Physicians and other eligible professionals who want to demonstrate meaningful use of EHRs (Electronic Health Records) and qualify for federal incentives have been anxiously awaiting the release of the EHR Meaningful Use Final Rule, which was released on July 13, 2010.

An initial analysis of performance requirements in the Final Rule indicates that CMS has scaled back criteria for meaningful use in response to concerns that these criteria, as defined in the proposed rule, were set too high. In addition, some flexibility related to reporting of performance measures has been incorporated. Modifications to criteria for meaningful use in the Final Rule should make it easier for eligible professionals to successfully meet meaningful use reporting requirements and qualify for federal incentives of up to $44,000 per eligible provider, under the traditional Medicare Fee-For-Service Plan or $63,750 under Medicaid.

The final rule identifies 25 performance measures for physicians and other eligible professionals. Of these 25 measures, 15 are core measures and must be reported by all eligible professionals. The remaining 10 measures are described as optional, but eligible professionals must select a minimum of five measures from the optional set to report with the added requirement that at least one of the two public health measures must be reported. Eligible professionals must successfully report a minimum of 20 performance measures to qualify for meaningful use incentives.

Overview of Meaningful Use Objectives

The American Recovery and Reinvestment Act (ARRA) of 2009 identified three objectives for EHR meaningful use:

• Use of EHR in a meaningful manner
• Use of certified EHR technology for electronic exchange of health information to improve quality of care
• Use of certified EHR technology to submit clinical quality measures (CQM) and other measures selected by CMS

Meaningful Use Implementation

Meaningful use is to be implemented in stages. Stage I identifies objectives for the first two reporting years, 2011 and 2012, and is focused on health outcomes with stated priorities as follows:

• Improve quality, safety, efficiency, and reduce health disparities
• Engage patients and families in their health care
• Improve care coordination
• Improve population and public health
• Ensure adequate privacy and security protections for personal health information

It should be noted that in order to meet some of the Stage I objectives, 80% of patients must have records meeting certified EHR technology requirements.

The Final Rule provides few details on Stage II provisions except that additional stages will be identified during Stage II. It is expected that current measures will be evaluated and refined and new measures added. In addition, CMS will likely raise the bar for existing requirements, which means that providers will need to meet the measure objectives for a larger percentage of patients.

Meaningful Use Measures for Eligible Professionals

As noted above, there are 25 meaningful use measures for eligible professionals, 15 core measures that must be reported by all providers and 10 optional measures from which a minimum of 5 measures must be reported. At least one public health measure must be reported from the optional measures.

The 15 core meaningful use measures are as follows:

• Use computerized physician order entry (CPOE)
• Practice E-Prescribing (eRx)
• Report ambulatory clinical quality measures to CMS/States
• Implement one clinical decision support rule
• Provide patients with an electronic copy of their health information upon request
• Provide clinical summaries for patients for each office visit
• Perform drug-drug and drug-allergy interaction checks
• Record demographics
• Maintain an up-to-date problem list of current and active diagnoses
• Maintain an active medication list
• Maintain an active medication allergy list
• Record and chart changes in vital signs
• Record smoking status for patients 13 years or older
• Demonstrate capability to exchange key clinical information among providers of care and patient –authorized entities electronically
• Protect electronic health information

Optional meaningful use measures are as follows:

• Perform drug formulary checks
• Incorporate clinical lab test results as structured data
• Generate lists of patients by specific conditions
• Send reminders to patients per patient preference for preventive/follow-up care
• Provide patients with timely electronic access to their health information
• Use certified EHR technology to identify patient-specific education resources and provide these resources to the patient, if appropriate
• Perform medication reconciliation
• Provide summary of care record for each transition of care/referrals
• Demonstrate capability to submit electronic data to immunization registries/systems (public health measure)
• Demonstrate capability to provide electronic syndromic surveillance data to public health agencies (public health measure)

EHR Meaningful Use Timeline

What To Do Now

Even though registration for the Medicare EHR Incentive Program does not begin until January 2011, all eligible providers should prepare now by implementing the following:

• Make sure that all eligible providers in your practice:
  • Have a National Provider Identifier (NPI)
  • Be enrolled in Provider Enrollment, Chain, and Ownership System (PECOS)
  • Have an active National Plan and Provider Enumeration System (NPPES) account (most but not all providers will need an NPPES account)
• Determine with the help of your health IT vendor what EHR technology and/or upgrades are needed by the practice to meet meaningful use requirements
• Review core meaningful use measures
• Determine whether any core meaningful use measures do not apply to your practice and determine what steps need to be taken to be excluded from those measures
• Review optional meaningful use measures and select at least 5 including at least 1 public health measure to report
• Write and/or update policies and procedures for meaningful use
• Check CMS EHR Incentive Programs website frequently for new information

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