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HHS yesterday issued two sets of long-awaited and much-anticipated federal regulations:
- List of "meaningful use" criteria that healthcare providers must meet to qualify for federal IT subsidies based on how they use their electronic health records.
- The standards and certification criteria that those EHRs must meet for their users to collect the money.
Phased Approach to Meaningful Use
What has been proposed is a phased approach that encompasses reasonable criteria for meaningful use based on currently available technology capabilities and provider practice experience, and builds up to a more robust definition of meaningful use, based on anticipated technology and capabilities development.
Under this phased approach to meaningful use, the criteria of meaningful use would get updated through future rulemaking. The initial meaningful use criteria have been referred to as "Stage 1."
(Stage 2 criteria are expected to be proposed by the end of 2011 and the Stage 3 definition may be proposed by the end of 2013.)
Stage 1 Meaningful Use Criteria
The Stage 1 meaningful use criteria focuses on electronically capturing health information in a coded format; using that information to track key clinical conditions and communicating that information for care coordination purposes (whether that information is structured or unstructured, but in structured format whenever feasible); consistent with other provisions of Medicare and Medicaid law, implementing clinical decision support tools to facilitate disease and medication management; and reporting clinical quality measures and public health information.
Stage 2 and Stage 3 Meaningful Use Criteria
Stage 2 meaningful use criteria shall expand upon the Stage 1 criteria to encourage the use of health IT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible, such as the electronic transmission of orders entered using computerized provider order entry (CPOE) and the electronic transmission of diagnostic test results (such as blood tests, microbiology, urinalysis, pathology tests, radiology, cardiac imaging, nuclear medicine tests, pulmonary function tests and other such data needed to diagnose and treat disease).
Stage 3 meaningful use criteria shall focus on promoting improvements in quality, safety and efficiency, focusing on decision support for national high priority conditions, patient access to self management tools, access to comprehensive patient data and improving population health.
Stage 1 Meaningful Use Defined in Detail
Goal 1: To further the care goal of improving quality, safety, efficiency and reducing health disparities.
- Use CPOE (which entails the provider's use of computer assistance to directly enter medical orders (for example, medications, consultations with other providers, laboratory services, imaging studies, and other auxiliary services) from a computer or mobile device. The order is also documented or captured in a digital, structured, and computable format for use in improving safety and organization. For Stage 1 criteria, it will not include the electronic transmittal of that order to the pharmacy, laboratory, or diagnostic imaging center)
- Implement drug-drug, drug-allergy, drug-formulary checks.
- Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®. It also includes past diagnoses relevant to the current care of the patient.
- Generate and transmit permissible prescriptions electronically (eRx).
- Maintain active medication list.
- Maintain active medication allergy list.
- Record the following demographics: preferred language, insurance type, gender, race and ethnicity, and date of birth.
- Record and chart changes in the following vital signs: height, weight and blood pressure and calculate and display body mass index (BMI) for ages 2 and over; plot and display growth charts for children 2 - 20 years, including BMI.
- Record smoking status for patients 13 years old or older.
- Incorporate clinical lab-test results into EHR as structured data.
- Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach.
- Report ambulatory quality measures to CMS (or, for EPs seeking the Medicaid incentive payment, the States).
- Send reminders to patients per patient preference for preventive/follow-up care. Patient preference refers to the patient's choice of delivery method between internet based delivery or delivery not requiring internet access.
- Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules.
- Check insurance eligibility electronically from public and private payers.
- 16. Submit claims electronically to public and private payers.
Goal 2: Provide patients and families with timely access to data, knowledge, and tools to make informed decisions and to manage their health
- Provide patients with an electronic copy of their health information (including diagnostics test results, problem list, medication lists, allergies) upon request. Electronic copies may be provided through a number of secure electronic methods (for example, personal health record (PHR), patient portal, CD, USB drive).
- Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies) within 96 hours of the information being available to the EP. Electronic access may be provided by a number of secure electronic methods (for example, PHR, patient portal, CD, USB drive). Timely is defined as within 96 hours of the information being available to the EP either through the receipt of final lab results or a patient interaction that updates the EP's knowledge of the patient's health.
- Provide clinical summaries for patients for each office visit.
Goal 3: To improve care coordination by enabling exchange of meaningful clinical information among professional health care team.
- Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
- Perform medication reconciliation at relevant encounters and each transition of care.
- Provide summary care record for each transition of care or referral.
Goal 4: To improve population and public health by having the patient's health care team communicate with public health agencies.
- Capability to submit electronic data to immunization registries and actual submission where possible and accepted.
- Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
Goal 5: To ensure adequate privacy and security protections for confidential information through operating policies, procedures, and technologies and compliance with applicable law and provide transparency of data sharing to patient.
- Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities.
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