We now have our first look at the official shape “meaningful use” of electronic health record (EHR) technology will likely take – in the near future, at least. As many had anticipated, one of the principal underlying themes is interoperability.
The long-anticipated proposed rule defining meaningful use finally was released by the Centers for Medicare and Medicaid Services (CMS) on Dec. 30. On the same day, we also received the interim final rule setting initial EHR technology standards, implementation specifications and certification criteria from the Office of the National Coordinator for Health Information Technology (ONC).
You can view both rules in the Jan. 13, 2010, Federal Register at http://www.access.gpo.gov/su_docs/fedreg/a100113c.html.
As it turns out, CMS will define meaningful use objectives in three distinct stages. Providers who meet the criteria in each of the three stages may be eligible for thousands of dollars in incentive bonuses through the American Recovery and Reinvestment Act (ARRA). In the initial proposal, however, CMS has only defined the requirements for Stage 1, which 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…implementing clinical decision support tools to facilitate disease and medication management; and reporting clinical quality measures and public health information.”
Stage 1 includes many of the recommendations that the HIT Policy Committee made last summer, although with modifications. Among them: use computerized provider order entry (CPOE); implement drug-drug, drug-allergy and drug-formulary checks; maintain up-to-date problem lists; use electronic prescribing; incorporate clinical lab-test results into EHR as structured data; and check insurance eligibility electronically from public and private payers.
Stage 2 criteria, to be proposed by the end of 2011, is expected to expand on Stage 1 criteria to more fully emphasize structured data exchange. Stage 3 will focus on “…decision support for national high priority conditions, patient access to self management tools, access to comprehensive patient data and improving population health.”
Look closely at this proposal. As you read, it becomes clear that interoperability is a major tenant of meaningful use. In fact, I would argue that saying this proposal defines meaningful use of “the EHR” falls short of the whole truth. Be careful not to limit your thinking to “medical record” technology alone. The reality is that the current definition requires interoperability across the entire HIT spectrum. CPOE, e-prescribing, clinical and outcomes data, insurance eligibility. You cannot achieve even these elements – which represent just the tip of the iceberg – unless interoperability is a criterion for every aspect of your HIT.
“‘Meaningful use’ is a term defined by CMS and describes the use of HIT that furthers the goals of information exchange among health care professionals.” That statement, found in the background section of the proposed rule, points to the undeniable standard toward which we are headed. It requires us to move data not only within our own organizations, but among myriad entities and applications.
Does your HIT – across the board – possess the interoperability necessary to meet future requirements? That’s the question we all must examine. Feel free to share your thoughts below.