Fed Advisors: Change MU Criteria

The HIT Policy Committee, which advises federal officials, has approved recommendations from a workgroup to scale back some proposed criteria to demonstrate meaningful use of electronic health records to receive Medicare and Medicaid incentive payments.

The action is important because the committee of industry stakeholders advises federal officials who now are receiving comment on the proposed meaningful use rule as they consider changes for a final rule expected during the first half of 2010.

The HIT Policy Committee's meaningful use workgroup recommended a measure of flexibility as an alternative to the "all or nothing" nature of the proposed rule, which required providers to comply in full with a wide range of criteria to demonstrate meaningful use of EHRs.

The meaningful use workgroup presented its recommendations to the full committee on Feb. 17. Providers working in good faith to comply with the meaningful use rule should not be denied incentive payments if they fall short of fully meeting all criteria, said Paul Tang, M.D., vice chair of the committee and co-chair of the meaningful use workgroup. He's also CIO at Palo Alto Medical Foundation in Mountain View, Calif.

Under the workgroup recommendations, eligible professionals and hospitals could defer--from Stage 1 starting in 2011 to Stage 2 starting in 2013--compliance with up to six meaningful use criteria in specific priority areas. The full committee changed the number to up to five deferred criteria.

Under the priority area "Improving quality, safety, efficiency and reducing health disparities," the workgroup recommended mandatory compliance with four criteria. The full committee stripped out one mandatory criterion--reporting quality measures to CMS or states--as this is required under existing law. The remaining three mandatory criteria are recording demographics as structured data, using CPOE for orders directly entered by the authorizing provider, and generating and transmitting permissible prescriptions electronically. Of the remaining criteria in this priority area, three could be deferred.

Under the priority area "Engage patients and families in their health care," the requirement to provide discharged patients with an electronic copy of their instructions and procedures would be mandatory. The workgroup recommended one remaining criteria could be deferred, but the full committee decided on no deferrals.

Under the priority area "Improve care coordination," the workgroup recommended testing of the EHR's capacity to electronically exchange key clinical information as mandatory criteria, with one remaining criteria deferrable. The full committee deleted the mandatory criteria and let stand one criteria that can be deferred.

Under the priority area "Improve population and public health," the committee concurred with the recommendation that no criteria are mandatory and one criteria can be deferred.

No deferrals would be permitted for criteria under the priority area "Ensure adequate privacy and security protections for personal health information."

The HIT Policy Committee also adopted 11 additional workgroup recommendations, several of which reinstated previous committee recommendations that were not included in the proposed meaningful use rule. The adopted workgroup recommendations are:

* Reinstate a previous policy committee recommendation to include progress note documentation in Stage 1 meaningful use criteria.
* Remove core measures (tobacco use screening, blood pressure measurement and drugs to be avoided in the elderly) from Stage 1 criteria, as they do not meet certain criteria for inclusion.
* Reinstate a committee recommendation to stratify quality reports by disparity variables.
* Providers should maintain not just lists, but "up-to-date" lists of problems, medications and allergies.
* Reinstate a committee recommendation to include recording of advanced directives in Stage 1 criteria.
* Reinstate with amendment a committee recommendation to report the percentage of patients for whom providers use the EHR to suggest patient-specific education resources.
* Reinstate a committee recommendation that all eligible providers should report to CMS the percentage of all medication, ordered into the EHR, as a generic formulation, when generic options exist in the relevant drug class. CMS also should explicitly require that at least one of the five clinical decision support rules address efficient diagnostic test ordering.
* CMS should advance its timetable for the release of future meaningful use proposed rules to allow adequate ramp-up time for vendors and providers.
* CPOE should be done by the authorizing provider.
* Change the preventive/follow up reminders criteria to read: "For a chosen preventive health service or follow up (the eligible professional chooses a relevant preventive or follow up service for their specialty), report on the percent of patients who were eligible for that service who were reminded."
* Under the Improve Care Coordination category, define "transition of care" to be "the movement of a patient from one setting of care (hospital, ambulatory primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another." Delete the term "relevant encounter" from the medication reconciliation measure.

The recommendations, before amendments, are available at http://healthit.hhs.gov/portal/server.pt. Click on Federal Advisory Committees, HIT Policy Committee, Meetings and NPRM Recommendations.

--Joseph Goedert

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