In mid July, 2010, The Centers for Medicare and Medicaid Services and the National Coordinator for Health Information Technology issued the Final Rule covering the HITECH Act's Electronic Health Records Incentive Program. Among those issues finalized was the definition of EHR Meaningful Use Stage 1 Criteria.
While several of the larger, more comprehensive systems addressed many of the final EHR Meaningful Use Stage 1 requirements, very few Electronic Health Record Systems addressed all of the requirements initially. Indeed, some of the requirements are not actually functions of an EHR system, such as conducting a HIPAA Security Risk Assessment.
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 was a surprise
When the initial draft of the Meaningful Use Criteria was released many found it surprising that 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.
The Meaningful Use Stage 1 Final Rule only addresses the requirements for 2011 and 2012, the Stage 1 Objectives.
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.
Meaningful Use Stage 1 Objectives
The 15 Core Objectives for Eligible Professionals (EP’s) in the Meaningful Use Stage 1 Criteria 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 in the Meaningful Use Stage 1 Criteria 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 Meaningful Use Stage 1 Measures for 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.
Other aspects of the HITECH Act necessary for the Meaningful Use Incentive program have also been completed. Five organizations have been certified to evaluate and certify EHR applications as “Certified EHR Technology”. Including variants of the same basic system, over 1700 EHR applications have received certification as a complete or modular EHR for ambulatory care practice settings. Only providers utilizing a complete EHR product can attest to meaningful use of certified EHR technology.
Meaningful Use Requirements are Evolving. So what’s next?
On August 23, 2012, CMS issued the final rule on Meaningful Use Stage 2 criteria. This rule covers the Stage 2 criteria for Eligible Professionals (EPs), Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) for purposes of Medicare or Medicaid incentive payments for meaningful use of certified EHR technology.
The Stage 2 objectives and measures expand on the Meaningful Use Stage 1 objectives, transitioning many of the Menu objectives into Core objectives and increasing the thresholds for performance.
How does this evolution impact Eligible Providers?
The Meaningful Use Stage 1 objectives will be relevant for years to come. The Stage 2 Final Rule anticipates providers may not adopt Certified EHR Technology for several years, and may only attest (or be audited!) as meeting Meaningful Use Stage 1 Criteria. Providers who delay in adopting EHR Technology may find the objectives and measures – and vendor capabilities for demonstrating meaningful use - have been overtaken by changes in Stage 2 and Stage 3, making meaningful use against Stage 1 criteria difficult to prove.
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