The wait is over. After long deliberation and review of over 2,000 comments, the Office of the National Coordinator for Health IT (ONC), together with the Centers for Medicare and Medicaid Services (CMS) have announced the final rule for Meaningful Use, as well as final rules for Certification.
The unveiling took place in a press conference today headed by HHS Secretary Sebelius, joined by ONC chief David Blumenthal, newly-appointed CMS head Don Berwick, Surgeon General Regina Benjamin, and patient-information activist Regina Holliday.
As part of the 2009 American Recovery and Reinvestment Act (ARRA), money was earmarked to incentivize the adoption of Certified EHR technology. This incentive money, paid out as bonuses to physicians and hospitals through either Medicare or (if there is enough volume) Medicaid, can pay up to $44,000 (via Medicare) over the period of 2011-2015 for “meaningful use of certified EHR technology.”
There are two parts to this set of rules: (1) the Meaningful Use rules, which spell out what a physician or hospital must do in order to demonstrate their meaningful use; and (2) Certification rules, which determine what vendors and developers must do in order to create EHR technology that can be deemed HHS Certified. As we have pointed out previously, legacy certification (CCHIT certification) will not suffice – HHS Certification is what is needed to qualify for Meaningful Use money.
The actual final Meaningful Use document can be found here, and a highlight summary was published in the New England Journal of Medicine today. Overall, the vision for moving this country to an interconnected health IT platform, and result in universal adoption of Electronic Health Records (EHRs) by 2014, is preserved in this final rule. What has changed has been an increased flexibility and easier thresholds for entrance onto the “escalator for universal EHR adoption” (to paraphrase David Blumenthal’s words at the press conference this morning)
With the final rule, Meaningful Use is no longer an all-or-nothing proposition. Of the 25 criteria initially proposed, 15 of them are considered “core” and necessary to qualify. The other 10 are considered “a la carte” menu items, from which only 5 need to be demonstrated, with the remaining ones postponed until Stage 2 Meaningful Use (in 2013). The “core” criteria for ambulatory settings are as follows:
1. Record patient demographics (including gender, race and ethnicity, date of birth, preferred language) at least 50% of the time
2. Record vital signs (height, weight, blood pressure, body mass index, and growth charts for children) at least 50% of the time
3. Maintain up-to-date problem lists at least 80% of the time
4. Maintain active medication lists at least 80% of the time
5. Maintain active medication allergy lists at least 80% of the time
6. Record smoking status for patients 13 years of age at least 50% of the time
7. Provide patients with a clinical summary for each office visit within 3 business days, at least 50% of the time
8. On request, provide patients with an electronic copy of their health information (including test results, problem lists, meds lists, allergies) within 3 business days, at least 50% of the time
9. Generate electronic prescriptions at least 40% of the time
10. Use Computerized Physician Order Entry (CPOE) for medication orders at least 30% of the time. (note: CPOE for lab ordering, imaging ordering, and referrals are not addressed here – only medications)
11. Implement drug-drug and drug-allergy interaction checks at least 40% of the time
12. Be able to exchange key clinical information among providers by performing at least one test of the EHR’s ability to do this.
13. Implement one clinical decision support rule, and ability to track compliance with the rule (this is reduced from the previous 5 rules to the final 1 rule)
14. Implement systems that protect privacy and security of patient data in the EHR, by conducting or reviewing a security risk analysis, and taking corrective step if needed
15. Report clinical quality measures to CMS or states – for 2011 provide aggregate numerator and denominator through attestation; for 2012, electronically submit measures (this refers to PQRI measures)
In addition to the 15 “required” elements noted above, a physician must also demonstrate at least 5 of the following 10 items:
1. Implement drug-formulary checking
2. Incorporate lab test data into the EHR as structured data
3. Generate lists of patients by specific conditions (to use for quality improvement, reduce disparities, research, or outreach)
4. Use EHR technology to identify patient-specific education resources, and provide those to the patient as appropriate – and do this at least 10% of the time
5. Provide medication reconciliation between care settings, at least 50% of the time
6. Provide summary of care record for patients transferred to another provider or setting, at least 50% of the time
7. Submit electronic immunization data to local registries (performing at least one test of data submission, where registries can accept them)
8. Submit electronic syndromic surveillance to public health agencies (perform at least one test, where local agencies can accept them)
9. Send reminders to patients (per patient preference) for preventive and follow-up care, at least 20% of the time, or for over-65 year-olds or under=5 year-olds)
10. Provide patients with timely electronic access to their health information, at least 10% of the time.
These criteria keep a high bar for moving everyone toward the vision for universal adoption of EHR technology. As mentioned at today’s press conference, it’s not just about using EHRs for the sake of using EHRs (and thus simply transcribing paper-based charting to an electronic form) – it’s about using these technologies “meaningfully” in order to begin improving the quality of healthcare delivered.
As developers of EHR technologies, our job is to create an EHR that is easily-accessible, highly usable (and therefore easy to adopt), HHS Certified, and contains all the tools needed to allow physicians the ability to easily report on their Meaningful Use criteria and access incentive money.
Robert Rowley, MD
Chief Medical Officer
Practice Fusion EMR
