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EHR “Meaningful Use” Alert

The Centers for Medicare and Medicaid Services (CMS) has issued a proposed rule to implement the electronic health record (EHR) incentive program. It specifies how hospitals and eligible professionals (EPs), including physicians, can qualify for Medicare and Medicaid incentive payments and defines the “meaningful use” of the EHR that is required to receive the payments. The public comment period on this proposed rule closed March 15 and a final rule is expected sometime after June 15. These rules are complex and lengthy, and physicians are advised to seek additional information and advice from their state and national medical societies.

A “Summary of Rulemaking Notices on HITECH Act Incentive Payments” can be found at www.ppsv.com, the Web site of Powers Pyles Sutter and Verville, PC, a law firm focusing on health care, education, and government relations.

The Doctors Company is posting this “Meaningful Use Summary for the Ambulatory Setting” (available on many Web sites, as is an accompanying inpatient summary) to call physicians’ attention to the 25 criteria that must be met for meaningful use.

Familiarity with these criteria is important when selecting an EHR, because the EHR should be capable of meeting these requirements.

Meaningful Use Summary—Ambulatory
The following list of 25 Stage 1 Meaningful Use criteria for eligible providers was taken from the proposed rule: “Medicare and Medicaid Programs; Electronic Health Record Incentive Program.”

1. Objective: Use CPOE.
   Measure: CPOE is used for at least 80 percent of all orders.
2.  Objective: Implement drug-drug, drug-allergy, drug-formulary checks.
   Measure: The EP has enabled this functionality.
3. Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT^®.
   Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data.
4. Objective: Generate and transmit permissible prescriptions electronically (eRx).
   Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.
5. Objective: Maintain active medication list.
   Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data.
6. Objective: Maintain active medication allergy list.
   Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient has no medication allergies) recorded as structured data.
7. Objective: Record demographics.
   Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data.
8. Objective: Record and chart changes in vital signs.
   Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20.
9. Objective: Record smoking status for patients 13 years old or older.
   Measure: At least 80 percent of all unique patients 13 years old or older seen by the EP have “smoking status” recorded.
10. Objective: Incorporate clinical lab-test results into EHR as structured data.
    Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data.
11. Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach.
    Measure: Generate at least one report listing patients of the EP with a specific condition.
12. Objective: Report ambulatory quality measures to CMS or the States.
    Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures as discussed in section II.A.3. of this proposed rule.
13. Objective: Send reminders to patients per patient preference for preventive/follow-up care.
    Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over.
14. Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules.
    Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3.
15. Objective: Check insurance eligibility electronically from public and private payers.
    Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP.
16. Objective: Submit claims electronically to public and private payers.
    Measure: At least 80 percent of all claims filed electronically by the EP.
17. Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request.
    Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours.
18. Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies).
    Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information.
19. Objective: Provide clinical summaries to patients for each office visit.
    Measure: Clinical summaries provided to patients for at least 80 percent of all office visits.
20. Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
    Measure: Performed at least one test of certified EHR technology’s capacity to electronically exchange key clinical information.
21. Objective: Perform medication reconciliation at relevant encounters and each transition of care.
    Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care.
22. Objective: Provide summary care record for each transition of care and referral.
    Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals.
23. Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted.
    Measure: Performed at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries.
24. Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
    Measure: Performed at least one test of certified EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically).
25. Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities.
    Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1) and implement security updates as necessary.

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