posted by Kevin Heubusch
Feb 11, 2010 12:01 am
AHIMA Meaningful Use White Paper Series
Paper no. 5a
The fourth paper in this series reviewed the EHR certification requirements related to the notice of proposed rulemaking on meaningful use, published by the Centers for Medicare and Medicaid Services on January 13, 2010. This paper offers an overview of the health IT functionality measures for eligible providers. A companion paper (5b) provides an overview of the requirements for hospitals.
Eligible providers (EPs) participating in the meaningful use program will be required to report on quality measures. The measures defined in the proposed regulation were developed to meet the stated objectives in support of the health outcome policy priorities.
The measures are grouped into two categories: HIT functionality measures and clinical quality measures. This paper focuses on the HIT functionality measures, which were developed to demonstrate the use of certified EHR technology in daily work processes.
Measures in Stage 1 are not set at 100 percent. However, most are set at a relatively high threshold to ensure the intent of the objectives and measures are met (e.g., 80 percent), while recognizing that there are technical hindrances and other barriers that may prevent full compliance. For other objectives and measures that depend on health information exchange, the thresholds remain low, since most areas of the country do not have the infrastructure to support this function.
CMS anticipates raising the threshold in subsequent stages as the capabilities of health IT infrastructure increases. It also anticipates redefining the objectives to go beyond capturing data in electronic format to include the exchange of the data in structured formats. The intent of escalating measures “is to ensure that meaningful use encourages patient-centric, interoperable health information exchange across provider organizations regardless of provider’s business affiliation or EHR platform,” CMS writes.
In order to meet the meaningful use objectives, EPs must use these EHR capabilities as part of their daily work processes. Further, CMS intends that EPs use the capability for all patients, not just for Medicare or Medicaid populations.
Hospital-based physicians do not qualify for the program. (However, there is an exception if more than 50 percent of a physician’s total patient encounters in a six-month period occur in a federally qualified health center or rural health clinic.) If EPs practice at multiple locations, the measures are to be limited to actions taken at locations equipped with certified EHR technology.
A practice is eligible if the certified EHR technology is available at the beginning of the EHR reporting period for a given location. CMS realizes that an EP may not have access to certified EHR technology at each location. The intent is to include EPs who are able to meaningfully use certified EHR technology when it is available yet also provide care to patients in other locations where it is not available.
To qualify as a meaningful user, 50 percent or more of an EP’s patient encounters during the EHR reporting period must occur at a location equipped with certified EHR technology. EPs who do not conduct 50 percent of their patient encounters in any one location would have to meet the 50 percent threshold through a combination of locations. CMS recognizes that this does not ensure control; however, it still advances the priorities and provides some level of equity.
Methods of Demonstration
The NPRM proposes that EPs demonstrate they satisfy each of the objectives by providing an attestation through a secure mechanism, such as claims-based reporting or an online portal (p. 1903). Through a one-time attestation following the completion of the EHR reporting period, they would identify the certified EHR technology used and the results of their performance on all the measures associated with the objectives.
CMS expects to move away from demonstration of meaningful use through attestation reporting in later years. It advocates for uniformity and simplicity in this process and suggests that the Medicaid programs follow its lead. CMS will issue further instructions on the specifics for submitting attestations.
The following definitions are helpful in reviewing the objectives, measures, and reporting requirements.
EHR reporting period: the period in which the EP demonstrates meaningful use. In the first payment year (beginning January 1, 2011), this may be any continuous 90-day period. In subsequent years of the program, CMS will require that meaningful use occur throughout the entire year.
Certified EHR technology: “A qualified electronic health record (as defined in section 3000(13) of the PHS Act) that is certified pursuant to section 3001(c)(5) of the PHS Act as meeting standards adopted under section 3004 of the PHS Act that are applicable to the type of record involved (as determined by the Secretary), such as an ambulatory electronic health record for office-based physicians or an inpatient hospital electronic health record for hospitals). In section I.A of this proposed rule, for both Medicare and Medicaid, we discussed incorporating ONC’s definition of certified EHR technology.”
Certified EHR technology (as defined in the technology standards IFR): “a Complete EHR or a combination of EHR Modules, each of which: (1) Meets the requirements included in the definition of a Qualified EHR; and (2) Has been tested and certified in accordance with the certification program established by the National Coordinator as having met all applicable certification criteria adopted by the Secretary.”
Unique patients: a patient may be counted only once during the EHR reporting period, even if seen by the EP multiple times. The meaningful use objective is not necessarily updated every time the patient is seen within the reporting period.
Transition of care: “transfer of a patient from one clinical setting (inpatient, outpatient, physician office, home health, rehab, long-term care facility, etc.) to another or from one EP or eligible hospital (as defined by CCN) to another.”
Relevant encounter: “any encounter that the EP or eligible hospital judges performs a medication reconciliation due to new medication or long gaps in time between patient encounters or other reasons determined by the EP or eligible hospital.”
Mapping Objectives, Measures, and Reporting
The table available in the PDF version of this white paper outlines the criteria, measures, and thresholds for both Medicare and Medicaid as currently described in the NPRM. (The table appears in the PDF version of this paper.) It is expected that there will be considerable comments made during the 60-day public period, and they could result in changes to the program in the final rule.
In reviewing the proposed Stage 1 criteria shown here, EPs may consider how the criteria would be integrated into their practices and how the required measures would be collected and calculated for each EP throughout the organization. EPs that cannot show they met the threshold for meaningful use will not collect the incentives set forth in the NPRM.
Download a PDF version of this paper. For more ARRA resources, visit www.ahima.org/ARRA. [web page no longer available]
The next papers in this series will cover the reporting of clinical quality measures using EHRs.
AHIMA. "Measures Reporting for Eligible Providers." (AHIMA report, February 11, 2010).