The federal HIT Policy Committee has approved revised recommendations of a workgroup for an initial definition of "meaningful use" of electronic health records systems. Among the changes made in the recommendations are refinements in computerized physician order entry criteria and a shorter timeline for implementing personal health records.
The definition is important because providers must demonstrate meaningful use of EHRs to qualify for Medicare and Medicaid incentive payments starting in 2011 under the economic stimulus law. The recommendations now go to the Office of the National Coordinator for Health Information Technology and other units of the Department of Health and Human Services. HHS officials will use the recommendations for guidance as they develop rules to implement the incentive programs. A proposed rule is expected by the end of this year.
The policy committee's Workgroup on Meaningful Use recommends that 2011 criteria apply not just to 2011, but also to a provider organization's first adoption year. That means if a provider cannot be ready for incentive payments until 2012 or 2013, the organization still will start with 2011 criteria. In other words, 2011 criteria would be considered Adoption Year 1 criteria.
Consequently, 2013 criteria would be in effect in 2013 or in an organization's third adoption year.
The workgroup's adopted definition of meaningful use is a matrix of more than two dozen requirements that have been revised to some degree since it first was unveiled a month ago. The workgroup made several clarifications, particularly in the area of requirements for adoption of CPOE. But many of the details remain to be fleshed out during the administrative rules process.
For instance, the requirement to use CPOE for "all" orders in 2011 means that 10% of orders of any type must be entered by the authorizing provider. This threshold would accommodate pilot CPOE projects and implementations in progress. But the requirement lacks clarity on how to meet the criteria. For instance, does "10% of all orders of any type" mean that 10% of each type of order must be electronically entered, or 10% of total orders? If the 10% criteria covers all orders, an organization might be able to meet the criteria by electronically ordering all medications, or all supplies, with all other orders remaining paper-based.
Other revisions to the 2011 criteria include:

  • Implement one clinical decision support rule relevant to a specialty or a high clinical priority;
  • Submit claims electronically to payers;
  • Check insurance eligibility electronically when possible;
  • Provide patients with timely electronic access to their health information;
  • Provide patients, upon request, with an electronic copy of their discharge instructions and procedures at the time of discharge; and
  • Require the capability to exchange health information where possible in 2011, with participation in a national health information exchange by 2015.

The revised recommendations also call for giving all patients access to personal health records populated in real-time in 2013, two years earlier than previously proposed.
The policy committee's workgroup also clarified payment of incentives when an organization is being investigated for violations of the HIPAA privacy or security rules. The revised recommendations call for the Centers for Medicare and Medicaid Services to withhold incentive payments until confirmed violations are resolved.
The complete recommendations soon will be available at Click on Public-Private Initiatives, then Health IT Policy Committee.
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