EMR / EHR Meaningful Use Criteria are finalized – now what?

Yesterday, the 864 page document, “Final Rule” covering the Electronic Health Record Incentive Program has been issued by CMS.  What does this mean to those hospitals and physicians who are considering purchasing and implementing an EHR system?  Besides finalizing (1) the amounts of the incentives available, (2) the penalties to be applied to eligible professionals, hospitals and Critical Access Hospitals, the Rule finalizes (3) the Meaningful Use Criteria which providers must meet in order to qualify for incentives.

The final “Meaningful Use Criteria“, long awaited, finally arrived. While many of the criteria are the same or similar to those in the draft rule, the approach has changed somewhat.

  • CMS has introduced 15 “Core” elements, which are required,
  • CMA outlines a “Menu” of 10 additional features, of which providers must chose at least 5 to implement.
  • Other major differences include the lowering of thresholds for certain objectives, for instance, generating and transmitting more than 40% of permissible prescription orders electronically, vs. at least 80%.

These changes may make it easier for some EPs and hospitals to achieve meaningful use, but keep in mind that most providers who have adopted EHR systems tell EHR consultants that they get the most benefit out of a system when they use as many of the features as possible on as many patients as possible.  So while the flexibility on some of these measures may be helpful in the short term, they are bare minimums to achieve, not final targets.

And what should you do if you are on the verge of selecting an EHR system and the incentives in the HITECH Act are important to you?  Now is the time for hard barganing with vendors.  Since the Meaningful Use criteria are finalized, serious vendors should be willing to guarantee that their system will give a provider the capability to meet the criteria – and the cure is a refund, not just waiver of maintenance fees or some other smaller concession.  Of course, any vendor who cannot or will not specify their software will be certified electronic technology is not a vendor you want to spend much more time with.

Issuance of the Final Rule was a major milestone, and along with the process for selecting organizations to certify EHR systems, will push the process forward.  Of course, providers must still engage in a due diligence process to make an intelligent decision on the best overall EHR for their organization.

When you need proven expertise and performance

Jim Hook, MPH

Mr. James D. Hook has over 30 years of healthcare executive management and consulting experience in medical groups, hospitals, IPA’s, MSO’s, and other healthcare organizations.

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