The proposed definition of "meaningful use" will result in the fulfillment of the policy priority of "improving quality, safety, efficiency and reducing health disparities." The proposed definition will also meet the five care goals of the HIT Policy Committee. The objectives in the Stage I criteria of meaningful use are reasonable and appropriate and should not represent a significant challenge for users of Certified EHRs. Southeast Texas Medical Associates is performing all of the measures of Stage I, II and III.
Even though there is a great deal of overlap in national quality measures, the Physician Quality Reporting Initiative and National Quality Forum clinical quality measure sets are too robust for a beginning effort. The extensive quality measure tracking and reporting requirements will result in many excellent groups either not participating, or not succeeding in their participation in the CMS program. A more circumscribed measurement group would be appropriate with gradual increasing of the breath of the requirement.
Caution must be used in the requirement for being able to report patient information electronically between practices, some with different EHRs and some without EHR capability. This interoperability is in development. The rules for participation in the CMS HIT incentive program must not discourage participation, but encourage it.
The promise of EHR and actually of "electronic patient management," is within our reach. The meaningful use requirement is a step in the right direction; it must proceed steadily but not so rapidly as to discourage participation.
James L. Holly, MD
Southeast Texas Medical Associates
Chief Information Officer
Hospitals may participate in both the Medicaid and Medicare programs if they qualify for each. In addition, those hospitals participating in both will not have to meet additional state (Medicaid) meaningful use measures if they meet Medicare's. Physicians, on the other hand, cannot participate in both, and instead would have a onetime option of switching from one program to another. At the very least, these disparities will cause confusion.
CMS did modify some of the objectives recommended by ONC's Policy Committee. Most notably, CMS rejected recording advanced directives. They also rejected the suggestion that providers report quality improvement and public reporting to patient registries.
CMS has chosen a three-stage approach: Stage I (2011-2012) emphasizing "electronically capturing health information in a coded format; using that information to track key clinical conditions and communicating that information for care coordination purposes"; Stage II (2013-2014) encouraging "the use of health IT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible"; Stage III (2015) on "promoting improvements in quality, safety and efficiency, focusing on decision support for national high priority conditions, patient access to self management tools, access to comprehensive patient data and improving population health." Using this staged approach, CMS is proposing a flexible system that allows hospitals and physicians to start adopting over time, where those starting in later years would have to accelerate through the stages to catch up with earlier adopters in order to collect incentives. It's hard to know at this juncture how providers will navigate the many different potential paths to qualifying for incentives or which paths are the most efficient and effective.
Bruce Taffel, MD
Chief Medical Officer