One day before 2009 passed into history, the much anticipated final definition of “meaningful use” was released by CMS and ONC, 556 pages and 136 pages, respectively. The blogosphere experts rushed to summarize the contents, some accurate and some less so, and just like everything that has to do with health care reform, for every rule making there are a dozen new questions being raised by the already thoroughly confused stakeholders at large.
Just so that THCB is not left out, here is a quick qualitative summary of the contents:
1. Data Collection – The following structured data elements will need to be collected by the software: Demographics, Vitals (plus Smoking status), Electronic Lab Results, Problem Lists, Medications and Allergies. The important thing to note here is that the requirement to record Advanced Directives has been dropped in the final ruling.
2. Medical Records for Patients – Providers will need to provide patients with electronic copies of Visit Summaries, Care Summaries, Discharge Summaries and Complete Medical Records upon request. In addition, continuous on-line access to medical records is also to be provided.
3. CPOE – With the exception of Electronic Prescribing, which needs to actually send scripts to pharmacies, all other orders need to be electronically recorded, but not electronically sent. So it’s OK to just print those requisitions.
4. Decision Support – The software needs to perform Drug-Drug, Drug-Allergy and Formulary checks. Reconciliation of medications should be performed upon transition of care. Five guide lines, based on specialty, need to be implemented and the software should provide alerts based on the guide lines selected.
5. Outreach – The software should create lists of patients by health and demographic status and the list should be used to reach out to those patients. Follow-up and other reminders should be similarly handled.
6. Information Exchange – The software should have the ability to exchange clinical data with other EMRs and to report to State and Federal agencies. Only one test per reporting period is required. There is no requirement for an ongoing, working exchange of information. Note that the only operational clinical interfaces required are eRx and Lab results.
7. Quality Reporting – This is very similar to current PQRI reporting requirements.
8. Security – Standard security measures and disclosure management.
9.Administration – The software should perform electronic Eligibility checks and submit Claims electronically.
These are the general requirements for 2011 and the required compliance rates range from 10% to 80% depending on the novelty of the requirement. All these activities need to be reported somehow, which translates into a new and meaningful reporting burden on most software vendors.
Physicians may acquire, or subscribe to, either one comprehensive product that has the ability to satisfy all requirements and is certified as such, or cobble together an array of modular products, each capable of a subset of the required functionality. The provider is responsible for successful integration of such modules.
Certification processes for comprehensive and modular technologies are to be defined at a later date.
The big news here is that the “drop dead” start date for meaningfully using technology has been pushed from January 1st 2011 to October 1st 2011 and it only takes 90 days of reported meaningful use in order to qualify for the full incentive payment in 2011.
The remainder of the CMS document deals mainly with various payment structures under Medicare, Medicare Advantage and Medicaid, and the ONC document is attempting to estimate costs to vendors building and certifying appropriate technologies.
Both documents contain repeated requests for public comments on most rulings in order to clarify feasibility of implementation. It is my impression that both CMS and ONC are genuinely open to listening, considering and implementing guidance from the interested public.
I have no doubt that large vendors, large hospitals, patient groups and the usual experts will indeed provide public comments according to their inclinations and business interests. However, what is really needed is a critical mass of comments from practicing physicians who are usually “too busy seeing patients”.
Of course having all doctors engaged in reading almost 700 pages of rule making is not very likely, and the language in many places is rather tedious.
This is probably our last opportunity to actively engage grass roots physicians in the creation of a roadmap for Health Care Information Technology. Failure to do so will dramatically slow down the adoption rates and force us through a myriad of detours through tried and failed approaches.
Therefore, this is a call to ONC and Dr. Blumenthal to waste no time in disseminating the information contained in the meaningful use final rulings throughout the physician community. These documents need to be distilled and presented through various physician associations, regional hospitals, webcasts, conference calls, email campaigns and any other public education means available. Clear and simple instructions on how to provide public comments should be included and a prompt announcement that such effort is underway would help set expectations.
Lastly, this is a call to all practicing physicians to engage in the process, to take the time to understand the meaningful use final ruling and to provide the guidance requested by CMS and ONC. Regardless of personal preferences, the move to Electronic Medical Records is all but inevitable now. Earnest participation in shaping the future of Clinical Information Technology will go a long way towards making the transformation less painful for each and single doctor who is currently busy seeing patients.
ONC IFR (PDF) http://tinyurl.com/ya7bn2k
CMS NPRM (PDF) http://tinyurl.com/yb62fcr
More information available at http://healthit.hhs.gov
Margalit Gur-Arie blogs frequently at her website, On Healthcare Technology. She was COO at GenesysMD (Purkinje), an HIT company focusing on web based EHR/PMS and billing services for physicians. Prior to GenesysMD, Margalit was Director of Product Management at Essence/Purkinje and HIT Consultant for SSM Healthcare, a large non-profit hospital organization.