
An eligible professional (EP), hospital and critical access hospital (CAH) must be using a certified EHR in a meaningful manner during prescribed timelines. Each must provide for the electronic exchange of health information, and submit that information based on basic functionality or required clinical thresholds to appropriate CMS-designated registries pertaining to clinical quality measures. Within these overall requirements are Stage 1 EHR Meaningful Use core and menu sets of mandated and optional functions EHRs must provide, and EPs, hospitals and CAHs must show capability.
Key Provision of the Final Rule
CMS' final Meaningful Use rule incorporates changes from the proposed rule designed to make the requirements more readily achievable while meeting the goals of the HITECH Act. For Stage 1, the criteria for meaningful use focus on electronically capturing health information in a coded format, using that information to track key clinical conditions, communicating that information for care coordination purposes, and initiating the reporting of clinical quality measures and public health information.
The final rule reflects significant changes to the proposed rule while retaining the intent and structure of the incentive programs. Key provisions in the final rule include:
- For Stage 1, the final rule divides the objectives into a "core" group of required objectives and a "menu set" of procedures from which providers can choose. This "two track" approach ensures that the most basic elements of meaningful EHR use will be met by all providers qualifying for incentive payments, while at the same time allowing latitude in other areas to reflect providers' varying needs and their individual paths to full EHR use.
- In line with recommendations of the Health Information Technology Policy Committee, the final rule includes the objective of providing patient-specific educational resources for both EPs and eligible hospitals and the objective of recording advance directives for eligible hospitals.
- With respect to defining hospital-based physicians, the final rule conforms to the Continuing Extension Act of 2010. That law addressed provider concerns about hospital-based providers in ambulatory settings being unable to qualify for incentive payments by defining a hospital-based EP as performing substantially all of his or her services in an inpatient hospital setting or emergency room only.
- The rule makes final a proposed rule definition that would make individual payments to eligible hospitals identified by their individual CMS Certification Number. The final rule retains the proposed definition of an eligible hospital because that is most consistent with policy precedents in how Medicare has historically applied the statutory definition of a "subsection (d)" hospital under other hospital payment regulations.
- Under Medicaid, the final rule includes critical access hospitals (CAHs) in the definition of acute care hospital for the purpose of incentive program eligibility.
- The final rule's economic analysis estimates that incentive payments under Medicare and Medicaid EHR programs for 2011 through 2019 will range from $9.7 billion to $27.4 billion.
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