The stated goal behind requiring health care providers to achieve the meaningful use of electronic health records...
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and EHR systems is to improve the efficiency and quality of care and reduce costs. It is hoped that the requirements will promote the rapid adoption of electronic record-keeping technology nationwide. For health care providers already in the throes of adopting EHR technology, meaningful use may prompt more aggressive deployment; for those lagging behind, it may create pressure to catch up.
The meaningful use requirements could have a wide array of other short-term and long-term effects on health care IT. As with any major IT implementation, deploying EHR systems and using them in accordance with meaningful use requirements have the potential to be costly, complicated and time-consuming. Among other things, these will require training for both IT professionals and non-IT professionals, and expansive new reporting requirements will create paperwork.
- What is meaningful use?
- Who is defining, and enforcing, meaningful use?
- How is meaningful use going to be measured?
- How will meaningful use affect health IT professionals and service providers?
- Are there penalties for noncompliance?
The American Recovery and Reinvestment Act of 2009 -- abbreviated ARRA and known as the economic stimulus package -- devised a program to compel doctors and hospitals to use certified electronic health record (EHR) technology in a "meaningful" way. The program, which is outlined in a section of the law called the Health Information Technology for Economic and Clinical Health Act, or HITECH Act, includes about $19 billion in financial incentives for early adopters and penalties for those who fail to comply by 2015. Under Title IV of the ARRA, doctors and other medical professionals could be eligible to receive Medicare and Medicaid incentive payments as early as January 2011, and hospitals as early as October 2010.
Before the payments can be doled out, however, a definition of meaningful use must be established. The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) were charged with developing rules for the incentives program, including this definition.
CMS released a proposed rule, more than 500 pages long, for implementing the incentives program, including a definition of meaningful use, Dec. 30. The rule is expected to be finalized this spring. The meaningful use rule document outlines the objectives that doctors and hospitals must achieve, the technology criteria needed to meet the objectives, and the corresponding measures to show whether the objectives are met.
The proposed objectives for the meaningful use of EHR include using the technology to accomplish the following:
- Improve the safety, quality and efficiency of delivering health care and public health.
- Reduce disparities in care.
- Improve coordination.
- Improve public health.
- Ensure that adequate safety and privacy protections for personal data are in place
The CMS plans to come up with two additional stages of EHR meaningful use, both with increasingly extensive and stringent criteria. Providers would have to reach these stages by the end of 2013 and 2015, respectively.
According to the CMS, “Stage 2 would expand upon the Stage 1 criteria in the areas of disease management, clinical decision support, medication management, support for patients’ access to their health information, transitions in care, quality measurement, and research and bidirectional communication with public health agencies.”
Stage 3, meanwhile, would center on improving quality, safety and efficiency; emphasizing national high-priority conditions; giving patients tools for self management; and “improving population health outcomes.”
The CMS and the Office of the ONC, both located within HHS, were charged with establishing rules for the financial incentives program spelled out in the stimulus package, including a definition for the meaningful use of certified EHR technology.
Two federal advisory committees created by the ARRA -- the Health IT Policy Committee and the Health IT Standards Committee -- submitted recommendations to the CMS and ONC. The policy committee wrote draft recommendations, provided 10 days for the public to comment and published its final comments on the meaningful use of health IT in September. The committee’s recommendations included a meaningful use matrix of objectives, measures, priorities and goals, which the CMS and ONC used as a foundation for the rules they proposed on Dec. 30.
There remain some question as to exactly how the meaningful use requirements will be enforced. Under the proposed rules, providers will have to demonstrate that they meet the objectives by submitting measurement data to the Department of Health & Human Services (HHS) using certified EHR technology.
As stated, providers will have to demonstrate that their certified EHR systems are connected in a way that enables the electronic exchange of health data, and will have to submit measurement data to HHS using such an EHR system.
The proposal sets up a phased approach for demonstrating the meaningful use of EHR technology. The Stage 1 meaningful use criteria, which must be in place by the end of 2011, include 25 specific objectives that physicians would have to meet and 23 objectives for hospitals. The qualification criteria would be based on technological capabilities currently available, as well as a practice’s experience.
As indicated, the incentives program for EHR technology aims to improve the efficiency and quality of care and reduce costs.
However, deploying EHR systems and using them in accordance with meaningful use requirements may force health care providers to devote significant resources to user training and to creating both paper and electronic reports.
Some in the industry thus have criticized the proposed rules as too complicated, warning that providers and hospitals may have a hard time meeting them. The College of Healthcare Information Management Executives (CHIME), for example, expressed concern that meaningful use reporting requirements could be excessive and overly burdensome. Others warn that many providers face challenges meeting meaningful use criteria and may not be prepared to meet the deadlines; the same is true of hospitals trying to achieve meaningful use, even those with EHR systems already in place.
Still others in the industry caution that the meaningful use requirements could have some dire results, such as widening the digital divide in health care. In a Nov. 14 blog post, Louis Wenzlow, CIO of the Rural Wisconsin Health Cooperative, argued that the requirements target hospitals that already have EHR adoption well underway. Hospitals that provide care for a high proportion of poor patients are already lagging behind, and the rules may not give them enough time to qualify for financial incentives, he said.
Financial incentives for using certified EHR systems in a meaningful way are available for hospitals as early as October and for doctors as early as January 2011. The incentive payments decrease over time, however, and financial penalties will be imposed on providers not using certified EHR technology by the end of 2015.
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