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Meaningful Use: A Moving But Attainable Target
On December 30, 2009, the Centers for Medicare and Medicaid Services (CMS) published their Notice of Proposed Rulemaking (NPRM), identifying the standards and specifications for implementation and criteria for “meaningful use” of an EMR. Since this date, there has been much discussion about how doctors will achieve this goal.
The latest definition of meaningful use of an EMR involves three stages that reflect an anticipation of increasing sophistication of EMR usage within the next 3 years. Currently, there are 25 defined criteria for stage 1 of the plan for meaningful use, which will need to be demonstrated in 2011. During this stage, physicians can report many of these criteria via attestation. Stages 2 and 3 will expand on these criteria over the following 2 years, giving doctors an opportunity to ease into the full reporting process, which could require computerized submission as early as 2012.
| Stage 1 | Providers must meet 25 objectives for EMR usage determined by the Centers for Medicare and Medicaid Services (CMS). |
| Evidence for meeting the 25 objectives must be provided to CMS in 2011 via attestation and clinical reporting. | |
| Stage 2 | Proposal to expand the 25 objectives of Stage 1 to include: Disease management, clinical decision support, medication management, patient access to their health information, transitions in care, quality measurement, and research and bi-directional communication with public health agencies. |
| Stage 3 | Further expand the criteria for meaningful use elaborated in Stages 1 and 2. |
For 60 days following the NPRM release, physicians were invited to comment on the proposal, which resulted in more than 800 remarks. Many doctors are concerned that the requirements for meaningful use are too rigid, and will hinder their ability to receive the ARRA incentives. Over the coming weeks and months, it is very likely that we will see further refining of the criteria as a result.
While the criteria and percentage of compliance may be changing continually, the basic goal of computerizing records is constant. The essential component of meaningful use is simply the ability to access and report on medical data for the betterment of healthcare overall. The three part preliminary definition of meaningful use has remained the same, with the 25 proposed criteria serving as a more defined guideline:
- e-Prescribing
- Electronically exchange information
- Submission of clinical quality data and statistics
If the incentives are not enough to spur doctors toward implementation of an EMR, Medicaid and Medicare have gone further to add penalties for those practitioners who choose not to move toward meaningful use of an EMR. Starting in 2015, those practitioners who choose to not participate will receive a 1% reduction in their Medicare allowed charges, and that reduction will increase by 1% each year up to a maximum of 5%.
In short, physicians have every reason to implement EMRs, and achieving meaningful use should be well within reach provided implementation is done in a well thought out and complete manner. Meaningful use of an EMR is just that. It requires more than a simple monetary investment in software. With the proper tools, and more importantly the proper training, complying with meaningful use criteria should prove an attainable task.
Sources: Centers for Medicare & Medicaid Services (CMS), Health Information Technology for Economic and Clinical Health (HITECH)
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