HIMSS Synopsis & Overview Webinar on Meaningful Use, Standards, & CertificationOn Wednesday, December 30, the Department of Health and Human Services released the Notice of Proposed Rule Making (NPRM) establishing the Electronic Health Record (EHR) Incentive Program, commonly referred to as the Meaningful Use of an EHR, and the Interim Final Rule (IFR) establishing the Initial Set of Standards, Implementation Specifications and Certification Criteria for EHR Technology. The following is a brief synopsis of the regulations. Visit the HIMSS website for an evolving set of tools to navigate and analyze the nearly 700 pages of regulatory change.
Sign up.On Wednesday, January 6 at 2:30pm CT, Martin Harris, MD, MBA, FHIMSS will present a 90-minute HIMSS overview webinar of the NPRM and IFR. Complimentary for HIMSS members, the webinar as led by Dr. Harris – CIO & Chairman of the Technology Division at Cleveland Clinic, Executive Director of the e-Cleveland Clinic, Chairman-Elect of the HIMSS Board of Directors, and member of the HIT Standards Committee – will highlight the themes and major components of the regulations. The overview is the first in a series hosted by HIMSS, so register today.
Upon release, the two regulations were described by Dr. David Blumenthal, National Coordinator for Health Information Technology, as enabling the transformation of the health system to "improve health care quality, efficiency, equity, and safety through the use of health information technology (HIT), while providing the foundation for continued, measurable improvement in our nation's health." The regulations are part of the federal government's investment in health IT that will allow patients to engage proactively with providers who are able to leverage technology to improve the quality and cost effectiveness of care delivery.
As a point of clarification, the process for certifying EHR products is not defined in these two proposed rules. In January, a third rule will be issued that defines the process by which ONC will recognize how products become certified and by what organization(s).
Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology
Status and Size of the Regulation: Released as an Interim Final Rule for public comment on December 30, 2009. The 136-page document will be posted officially in the Federal Register on January 13, 2010, and includes a 60-day comment period. A final rule is expected in late spring 2010.
Relevant Themes: Creates a floor for standards, implementation specifications, and certification criteria for qualified EHR technology. The IRF creates specific standards in 2011 in four areas: vocabulary, content exchange, transporting of information, and, privacy and security.
Notice of Proposed Rulemaking on the Electronic Health Record Incentive Program for Medicare and Medicaid
Status and Size of Regulations: Released as a Notice of Proposed Rule Making for public comment on December 30, 2009. The 556-page document will be posted officially in the Federal Register on January 13, 2010, and includes a 60-day comment period. A final rule is anticipated in time for the start of the eligible hospital incentive program in October 2010.
Relevant Themes: HHS made a critical decision early in the process to align Medicare Fee-for-Service, Medicare Advantage, and Medicaid, where practicable and legally possible. Medicare incentive payments will be released by CMS. Medicaid payments will be released through the states, following approval of the individual state plans. As of December 30, 2009, 13 states have been approved for planning grants, while several others are in the review process with Medicaid. Medicaid providers can receive payments to purchase or upgrade their systems, and some form of incentive is available through Medicaid through 2021.
The Medicare and Medicaid Incentive Payment Programs are designed as a three-stage effort (for more information, see pages 40-43 of the NPRM):
Stage I – Electronic capture of health information in a coded format; tracking key clinical conditions and communicating outcomes for care coordinating; implementing clinical decision support tools to facilitate disease and medication management; and reporting outcomes for public health purposes.
Stage II – Expands on stage I. Encourages the use of health IT to enhance computerized provider order entry; transitions in care; electronic transmission of diagnostic test results; and, research.
Stage III – Expands on stage II. Promotes improvements to quality and safety; focuses on clinical decision support at a national level by encouraging patient access and involvement; and, improved population health data.
Preliminary Review of Key Points:
EHR Incentive Program
Stage 1 Meaningful Use consists of 25 measures; 17 metrics will require attestation by the provider, while eight will require information being submitted by the provider.
Computerized Provider Order Entry (CPOE) required in Stage 1 (10% hospitals; 80% for eligible providers)
Robust clinical quality measures for eligible professionals (EPs) and hospitals are delineated.
Requires patients be provided with an electronic copy of test results, problem lists, medication lists and discharge summary upon request.
Hospitals can participate in both Medicare and Medicaid incentives, if eligible by volume.
Hospitals and EPs must implement five clinical decision support rules relevant to clinical quality metrics.
Hospitals and EPs able to use an attestation methodology to submit summary information to CMS in 2011. Expect a formalized process from HHS by 2012.
Hospitals and EPs have a 90-day minimum reporting period in the first year to qualify as a meaningful user. Subsequent years require full year reporting
Interim Final Rule (IFR) establishing the Initial Set of Standards, Implementation Specifications and Certification Criteria for EHR Technology:
Certification criteria described in the IFR establish the capabilities and standards that certified EHR technology will need to, at a minimum, support the achievement of proposed meaningful use Stage 1 by EPs and hospitals.
In physician practices, key information system applications needed to meet the definition of a qualified EHR are:
Clinical Data Repository – store, retrieve, and manage medications and laboratory and radiology results.
Clinical Documentation – provide appropriate referrals, problem list, current medication list.
Clinical Decision Support – implement drug-drug, drug-allergy, and drug-formulary checks.
CPOE required in the areas of medications, laboratories, radiology/imaging, and provider referrals.
Requires electronic generation and transmission of permissible prescriptions.
Financial Information Systems – ability to check insurance eligibility and submit claims electronically.
Patient Communication – ability to electronically generate reminders, provide test results, problem lists, and immunizations.
In hospitals, the key applications needed to meet the definition of a qualified EHR are:
Clinical Data Repository – store, retrieve, and management laboratory and radiology results.
Clinical Documentation – nursing and physician in the areas of discharge, transfer, care coordination, problem list, demographic capture, vital signs and BMI, smoking status (for patients 13 years and older); calculate and electronically display quality measure results.
CPOE in the areas of medications, laboratories, radiology/imaging, blood bank, physical therapy, occupational therapy, respiratory therapy, rehabilitation therapy, dialysis, provider consults, and discharge/transfer.
Medication administration for alerts at the point-of-care to accomplish real time drug-drug, drug-allergy, and drug-formulary checks, and to maintain an active medication list.
Clinical Decision Support – implement the five automated, clinical rules.
Financial Information Systems – ability to check insurance eligibility and electronically submit claims.
Patient Communication – create an electronic copy of a patient's clinical information upon request. Provide copy of discharge instructions and procedures at time of discharge, upon request.
To learn more, sign up today for the HIMSS webinar series on Meaningful Use and Certification Criteria. And, be sure to visit the HIMSS website for the latest information and analysis.
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