AHIMA Meaningful Use White Paper Series
Paper no. 9

Preceding papers in this series have reviewed the requirements in the notice of proposed rulemaking on meaningful use, published by the Centers for Medicare and Medicaid Services in January 2010. The eighth paper offered an overview of AHIMA’s comments on the proposal. This ninth and final paper highlights AHIMA’s comments on the related interim final rule on standards for certification, including the accounting of disclosure standard.

In order to be eligible for the meaningful use incentive program, healthcare providers must use EHR technology that meets certification standards set by the federal government. On January 13 the Office of the National Coordinator for Health IT (ONC) published an interim final rule for these standards, which became effective February 12. However, the rule is not final, and the comments that ONC receives until March 15 could affect the content of the eventual final rule.

AHIMA’s comments on the IFR were prepared by members and staff. AHIMA has been involved in both the creation of standards through active participation in standards bodies such as Health Level Seven International (HL7) and as a founder of the Certification Commission on Health Information Technology (CCHIT). (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 8

Preceding papers in this series have reviewed the requirements in the notice of proposed rulemaking on meaningful use, published by the Centers for Medicare and Medicaid Services in January 2010. This paper highlights AHIMA’s comments on the NPRM and links to the full document.

[Updated March 12 with link to a copy of AHIMA's final, submitted comments]

The Centers for Medicare and Medicaid Services (CMS) released its proposal for the meaningful use program as a notice of proposed rulemaking (NPRM) in part to solicit comment on the details of this complex initiative prior to proceeding with the rulemaking process. Comments are due March 15.

CMS intends to post the final rule in late spring or early summer. The number and variety of comments it receives will affect the final rule’s timeliness as well as its content.

AHIMA’s comments on the NPRM were prepared by its members and staff, who reviewed and analyzed not only the NPRM itself, but all related activity beginning with initial testimony taken at the National Committee on Vital and Health Statistics hearings in April 2009 through the recommendations of the Health IT Policy and Standards Committees and CMS’s own comments within the NPRM. (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 7

Preceding papers in this series have reviewed the requirements in the notice of proposed rulemaking on meaningful use, published by the Centers for Medicare and Medicaid Services in January 2010. This paper summarizes the proposed process for qualifying for the program and also offers a look at the program’s next steps.

CMS published its program requirements as a notice of proposed rulemaking (NPRM) in order to solicit public comment. That comment period closes March 15. CMS will then proceed to write a final rule with the assistance of the Office of the National Coordinator for Health Information Technology (ONC). The rule will then be reviewed by the Office of Management and Budget before its official publication in the Federal Register.

CMS is targeting late spring or early summer for publication. The number and variety of comments will affect the timeliness as well as the content. For the most part, it should be presumed that the proposed requirements will not be significantly increased in a final rule. The debate over the NPRM has been whether there are too many reporting requirements, and indeed CMS has requested comment to this effect, and the best that can be predicted is that some requirements will be eliminated in the final rule. (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 6b

Papers 5a and 5b in this series reviewed the functionality measures for providers and hospitals described in 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 requirements for reporting clinical quality measures for eligible hospitals. A companion paper (6a) provides an overview of the requirements for providers.

When Congress developed the meaningful use EHR incentive program, one of its goals was to improve the quality and efficiency of care for the Medicare and Medicaid populations. Accordingly, hospitals and providers that participate in the program will be required to capture and report clinical quality measures using certified EHR technology, in addition to the functionality measures they must report to prove they are using EHR technology in a meaningful way.

For purposes of the incentive program, CMS defines clinical quality measures as the “processes, experience, and/or outcomes of patient care, observations or treatment that relate to one or more quality aims for health care such as effective, safe, efficient, patient-centered, equitable, and timely care” (p. 1871). (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 6a

Papers 5a and 5b in this series reviewed the functionality measures for providers and hospitals described in 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 requirements for reporting clinical quality measures for eligible providers. A companion paper (6b) provides an overview of the requirements for hospitals.

When Congress developed the meaningful use EHR incentive program, one of its goals was to improve the quality and efficiency of care for the Medicare and Medicaid populations. Accordingly, hospitals and providers that participate in the program will be required to capture and report clinical quality measures using certified EHR technology, in addition to the functionality measures they must report to prove they are using EHR technology in a meaningful way.

For purposes of the incentive program, CMS defines clinical quality measures as the “processes, experience, and/or outcomes of patient care, observations or treatment that relate to one or more quality aims for health care such as effective, safe, efficient, patient-centered, equitable, and timely care” (p. 1871). (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 5b

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 hospitals. A companion paper (5a) provides an overview of the requirements for providers.

Hospitals that intend to qualify early for the meaningful use EHR incentive program can first apply in the federal fiscal year 2011, which begins October 1, 2010, less than a year after the rules were first published. The qualification period in the first year is only 90 days.

While this is a short period, hospitals seeking to qualify should be determining their current capabilities to qualify and what related functionalities will be available from existing vendors in products to be offered or upgraded in the next year.

Criteria and Objectives

To qualify as a meaningful user an eligible hospital must demonstrate that it meets all of the objectives and their associated measures (p. 1854). Except as otherwise indicated, each objective must be satisfied by an individual hospital as determined by unique CMS certification numbers. Within the NPRM CMS asks for public comment on whether hospitals might have difficulty meeting the proposed objectives. (more…)

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.

Eligibility

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. (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 4

Preceding papers in this series have reviewed requirements within the notice of proposed rulemaking on meaningful use, published by the Centers for Medicare and Medicaid Services on January 13, 2010. This fourth paper takes a look at a companion rule on EHR certification.

Providers and hospitals that wish to participate in the meaningful use incentive program must use EHR technology that meets federal requirements. Commonly referred to as certification criteria or certification standards, these requirements were officially published January 13, 2010, and become effective February 12. With the publication of the criteria, healthcare providers and vendors can begin to assess and align their systems accordingly.

The Office of the National Coordinator for Health Information Technology, or ONC, released the criteria in an interim final rule titled “Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.” Given how closely the criteria are tied to the meaningful use program, the IFR’s publication was concurrent with the notice of proposed rulemaking on meaningful use that came from the Centers for Medicare and Medicaid Services.

Although the IFR is effective February 12, ONC will accept comments on it until March 13. There is potential for the rule to be changed before a final rule is published. (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 3

The second paper in this series began an overview of the provider requirements within the notice of proposed rulemaking on meaningful use, published by the Centers for Medicare and Medicaid Services on January 13, 2010. This paper continues that overview with a look at the proposed payment methods and program requirements.

After describing the criteria for the meaningful use of EHRs, the NPRM addresses the incentive payments themselves, broken down among the Medicare Fee for Service (FFS), Medicare Advantage (MA), and Medicaid programs.

FFS Payments to Providers

CMS takes the definition of physician to mean one of five types of professionals: a doctor of medicine or osteopathy, a doctor of dental surgery or dental medicine, a doctor of podiatric medicine, a doctor of optometry, or a chiropractor. Hospital-based physicians do not qualify for an incentive payment (pp. 1904–7). (more…)

AHIMA Meaningful Use White Paper Series
Paper no. 2

The first paper in the series offered a general overview of the notice of proposed rulemaking on meaningful use, published by the Centers for Medicare and Medicaid Services on January 13, 2010. This paper begins a more detailed, two-part review of the proposed rule.

The meaningful use program established by ARRA is initially an incentive program, not an entitlement program. No healthcare organization—provider or hospital—is required to apply for or participate in the program for the first five years.

To receive incentive payments an entity or provider must participate in Medicare Fee-for-Service, Medicare Advantage, or a state Medicaid program, with some restrictions. Beginning in 2016, however, the program becomes punitive. ARRA established that providers in Medicare programs will be penalized if they do not meet the meaningful use requirements. (more…)