What is a Meaningful User of EHR?

Updated September 3, 2010 by Erica Greenwood

Whether or not you've been following our latest series of articles about ARRA EHR incentive funding for private practice pediatricians, you may be interested to learn more about what is required in order to prove “Meaningful Use” of a Certified EHR. This topic is a key piece of the equation for physicians hoping to get their share of the stimulus money. Even for those who aren't, there is a good chance that issues surrounding this discussion will help shape the way we use Health Information Technology to facilitate patient care moving forward.

If you are considering taking advantage of the ARRA EHR incentives, there are three questions you must address. First, are you eligible? Once you have determined that you are, you must take into consideration whether you need a Certified EHR. Finally, if you are eligible for funding and you plan to adopt, update, or implement a Certified EHR product within the timetable the government has laid out, you also must prove you are a Meaningful User of your Electronic Health Record technology. This article will provide some general information about the proposed criteria for proving Meaningful Use and the recent changes in these criteria that are applicable to private practice pediatricians.

Meaningful Use - A Staged Plan

The objective of the Meaningful Use initiative is to ensure that EHR technology improves patient quality of care. There has been much debate over the translation of this goal into a measurement program. The result is a staged plan starting with a set of criteria that CMS feels is attainable now. CMS expects to grow this set of criteria with at least two more stages occurring during the ten year incentive program timeline.  The program begins in 2011 and ends in 2021.

The Final Rule on Meaningful Use was published in the Federal Register on July 28, 2010 and focuses on criteria for the first stage of the program. CMS plans to propose criteria for Stage 2 and 3 in future rulemaking. The Meaningful Use criteria is organized into 15 "core set" criteria which are required, and 10 "menu set' criteria, of which 5 are requried.  A total of 20 criteria must be met in order for a provider to be deemed a meaningful EHR user.  The criteria outlined in the Final Rule can be read in the Federal Register Document online.  Because the criteria is intended to be used by a wide array of medical offices, the Final Rule and criteria list are quite lengthy.  PCC has reviewed the Final Rule and pulled together a shorter list of Meaningful Use Criteria for Pediatricians interested in this program that may help you make a decision about participation in this program.

Proving Meaningful Use

Providers will need to display Meaningful Use of a Certified EHR system using criteria established by the Centers for Medicare and Medicaid Services (CMS). These criteria were published on July 28, 2010 in the Federal Register and are based on the recommendations of the HealthIT Policy Council. These criteria  are now final. 

Much public input has been taken into consideration and a number of positive adjustments have been made since the proposed rule.

Some changes that occurred between the first and second rule proposals that were applicable to pediatrics included:

• Record and chart changes in vital signs. This now includes the requirement of displaying growth charts for children 2-20 years including BMI.
• Record smoking status has now been adjusted to have a patient age range of age 13 years and older.
• Send reminders to patients per patient preference for preventive/follow up care is now only required for patients over 50 years old.
• Capability to submit electronic data to immunization registries and actual submission where required and accepted is included.
• Specialty based clinical quality measures were proposed.

New changes were released in the Final Rule on July 28, 2010 including:

• The number of requried criteria has been reduced by 5.  There are now 15 required items and a menu of 10 additional, of which, a provider must choose 5.  This change was made to offer flexibility and to recognize that some criteria on the menu set may be prioritized differently by different providers.
• Percentages were reduced.  For example, Computerized Physician Order Entry percentage has been dropped from 80% to 30% and the requirementto Generate and Transmit Permissable Prescriptions Electronically has dropped from 75% to 40%.  Many similar changes were made throught the criteria list.
• Electronic Claim Processing was recognized as necessary for billing yet not a typical function of Electonic Health Records and so it was dropped from the criteria list.
• Clinical Quality Measures were specified and broken into a "core" and "menu" set to allow flexibility.
• States are only allowed to add Public Health related criteria.
• Many, many, specific questions were answered in detail in the final rule document lending further clarification to the intent and scope of the rule

What Does This Mean For Pediatricians?

You can meet some of the Meaningful Use criteria by simply producing reports from your EHR system. If this sounds too good to be true, that's because it is. Certification and Meaningful Use criteria were developed each with the other in mind, but at this stage, it isn't a perfect fit. 

As such, you should not assume that a Certified product will be able to provide all of the reports you need to prove Meaningful Use. Many systems charge for the creation of custom reports so beware of additional vendor fees for Meaningful Use reporting and special reporting pediatricians might need to meet state requirements that don't apply to physicians participating under the medicare program.

Also, note that some Meaningful Use items are not simply reportable numbers from your EHR. For example, the performance of security and risk analysis is a task you must do that will take some time to complete and will need to be updated regularly.

Some of these requirements will necessitate significant changes to your processes (as will an EHR), such as the requirement to provide clinical summaries for 50% of your patients or the requirement of providing a timely response (within 3 business days) for specific communications such as a request for a copy of medical records. The criteria will present both technical and process challenges for many offices and you will need to review the criteria and capabilities of your Certified EHR carefully to determine if the technology cost and the cost of your time to implement, maintain, and report on new initiatives is worth the incentive being provided.

It may also be wise to assess your risk. How confident are you that you can meet all of this criteria, including any special state criteria that pediatricians and other providers qualifying for Medicaid incentives may be required to meet? There is no incentive for meeting the criteria partially. If you miss one benchmark, you will not receive your ARRA funds. 

While this program may be a terrific opportunity for some providers, PCC recommends choosing the EHR that you like the best and implementing it within a time frame that makes sense for your practice. The bottom line, from our perspective, is that no amount of government funding will make up for choosing the wrong EHR. 

If you're thinking about taking advantage of the ARRA EHR Incentive Program, we encourage you to stay informed in this evolving discussion on Meaningful Use. We will post additional articles when news about Meaningful Use and Certification becomes available.

For more on this topic visit: http://www.pedsource.com/ehrmoney

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