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Pabrai on HIPAA/HITECH Compliance

Aug 23 2010   11:51AM GMT

Understanding Meaningful Use EHR Objectives



Posted by: Pabrai
EHR, HITECH, Meaningful use

The objectives defined in the proposed rule for meaningful use were offered with more flexibility and choice in the final rule on the meaningful use EHR incentive program published on July 28, 2010. The rule is effective September 26, 2010.

The objectives in the final rule are designed to allow program participants to establish their own path to meaningful use. Further, the bar for measurements associated with several objectives was lowered. In the proposed rule for meaningful use 27 objectives had been defined in Stage 1 of the program. In the final rule, the objectives were organized into two tracks: Core Set and Menu Set. Program participants must achieve each of the objectives in the core set, while the menu set provides for greater flexibility in Stage 1. Think of the core set as mandatory while the menu set provides a la carte objective choices.

How many core set objectives have been defined? For Eligible Professionals (EPs) a total of 15 objectives are defined in the core set; while Eligible Hospitals (EHs) and Critical Access Hospitals (CAH) must meet 14 core set objectives.

What about menu set? How is the menu set criteria organized? The menu set actually includes twelve objectives of which ten apply to EPs and ten apply to hospitals.  EPs and hospitals must choose five out of the ten menu set objectives. The items not chosen are deferred to Stage 2. There is, however, one requirement related to the menu set – participants must select at least one population and public health measure.  

What is the timeline for criteria to be updated? HHS expects to update the meaningful use criteria every two years. Stage 2 criteria are expected to be finalized by the end of 2011 and Stage 3 criteria by the end of 2013. In the final rule, HHS also chose to remove all language about direction beyond 2014 – this would be addressed in future rule making. Further, providers joining the program in 2013 will be required to be at Stage 1 in 2014 – and not Stage 2 as was in the proposed rule.

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