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One of the issues that federal officials must tackle as they write a rule defining meaningful use of electronic health records is to figure out how to know that a provider organization has achieved meaningful use.

The Centers for Medicare and Medicaid Services is mulling a number of options ranging from self-attestation of providers that they comply with meaningful use requirements, to requiring the reporting of electronic data that demonstrates meaningful use.

The only thing certain now is that in the proposed rule covering meaningful use that is expected in December, CMS won't propose any compliance process that its computer systems can't accept, says Tony Trenkle, director of CMS' office of e-health standards and services.

Trenkle spoke during the Aug. 14 meeting of the HIT Policy Committee, a federal advisory body. Asked about the ability of CMS' systems to accept meaningful use data, Trenkle replied, "Whether we can do it in 2011 or later will be discussed in our proposed rule in December."

CMS wants to harmonize Medicare and Medicaid meaningful use directives that will drive incentive programs for use of EHRs, he added. One idea under consideration is that Medicare's criteria would be a base. In turn, states could raise the criteria for compliance with Medicaid incentive payments. States, however, could not set Medicaid criteria below Medicare's requirements.

--Joseph Goedert