Next Steps: Making EHR Meaningful Use a Reality
Right now there are hundreds, even thousands, of Greenway customers using a certified electronic health record (EHRs) with the functionality and product strategy capabilities to meet the objectives and requirements of the EHR Meaningful Use Final Rule released July 13.
Now armed with a definitive checklist of the requirements, eligible professionals (EPs) in ambulatory settings and those within eligible hospitals can evaluate automation needs and address patient demographics and population to determine whether the Medicare incentive pathway offering up to $44,000 per provider, or the Medicaid pathway offering up to $63,750 per provider, is the optimal choice.
Even for providers already accomplishing integrated, automated workflows and of course for those considering their implementation choices – and there is time to do so – and given the nearly 1,100 pages of regulation, there are some important fundamentals to understand that speak to timeframes, EHR reporting requirements and certification toward making EHR/EMR Meaningful Use a reality.
Foremost to keep in mind is that as of January 1, 2011, organizations seeking the EHR adoption incentives must register with the Centers for Medicare and Medicaid Services (CMS) for either pathway.
Also keep in mind that:
The Final Rule is comprised of two documents. The 864-page CMS rule speaks to the automated functions and in some cases thresholds EPs and eligible hospitals must meet, while the more than 228-page rule by the Office of the National Coordinator for Health Information Technology (ONC) addresses the companion functionality EHRs must meet and enable.
The rules largely speak to EHR Meaningful Use Stage One requirements, which are the reporting standards for 2011 and 2012. But, at the same time, EHR Meaningful Use Stage Two is also addressed. The core set of 15 requirements speak to Stage One. The menu set of 10 requirements allow providers to select five for Stage One, and then defer five to Stage Two. That way EPs and hospitals can begin to establish attainable Stage Two requirements based on patient and clinical needs.
In regards to the scaling up of functionality stages – and up to possibly five are planned over time – and therefore the sophistication of EHRs that translate into enhanced patient outcomes and population health, there does still need to be legislative and regulatory attention to the timeframes between stages and the ability for EPs and hospitals to adjust, concerns that organizations like the Electronic Health Record Association will be addressing.
But let’s not get too far ahead of ourselves.
What’s also important right now is to also keep in mind that both the Medicare and the Medicaid pathways require just a 90-day continuous reporting period within the first calendar year of EHR/ EMR Meaningful Use incentive capture to attain that year’s maximum incentive.
That means equipped EPs or those seeking implementation in the ambulatory care setting can begin as of January 1, 2011 and receive incentives payments as early as May of 2011. Or those needing more time to implement can begin as late as October, 2011 and still receive the maximum first-year incentive.
In terms of EHR certification – and EHRs must be certified by ONC Authorized Testing & Certification Bodies (ONC-ATCBs) for providers using them to qualify for Meaningful Use – ONC began the process of identifying certification bodies on July 1, knowing that entities must be approved and test scripts finalized and then of course EHRs certified in time.
Do not be shy about pressing your EHR solution provider to address the core and menu sets of requirements, and to detail their current certification level and plans to address Meaningful Use certification.
During the release of the Final Rule, officials from the federal Department of Health and Human Services (HHS) also noted the intent to construct an EHR implementation surveillance structure to also gauge the timing and success of implementation if any adjustments are needed to the Meaningful Use Rule in the future.
Additionally HHS took steps on July 8 to fortify the security and privacy of patient records, another high-profile step to empower and bring patients into the process.
Taken as a whole, and with regards to the balance between the importance of EHR adoption and the presenting of attainable Stage One goals that ONC and CMS clearly understood following some 2000 public comments that greeted the original proposals, the foundations and even the cornerstones are in place to make EHR Meaningful Use a reality for providers and patients nationwide.






Vice President of Human Resources
Chief Medical Officer