What is a Meaningful User of EHR?

July 13, 2010 - Final Rule Released by CMS.  This article is not yet updated with the new information.  Join our PedSource News e-Newsletter for announcements about updated articles.  

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 Internet 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 incentive program timeline.

The proposed rule focuses on criteria for the first stage, and CMS plans to propose criteria for Stage 2 and 3 in future rulemaking. CMS has proposed 25 objectives, all of which must be met in order for a provider to be deemed a meaningful EHR user. See the CMS fact sheet or read the Federal Register Document on Meaningful Use.

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 January 13, 2010 in the Federal Register and are based on the recommendations of the HealthIT Policy Council. These criteria are not yet final. 

Much public input has been taken into consideration in the current set of proposed criteria. A number of adjustments have been made that are applicable to private practice pediatricians since the initial criteria were revealed last year.

These changes to the criteria include:

• 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.
• Offices are now required to implement five clinical decision rules based on their specialty

Other changes include:

• Computer based order entry is now expected at a level of 80% vs 100%.
• Problem List has been defined.
• Date of Birth has been added to the required demographics list.

What Does This Mean For Pediatricians?

You can meet some of the Meaningful Us 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 80% of your patients or the requirement of providing a timely response (within 96 hours) for specific communications such as lab test results. 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? There is no incentive for meeting the criteria partially. If you miss one benchmark, you will not receive your ARRA funds.

Note that in the first year of the program, it is not expected that the states will be ready to accept Meaningful Use reporting electronically. Some of the criteria will be proven through attestation.

These changes in addition to the rest of the criteria are still in the "proposed" stage and CMS is accepting comments through March 15, 2010. We encourage you to stay informed in this evolving discussion on Meaningful Use and to voice your opinions by submitting a comment. We will post additional articles when the criteria for Meaningful Use and Certification are finalized, or when more information becomes available.

Conclusion

PCC cautions against falling for "guarantees" from companies promising to fulfill criteria that has not yet been finalized. Additionally, many pediatricians and other providers qualifying for Medicaid incentives may be subject to additional criteria from the states. 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 no amount ofgovernment funding will make up for choosing the wrong EHR.

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