Defining “Meaningful Use” Under the HITECH Act
May 20, 2009
The Facts
The Health Information Technology for Economic and Clinical Health (HITECH) Act, part of the American Recovery and Reinvestment Act of 2009, includes Medicare incentives for adoption and meaningful use of certified electronic health record (EHR) technology. To be eligible for incentive payments, hospitals and physicians must use EHRs in a meaningful manner, exchange electronic health information to improve the quality of care, and report on clinical quality and other measures. Additional guidance regarding these parameters is expected from the U.S. Department of Health and Human Services through the regulatory process. The Health Information and Management Systems Society has published recommendations regarding the definition of “meaningful use”:
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Recognize Certification Commission for Healthcare Information Technology (CCHIT) as the certifying body of EHRs.
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Adopt metrics that can be reasonably captured and reported beginning in 2011. These metrics should then become increasingly stringent every two or more years to achieve incremental maturation of “meaningful use.”
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Coordinate with Health Information Technology Standards Panel and Integrating the Healthcare Enterprise to publish implementation guides and standards for output of EHR data to bridge existing gaps in interoperability of health information.
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Collaborate with CCHIT to fairly evaluate hospitals and physicians that use “best of breed” systems from multiple vendors or open source technologies.
What’s at Stake
Hospitals and physicians that meet the requirements of “meaningful use” of certified EHRs will be eligible for Medicare incentive payments beginning in 2011. Medicare payments may be reduced to hospitals and physicians that do not meet the requirements for “meaningful use” of certified EHRs by 2015.
What You Should Do
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If your organization is considering acquiring an EHR system, seek counsel on the legal requirements of “meaningful use” (including interoperability) and anticipate the timeframe for your organization to meet these requirements before the eligibility dates.
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Obtain a contractual commitment from the vendor that the system will permit usage in accordance with the federal definition of “meaningful use.”
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Conduct due diligence on and obtain contractual commitments from your vendor to make sure it is certified and can meet the requirements of certification panels.
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When selecting an EHR system, obtain stakeholder endorsements to support system success.
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Featured Commentary
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This article features guest commentary from Susan Reynolds, M.D., Ph.D., president and CEO of the Institute for Medical Leadership, and Jay Volk, president of Workflow.com. The concept of interoperability is part of the definition of “meaningful use.” Therefore, many hospitals and physicians that want to position themselves for the Medicare incentives are asking whether EHR systems will “talk” to each other, i.e., what standards will be set by the administration so that these information systems are easily integrated, and when those standards will be set. The administration should carefully consider its ultimate goals when developing the standard for “meaningful use.” If the administration’s goal is to get technology in the hands of doctors, it should consider writing rules that define meaningful use very liberally. If the goal of the administration is return on investment, it should consider writing rules that define meaningful use with measurable goals. A liberal standard may mean more practitioners buying, but not ultimately using EHRs as effectively as they could be used. A stricter standard may mean fewer practitioners purchasing EHRs, but those practitioners will make the commitment to use them and likely see the metric benefits of EHR use. Of course, the devil in the details of “meaningful use” is usability. Vendors will need to respond to the new federal regulations to make their systems user-friendly for physicians and hospitals. Susan Reynolds, M.D., Ph.D., can be contacted at sreynolds@medleadership.com |
