EHR Meaningful Use Overview
Armed with a definitive checklist of requirements from the final rule, we are confident that our examination of the Meaningful Use guidelines can result in ensuring your success.
What are the Goals of the Meaningful Use Program?
By focusing on the effective use of EHRs, the HITECH Act makes clear that Meaningful Use is not an end-goal; instead it is the ongoing use of EHRs to achieve advanced care coordination and delivery within the following Meaningful Use guidelines:
- Improve the quality, safety and efficiency of care while reducing disparities.
- Engage patients and families in their care.
- Promote public and population health.
- Improve care coordination.
- Promote the privacy and security of EHRs.
In the context of the EHR incentive programs, “demonstrating Meaningful Use” is the key to receiving the incentive payments while achieving quality, efficiency and patient safety in the healthcare system through the use of certified EHR technology.
Making Meaningful Use a Reality
The Meaningful Use guidelines for participation in Stage 1 of the Meaningful Use program were released on July 13, 2010. The guidelines for Stage 2 of the Meaningful Use program were released on August 23, 2012. These final rules definitively outline specific requirements of Stage 1, 2 and clinical quality measure reporting to receive the incentive payments. The HITECH Act specifies three main components of Meaningful Use:
- The use of a certified EHR in a meaningful manner (e.g.: ePrescribing).
- The use of certified EHR technology for electronic exchange of health information to improve the quality of healthcare.
- The use of certified EHR technology to submit clinical quality and other measures.
The definition of Meaningful Use harmonizes criteria across Centers for Medicare and Medicaid Services (CMS) programs and coordinates with existing CMS quality initiatives. It also closely links to the certification standards criteria by the Office of the National Coordinator for Health Information Technology (ONC) and provides a platform for a staged implementation over time.
An eligible professional (EP), hospital and critical access hospital (CAH) must be using a certified EHR in a meaningful manner during prescribed timelines. Each must provide for the electronic exchange of health information, and submit that information based on basic functionality or required clinical thresholds to appropriate CMS-designated registries pertaining to clinical quality measures. Within these overall requirements are Stage 1 and 2 EHR Meaningful Use core and menu sets of mandated and optional functions EHRs must provide, and EPs, hospitals and CAHs must show capability.
Key Provision of the Stage 1 Final Rule
CMS’ final Meaningful Use rule incorporates changes from the proposed rule designed to make the requirements more readily achievable while meeting the goals of the HITECH Act. For Stage 1, the criteria for meaningful use focus on electronically capturing health information in a coded format, using that information to track key clinical conditions, communicating that information for care coordination purposes, and initiating the reporting of clinical quality measures and public health information.
The final rule reflects significant changes to the proposed rule while retaining the intent and structure of the incentive programs. Key provisions in the final rule include:
- For Stage 1, the final rule divides the objectives into a “core” group of required objectives and a “menu set” of procedures from which providers can choose. This “two track” approach ensures that the most basic elements of meaningful EHR use will be met by all providers qualifying for incentive payments, while at the same time allowing latitude in other areas to reflect providers’ varying needs and their individual paths to full EHR use.
- In line with recommendations of the Health Information Technology Policy Committee, the final rule includes the objective of providing patient-specific educational resources for both EPs and eligible hospitals and the objective of recording advance directives for eligible hospitals.
- With respect to defining hospital-based physicians, the final rule conforms to the Continuing Extension Act of 2010. That law addressed provider concerns about hospital-based providers in ambulatory settings being unable to qualify for incentive payments by defining a hospital-based EP as performing substantially all of his or her services in an inpatient hospital setting or emergency room only.
- The rule makes final a proposed rule definition that would make individual payments to eligible hospitals identified by their individual CMS Certification Number. The final rule retains the proposed definition of an eligible hospital because that is most consistent with policy precedents in how Medicare has historically applied the statutory definition of a “subsection (d)” hospital under other hospital payment regulations.
- Under Medicaid, the final rule includes critical access hospitals (CAHs) in the definition of acute care hospital for the purpose of incentive program eligibility.
- The final rule’s economic analysis estimates that incentive payments under Medicare and Medicaid EHR programs for 2011 through 2019 will range from $9.7 billion to $27.4 billion.
Key Provisions of the Stage 2 Final Rule
Several changes have been suggested to the Stage 1 measures in the CMS Final Rule released August 23, 2012. These measures, which would be optional for providers to achieve in Stage 1, but required by the start of Stage 2 in 2014, include:
- Changes to the denominator of computerized provider order entry (CPOE).
- Changes to the age limitations for vital signs.
- Elimination of the “exchange of key clinical information” core objective from Stage 1 in favor of a “transitions of care” core objective that requires electronic exchange of summary of care documents in Stage 2.
- Replacing “provide patients with an electronic copy of their health information” objective with a “view online, download and transmit” core objective.
The goals for Stage 2 meaningful use remain consistent and the requirements expand upon the Stage 1 criteria while ensuring a focus on the meaningful use of EHRs. Specifically, Stage 2 requirements include heightened expectations for health information exchange, including: higher thresholds for e-prescribing; the addition of clinical laboratory test results; and the electronic transmission of summary of care records across unaffiliated providers, settings and EHR systems.
Notable changes are the proposed 17 core objectives and a further selection of three of six menu objectives required for EPs. EHs and CAHs are proposed to meet 16 core objectives and further select three of six menu objectives in Stage 2. Currently, Stage 2 is scheduled to commence on January 1st of 2014 for EPs and October of 2013 for hospitals.
A few of the key proposed changes include:
- The use of computerized provider order entry (CPOE) for medication orders increases from 30% to 60%, including a 30% threshold level for labs and radiology. Measurements are now based on orders instead of unique patients.
- Generate and transmit permissible scripts electronically (eRx) increases from 40% to 50%.
- Threshold levels to increase from 50% to 80% for the following:
- Recording Demographics (preferred language, gender, race, ethnicity, etc.).
- Record and chart changes in vital signs for patients over 3 years of age (height, weight, blood pressure, BMI, etc.).
- Record smoking status for patients over 13 years of age.
- The following are moving from the menu set to become core items:
- Patients are provided online access to their health information (via a web portal) on 50% of the occasions, and further, 5% unique patients actually view, download or transmit that data to a third party.
- Successful ongoing submission of electronic immunization data from certified EHR technology to an immunization registered is now required, previously only a test was acceptable.
- Provide a summary of care record for 50% of transitions of care during referrals or transfer of patient care settings, and electronically transmit 10% across EHR vendor types and organizations. This measure combines Stage 1 core items – problem list, active medication list and active medication allergy list – to emphasize increased data exchange.
- Incorporate 55% of clinical lab-test results into Certified EHR Technology as structured data.
- Generate at least one report listing patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach.
- Use clinically relevant information to identify more than 10% of unique patients who should receive reminders for preventive/follow up care.
- Provide patient-specific education resources identified by Certified EHR Technology to more than 10% of patients with an office visit.
- When and EP receives a patient from another setting of care, they should perform medication reconciliation for more than 50% of transitions care.
- Stage 2 also proposes:
- Secure electronic messaging is utilized to communicate with patients on relevant health information for 5% of unique patients.
- Patient family health history is recorded for more than 20% of unique patients.
- More than 10% of all imaging results and information are accessible through certified EHR technology.
- Increase from one clinical decision support to five, encompassing drug-drug and drug-allergy checks.
- Provide clinical summaries to more than 50% of patients within 1 business day.
- Protect electronic health information by conducting or reviewing a security risk analysis and implement security updates as necessary.
- Successful ongoing submission of electronic syndromic surveillance data to a public health agency for the entire HER reporting period. Previously only one test was required.
- Ongoing submission of cancer case information to a specialized registry.
- Capability to identify and report specific cases to a specialized registry (other than cancer).
- Enter at least one electronic progress note created, edited, and signed by an eligible professional for more than 30% of unique patients with at least one office visit.