Meaningful Use Final Rule Criteria
What is Meaningful Use of EHR? How does a physician receive government funding and incentives for adopting an EHR or EMR? When do payments begin? Can I be penalized for not having an EHR? Which EMRs and EHRs are certified?
With so many questions about the Meaningful Use Definition, Criteria, Requirements and the Final Rule, we are bringing you the latest information and hope that this summary is easy to understand and answers some of your questions. We will keep this up to date as more information is released.
- EHR Meaningful Use Education Tour– If you are interested in Stimulus Funds and reaching Meaningful Use- be sure to watch these videos
On July 28, the Department of Health and Human Services (HHS) published in the Federal Register the final rules for meaningful use and certification standards of electronic health record (EHR) systems under the Health Information Technology for Economic and Clinical Health (HITECH) provisions of the American Recovery and Reinvestment Act (ARRA). The rules establish the requirements for eligible hospitals and providers to qualify for Medicare and Medicaid incentives for meaningful use of certified EHRs. For a summary of the regulations, you may want to read The New England Journal of Medicine article by David Blumenthal, MD, MPP (national coordinator for HIT at HHS) and Marilyn Tavenner, RN, MHA (principal deputy administrator for Medicare and Medicaid Services).
Meaningful Use Regulatory Definition
The Act provides that an Eligible Professional (EP) shall be considered a meaningful EHR user for an EHR reporting period for a payment year if they meet the following three requirements:
1. use of a certified EHR technology in a meaningful manner
2. that the certified EHR technology is connected in a manner that provides for the electronic exchange of health information to improve the quality of care; and
3. that, in using certified EHR technology, the provider submits to the Secretary information on clinical quality measures and such other measures selected by the Secretary.
Certified EHR Systems
Practice Partner version 9.5, Medisoft Clinical v17, and Lytec MD 2011 recently earned certification as “Complete” electronic health record (EHR) systems under the Office of the National Coordinator (ONC) Authorized Testing and Certification Body (ATCB) process. The software was certified by the Certification Commission for Health Information Technology (CCHIT®), an ONC-ATCB, as 2011/2012 compliant in accordance with the applicable certification criteria for Eligible Providers adopted by the Secretary of Health and Human Services.* Certification was granted on December 6, 2010.
HITECH Program Stages
- Stage 1- Goal: Electronic Capture of Patient Data
- Stage 2- Goal: Improved Clinical Processes
- Stage 3- Goal: Quality Measurement & Improvement (not yet defined)
The Final Rule has defined the first stage of three. Criteria of meaningful use will be updated through future rulemaking which means that there could be future stages beyond stage 3 and the rules in stage 1 could possibly be expanded. Translation: Do stage 1 before they make the rules even harder. And in order to receive the maximum payment you have to enter the program in 2011 or 2012.
EHR Meaningful Use Brochure and Reference Guide
Criteria by payment year and entry year
Stage 1- Two categories of requirements are established (Core and Menu):
1. The 15 Core set of objectives are not optional, and the specified measurement for each objective must be achieved.
2. The Menu set of objectives allows eligible providers to select five of the 10 objectives based on their current stage of EHR implementation.
Core Set of Meaningful Use Objectives
15 Required Measures
1. Use Computerized Physician Order Entry (CPOE)
2. Implement drug to drug and drug allergy interaction checks
3. E-Prescribing (e-Rx)
4. Record demographics
5. Maintain an up-to-date problem list
6. Maintain active medication list
7. Maintain active medication allergy list
8. Record and chart changes in vital signs
9. Record smoking status
10. Implement one clinical decision support rule
11. Report ambulatory quality measures to CMS or the State
12. Electronically exchange key clinical information
13. Provide patients with an electronic copy of their health information
14. Provide clinical summaries for patients for each office visit
15. Protect electronic health information created or maintained by certified EHR
Menu Set of Meaningful Use Objectives
5 of 10 required
1. Implement drug-formulary checks
2. Incorporate discrete clinical lab results into EHR
3. Generate patient list by condition
4. Send reminders to patients per patient preference
5. Provide patient with electronic access to health information
6. Use EHR to identify education resources
7. Perform medication reconciliation on transition
8. Provide summary care record on transition
9. Submit data to immunization registries*
10. Submit surveillance data*
*At least 1 population health objective must be selected
Meaningful Use Table- detailed overview and printer friendly
Changes from previous ruling worth noting under both sets of objectives:
- For computerized provider order entry (CPOE), the final rule requires 30% of patients to have one medication order entered via CPOE vs. the previous proposal of 80% of all clinical orders.
- For electronic prescribing, the final rule requires 40% of all permissible prescriptions written by the physician are transmitted electronically down from the previous 75%.
- Security and Privacy requirements call for a security risk analysis, implementation of security updates and deficiency correction.
- One clinical decision support rule must be implemented vs. the previous proposal of five.
- Providers must be able to electronically exchange key clinical information among providers (pass at least one test transaction).
- Incorporate lab results as structured data (at 40% level).
- Generate lists of patients by specific conditions (at least one condition).
- New: Use the EHR to identify patient-specific education resources (10% level).o
- Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies) upon request for more than 50% of all patients that request it within 3 business days vs. the previous 80% within 48 hours.
- Provide clinical summaries to patients for more than 50% of all office visits within 3 business days down from the previous 80%.
- Perform Medication Reconciliation between care settings (for more than 50% of transitions of care).
* McKesson’s Practice Partner 9.5, Medisoft Clinical v17 and Lytec 2011 are now 2011/2012 compliant and were certified as a Complete EHR on December 6, 2010, by the Certification Commission for Health Information Technology (CCHIT®), an ONC-ATCB, in accordance with the applicable certification criteria for eligible providers adopted by the Secretary of Health and Human Services. The certification number is CC-1112-589589-1. ONC-ATCB 2011/2012 certification conferred by CCHIT does not represent an endorsement of the certified EHR technology by the U.S. Department of Health and Human Services nor does it guarantee the receipt of incentive payments.
The clinical quality measures to which Practice Partner Version 9.5, Medisoft Clinical v17 and Lytec 2011 have been certified include: NQF 0421, NQF 0013, NQF 0028, NQF 0041, NQF 0024, NQF 0038, NQF 0059, NQF 0064, and NQF 0061.
The additional software that Practice Partner, Medisoft Clinical and Lytec MD relied upon to demonstrate compliance includes: Windows Server® 2008 Server which includes BitLocker® and IPSec for 170.302(u) & 170.302(v); SureScripts Messenger™ Services for 170.304(b) & 170.302(b); Medi-Span® for 170.302(e) & 170.302(a); AMA’s CPT® codes for 170.302(d), 170.304(e) & 170.304(a); and RelayClinical™ Education for 170.302(m).