For those following the national quest to adopt electronic health records (EHRs), it is common knowledge that the Centers for Medicare and Medicaid Service (CMS) released the proposed definitions for “meaningful use” of EHRs on Dec. 30, 2009.
The goal behind developing these definitions was to cultivate EHR continuity as the medical community adopts the technology to advance patient safety, health care quality and efficiency.
While it provides the strategic plan for EHR adoption, this long-awaited document is approximately 500 pages, which may leave many confused or overwhelmed. Anyone interested in implementing an electronic health record system in the next few years should stay up to date with meaningful use requirements as well as other aspects related to the economic stimulus plan and health information technology.
These guidelines outline the goals that you as a medical professional must meet to be eligible for American Recovery and Reinvestment Act of 2009 (ARRA) funds during the next several years.
There are currently three stages of meaningful use proposed. Stage 1, which begins in 2011, would kick off the process by entering health information into an electronically coded format. There are 25 of these objectives for eligible professionals and 23 for eligible hospitals. CMS will be listening to comments from providers for 60 days or March 15, 2010. They expect to have the final versions of the definitions of meaningful use ready by this spring.
During this current evaluation and discussion process, you are important. It is up to medical professionals, like you, to carefully evaluate the proposals and comment on their efficiency and effectiveness. Reading articles and blogs about this transformation can help, but the most important tool you have is your experience. If you find areas of the definitions and regulations that will limit or be a barrier to your practice, make sure you file your comment by clicking here.
When filing your comments, explain why the particular regulation may be a problem and send it in by 5 p.m. March 15, 2010. It will not be possible to submit your comments by fax. Comments must use the identifier RIN 0991-AB58. Note that all comments will be available for public inspection, so limit personal or confidential information in your comments. Please see additional filing information at the end of this article. For further information, contact Steven Posnack, Policy Analyst at (202) 690-7151.
The current proposals are in a 500-page document available online starting Jan. 13, 2010.
Now, let’s talk about the proposed definitions that would have impact on your practice.
CMS wants certified EHR to be a routine quality reporting method, as per the CMS fact sheet “CMS Proposes Definition of Meaningful Use of Certified Electronic Health Records (EHR) Technology.” For you that sounds like work? Actually it is a different way of doing things, changing habits so that the next provider who reads the information you entered can easily understand it. Or in reverse, if you are treating a patient who has a certified EHR, you will be able to read the notes and observations easily.
Stage 1 is the beginning of the proposed meaningful use EHR process. From Stage 1’s basic guidelines, Stage 2 and Stage 3 further define and focus the meaningful use definitions.
So what are the definitions outlining the Stage 1 process? According to the Federal Register, Stage 1 outlines which information will be collected to preserve the intent of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) privacy rules.
The rules go on to establish HIPAA transactions and Code Sets standards. Basically, this part of the rule attempts to keep the HIPAA and the EHR timetables in line with each other. Part of this is to make sure the electronic prescribing standards follow the Medicare Prescription Drug Improvement and Modernization Act of 2003 (MMA). For a refresher, this deals mostly with Medicare Part D standards. The proposal is to move from NCPDP Script Version 5.0 to NCPDP Script Version 8.1.
Interoperability is a main focus of the rules. The goal is to move towards a nationwide electronic exchange for health information. Prioritizing standard and specification criteria is the first step to achieving this harmony of data transfer. Eight areas are identified so far. They are:
- Find security technology to help assuage patients’ fears of EHR
- Create infrastructure to assist accurate information exchange
- Achieve 100 percent patient use of EHR by 2014
- Organize accounting and disclosures of treatments, payments, and health care operations
- Improve the quality of health care by using EHRs to reduce medical errors, health disparities, chronic diseases; and improving the population’s health with better medical information continuity and advancing research and education
- Find technology to make sure patient data is unusable and unreadable to unauthorized people
- Organize demographic data collection to provide uniform information
- Find technology to address the needs of vulnerable populations, such as children, elderly and mentally unstable
Incentive Payments and Meaningful Use Reporting Periods
In order to qualify for cash incentives for EHR use, eligible professionals must meaningfully use EHR technology. Until CMS released the preliminarily definitions of meaningful use, no one knew how to meaningfully use EHR. They define certified EHR technology as a qualified EHR that meets the standards of the CMS and Office of the National Coordinator.
Defining the Meaningful Use “Period”
One proposal is to define any continuous 90-day period within the first reporting year. Previous discussions had suggested the first reporting period begin on the first of the year. Federal Register page 1849 cites the example of March 13, 2011 to June 11, 2011 would be just as valid a reporting period as would January 1, 2011 to April 1, 2011. A reporting period that would not be allowed would be one that begins November 1, 2011 and ends January 31, 2012.
Starting with the second payment year, the proposed definition would be the entire payment year. The committee considered the first payment year differently from the rest of the payment years because usually once a medical provider begins to use EHR they are unlikely to stop.
Further discussion continued about the length of the period. If it becomes 180 days, it would allow for more time to ensure a true meaningful use, but it would move the date an eligible party could begin their meaningful use and still receive the incentive payments from October 1, for the 90 day period, to July 1 to comply with the 180 period. If the period is less than 90 days, there may not be enough time to verify that the medical provider will continue to meet the meaningful use criteria. In other words, the 90- or 180- day period would provide a better measure of the providers’ commitment to continue EHR meaningful use than would a shorter period.
Following the first payment year, the proposal is to make the evaluation period the entire year. If you endorse the 90-day period the first year and the entire year the second year, it would be wise to send your comment to that effect. If you have a specific alternative, you should also send that comment. Another idea under consideration is to designate specific start dates. Again, if you have comments on this, please send it to the appropriate place.
Meaningful EHR User
For years past the first incentive year, the proposed definition of a Meaningful EHR User is a Medicaid provider who demonstrates meaningful use of certified EHR technology such as:
Use of EHR technology in a meaningful manner, like eprescribing
Use of EHR that provides for the exchange of information to improve health care
Submission of clinical quality measures
It’s time for your comments. Send in what you think about the proposals. Should anything be added? Deleted?
Meaningful EHR Use
Both Medicare and Medicaid providers have the same definition of meaningful use. They both have to try to adopt, implement or upgrade their certified EHR technology.
What do you think? Should Medicare and Medicaid have separate definitions of meaningful use? Should there be more or less in the definition of meaningful use?
Stage 2 Proposals
The Stage 2 proposals build on the Stage One proposals encouraging expanded use of EHR. The plan is to exchange health information in a structured way and to increase EHR use to include:
Transmission of orders using the computerized provider order entry (CPOE)
Transmission of diagnostic tests
Applying the data to both inpatient and outpatient uses
Please refer to the Attachment to read the specifics before you comment.
Stage 3 Proposals
In Stage 3, the focus shifts to national high priority conditions and improving population health. There is also a section dealing with patient self-improvement.
How often should these definitions be reconsidered? The proposal is every two years.
What do you think?