When was the final rule on meaningful use released? ONC announced the final rule on July 8, 2010. The rule was released on July 13, 2010.

For purposes of participating in the Medicare and Medicaid Electronic Health Record Incentive Program, who are EPs (eligible providers)?

Medicare Fee For Service are considered eligible providers and include:

• Doctor of Medicine or Osteopathy
• Doctor of Dental Surgery or Dental Medicine
• Doctor of Podiatric Medicine
• Doctor of Optometry
• Chiropractor
• Acute Care Hospitals (Subsection (d) hospitals that are paid under PPS and located in the 50 states and the District of Columbia, and
• Critical Access Hospitals (CAHs)
  

Medicaid Eligible Provider Includes:

• Physicians
• Nurse Practitioner (NPs)
• Dentists
• Physician Assistants (PSs) working in a Federally Qualified Health Center (FHCQ) or rural health clinic (RHC) that is so lead by a PA
• Acute Care Hospitals (including CAHs), and
• Children's Hospitals

Medicare Advantage Eligible Providers:

• Must furnish on average, at least 20 hours/week of patient-care services and be employed by the qualifying MA organization, or
• Must be employed by or be a partner of, an entity that through contract with the qualifying MA organizations furnishes at least 80% of the entity's Medicare patient care services to enrollees of the qualifying MA organization
• Medicare Advantage Affiliated Eligible Hospitals

Under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program, who is responsible for demonstrating meaningful use of certified EHR technology, the provider or the vendor? To receive an EHR incentive payment, the EP, eligible hospital or critical access hospital (CAH) is responsible for demonstrating meaningful use of certified EHR technology under both the Medicare and Medicaid EHR incentive programs.

To qualify for incentive payments, what are the ways the meaningful use may be met?

• Medicare EHR incentive program - Eligible professionals and hospitals must successfully demonstrate meaningful use of certified electronic health record technology every year they participate in the program.
• Medicaid EHR incentive program - Eligible professionals and hospitals may qualify for incentive payments for the adoption, implementation, upgrade or the demonstration of meaningful use in their first year of participation. They must successfully demonstrate meaningful use for the remaining years they participate in the program. This option is not available for Medicare EHR program.

What does the adopt/implement/upgrade mean and what is the reporting period requirement?

• Adopted - Acquired and installed; for example, Evidence of installation prior to incentive.
• Implemented - Commenced Utilization of; example, Staff training, data entry of patient demographic information into EHR.
• Upgrade - Expanded; example, upgrade to certified EHR technology or added new functionality to meet the definition of certified EHR technology.
• There is no reporting period requirement. Providers could install on day one and attest to the A/I/U the following day.

What are the three main criteria of meaningful use?

• The use of a certified EHR in a meaningful manner (e.g.: e-Prescribing);
• The use of certified EHR technology for electronic exchange of health information to improve quality of health care; and
• The use of certified EHR technology to submit clinical quality and other measures

What are the changes between the proposed changes and the final rule?

Notice of Proposed Rule Making	Final Rule
Meet all MU reporting objectives (all or nothing)	Must meet core set/can defer 5 optional menu set (flexibility)
25 measures for EPs/23 measures for eligible hospitals	25 measures for EPs/24 for eligible hospitals
Measure thresholds range from 10% to 80% of patients or orders (most at higher range)	Measure thresholds range from 10% to 80% of patients or orders (most at lower to middle range)
Denominators - To calculate the threshold, some measures required manual chart review	Denominators - No measures require manual chart review to calculate threshold
Administrative transactions (claims and eligibility) included	Administrative transactions removed
Measures for Patient-Specific Education Resources and Advanced Directives discussed but not proposed	Measures for Patient-Specific Education Resources and Advanced Directives (for hospitals) included
States could propose requirements above/beyond MU floor, but not with additional EHR functionality	States' flexibility with Stage 1 MU is limited to seeking CMS approval to require 4 public health-related objectives to be core instead of menu
Core clinical quality measures (CQM) and specialty measure groups for EPs	Modified Core CQM and removed specialty measure groups for EPs
90 CQM total for EPs	44 CQM total for EPs - must report total of 6
CQM not all electronically specified at time of NPRM	All final CQM have electronic specifications at time of final rule publication
CQM total for eligible hospitals and 8 alternate Medicaid CQM	15 CQM total for eligible hospitals
5 CQM overlap with CHIPRA initial core set	4 CQM overlap with CHIPRA initial core set

What are meaningful use core set objectives for EPs?

1. Computerized physician order entry (CPOE)
2. E-Prescribing (eRx)
3. Report ambulatory clinical quality measures to CMS/States
4. Implement one clinical decision support rule
5. Provide patients with an electronic copy of their health information, upon request
6. Provide clinical summaries for patients for each office visit
7. Drug-drug and drug-allergy interaction checks
8. Record demographics
9. Maintain an up-to-date problem list of current and active diagnose
10. Maintain active medication list
11. Maintain active medication allergy list
12. Record and chart changes in vital signs
13. Record smoking status for patients 13 years or older
14. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically
15. Protect electronic health information

What are meaningful use core set objectives for Eligible Hospitals?

1. CPOE
2. Drug-drug and drug-allergy interaction checks
3. Record demographics
4. Implement one clinical decision support rule
5. Maintain up-to-date problem list of current and active diagnoses
6. Maintain active medication list
7. Maintain active medication allergy list
8. Record and chart changes in vital signs
9. Record smoking status for patients 13 years or older
10. Report hospital clinical quality measures to CMS or States
11. Provide patients with an electronic copy of their health information, upon request
12. Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request
13. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically
14. Protect electronic health information

What are the meaningful use menu set objectives for eligible professionals?

1. Drug formulary checks
2. Incorporate clinical lab test results as structured data
3. Generate lists of patients by specific conditions
4. Send reminders to patients per patient preference for preventive/follow up care
5. Provide patients with timely electronic access to their health information
6. Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate
7. Medication reconciliation
8. Summary of care record for each transition of care/referrals
9. Capability to submit electronic data to immunization registries/systems*
10. Capability to provide electronic syndromic surveillance data to public health agencies*

*At least 1 public health objective must be selected

What are the meaningful use menu set objectives for eligible hospitals?

1. Drug formulary checks
2. Record advanced directives for patients 65 years or older
3. Incorporate clinical lab test results as structured data
4. Generate lists of patients by specific conditions
5. Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate
6. Medication reconciliation
7. Summary of care record for each transition of care/referrals
8. Capability to submit electronic data to immunization registries/systems*
9. Capability to provide electronic submission of reportable lab results to public health agencies*
10. Capability to provide electronic syndromic surveillance data to public health agencies*

*At least 1 public health objective must be selected

What does a provider do if some of the meaningful use objectives are not applicable to their practice? Some meaningful use objectives are not applicable to every provider's clinical practice, thus they would not have any eligible patients or actions to report. Exclusions do not count against the five deferred measures. In these cases, the EP, eligible hospital or CAH would be excluded from having to meet that measure.