EHR Meaningful Use Criteria: Overview Including 15 Core Objectives

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“Meaningful Use Criteria” refers to specific features of an EHR system that providers will be required to utilize in their practice if they are to qualify for the incentives listed in the HITECH Act.

On July 13, 2010, The Centers for Medicare and Medicaid Services (CMS) along with the Office of the National Coordinator for Health Information Technology (ONC) released the Final Rule covering the Electronic Health Record (EHR) Incentive Program. This Rule finalizes a great many aspects of the program including the definition of EHR Meaningful Use criteria.

While several of the larger, more comprehensive systems address many of the final EHR Meaningful Use requirements, very few Electronic Health Record Systems address all of the requirements. Indeed, some of the requirements are not actually functions of an EHR system, such as conducting a security risk analysis.

The first draft of the meaningful use criteria was published in June 2009 by the Meaningful Use Workgroup of the Health Information Technology Policy Committee, the advisory committee established to propose regulations and policies to implement the HITECH Act. An Interim Final Draft rule was published in January 2010.

The first draft of the Meaningful Use Criteria were a surprise. There was less emphasis on the traditional functions of an EHR system, e.g., provider documentation and electronic claims submission, and more emphasis on patient access.

In retrospect that was not surprising given that the criteria are driven by Health Outcomes Policy Priorities and Care Goals.

Health Outcomes Policy Priorities for Meaningful Use include:

Improve the quality, safety, efficiency of health care, and reduce health disparities.

Engage patients and families.

Improve care coordination.

Improve public health.

Ensure adequate privacy and security protections for PHI.

The Meaningful Use Criteria Include 10 Care Goals:

Provide access to comprehensive patient health data for the patient’s health care team.

Use evidence-based order sets and Computerized physician order entry.

Apply clinical decision support at the point of care.

Generate lists of patients who need care and use them to reach out to patients, e.g., reminders, care instructions, etc.

Report to patient registries for quality improvement, public reporting, etc.

Provide patients and families with timely access to data, knowledge and tools to make informed decisions and to manage their health.

Exchange meaningful clinical information among professional health care team members.

Communicate with public health agencies.

Ensure privacy and security protections for confidential information through operating policies, and technologies and compliance with applicable law.

Provide transparency of data sharing to the patient.

The Care Goals are implemented through a series of Objectives and Measures. These Objectives and Measures are scheduled for implementation over a four-year period between 2011 and 2015.

The Final Rule only addresses the requirements for 2011 and 2012, the Stage 1Objectives. CMS expects to issue expanded objectives, implementing other requirements in the underlying statute, by the end of 2012, for application in 2013 and beyond.

The Objectives are described for Eligible Providers and for Hospitals. There are two groups of objectives, consisting of 15 “Core Objectives”, plus a Menu of 10 additional features, of which providers must chose at least 5 to implement.

The 15 Core Objectives for Eligible Professionals (EP’s) include:

Use computerized physician order entry (CPOE) for medication orders.

Implement drug-drug, and drug-allergy checks.

Generate and transmit permissible prescriptions electronically.

Maintain an up-to-date problem list, active medication list and allergy list.

Record demographics, vital signs and smoking status.

Implement at least one clinical decision rule.

Report ambulatory clinical quality measures to CMS or to States.

Provide patients with an electronic copy of their health information, including diagnostic test results, problem list, medication lists and medication allergies.

Provide clinical summaries of each office visit.

Have the capability to exchange key clinical information among providers of care and patient authorized entities electronically.

Protect electronic protected health information (ePHI) created or maintained by the EHR through implementation of appropriate technical capabilities.

The list for hospitals is the same, except they must provide patients with an electronic copy of their discharge instructions upon request, vs. a summary of each office visit.

The “Menu Set” for Eligible Professionals includes the following objectives:

Implement drug-formulary checks

Incorporate lab test data into the certified EHR technology as structured data.

Generate lists of patients by specific conditions to use for quality improvement, research, etc.

Send reminders to patients per patient preference for preventive/follow-up care.

Provide patients with timely electronic access to their health information within 4 business days of the information being available to the EP.

Use certified EHR technology to identify patient-specific education resources and provide them to patients if appropriate.

Perform a medication reconciliation for patients sent from another provider or care setting, when an encounter with the patient is appropriate.

Provide a summary of care record when referring a patient to another provider.

Submit data electronically to immunization registries, public health agencies.

The Meaningful Use Criteria objectives are accompanied by Measures – standards of performance of use for each Objective. Thus, Eligible Providers must have an EHR system with the capability of meeting the meaningful use criteria objectives, and must actually use it to certain levels, to qualify for the incentives in the HITECH Act.

Examples of the Stage 1 Measures for Meaningful Use by Eligible Providers include:

Use CPOE for medication orders for at least 30% of all such orders.

Maintain an up-to-date problem list, active medication list and allergy list on at least 80% of all patients.

Record demographics, vital signs and smoking status as structured data on at least 50% of all patients.

Incorporate at least 40% of all lab tests ordered whose results are positive/negative or numerical format data into the EHR as structured data.

Many measures have simple Yes/No answers, such as performing drug-drug and drug-allergy checks.

Reporting on measures is likely to be very challenging since it will require the collection of information to use as a denominator in calculating these percentages. Not all providers will be collecting information on all measures. For example, specialists may not routinely collect information on smoking status or maintain problem lists.

What’s next?

The criteria for Certified EHR Technology, outlining the functionality required for certification, have also been issued.

A few vendors have already pledged to modify their systems to meet the Meaningful Use Criteria, but they now need to decide if they will make modifications to meet the Certified EHR Technology criteria as well as.

An interim process for organizations to certify EHR technology as meeting the Certification criteria has been announced, and a handful of organizations are applying to become certifying bodies. The government is expected to allow for several certification methods or organizations, including CCHIT.

Certified EHR Technology products are expected to be available by the end of 2010, just in time for EPs to start the 90-day period for attestation of meaningful use in 2011.

EPs attaining meaningful use of EHR in the first quarter of 2011 can attest to that fact in April 2011, and begin receiving incentive payments in May 2012.

How does this impact Eligible Providers?

Implementing an Electronic Health Record is a transformative technology even using existing systems. Implementation of systems and practices to meet the meaningful use criteria will require even more adjustments for providers, EHR vendors and EHR consultants. If the incentives of the HITECH Act are important to a provider, then make sure you are dealing with a vendor who has committed or achieved compliance with the Certified EHR Technology standards, and to helping your organization achieve meaningful use of that technology.

For more information on meaningful use criteria and many other issues related to EHR systems, sign up for a free EHR systems reference guide from The Fox Group. This complete 26 page booklet is a logical and sequential description of the process: The Art and Science of Evaluating, Selecting, and Implementing an Electronic Health Records System.

The Meaningful Use Criteria and Certification requirements, if adopted and implemented intelligently, will transform our entire health care system. Will you be part of it?

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