In mid-November, I was interviewing provider organizations about their plans to register and apply for electronic health records meaningful use incentive payments. Six weeks before the incentive program becomes real, it was stunning how little folks know about how the program will work and how little guidance they are getting from the federal government.

I think the Office of the National Coordinator for Health Information Technology has done a good job soliciting and acting on public comment as meaningful use was put together. But the guidance side has been limited to Frequently Asked Questions on two Web sites that often don't bring clarity, and brief superficial tidbits of useful information at trade show presentations that 99.99 percent of potential meaningful users are not attending.

Some folks who expect to apply for incentive payments as soon as possible still don't know if the attestation is Web-based or on paper (Web). And nobody knows anything about Medicaid meaningful use programs expect that the 56 programs will start at various times throughout 2011 and may or may not have similar procedures and methods of payment.

Here's some pretty important questions that providers needed clarity on a long time ago and still don't have it today:

* Do you have to purchase certified EHR modules that support optional meaningful use criteria that you don't have to meet?

* Can only the authorized ordering clinician enter orders into the CPOE system?

* What documentation--proof--do you have to submit along with your meaningful use attestation?

* Can you extract data from a non-certified system and run it through the reporting module of a certified system to prevent double counting of patients?

Further, how many providers know that 2012 is a partial meaningful use attestation year, meaning functional measures are submitted via attestation but clinical quality measures must be electronically submitted? Isn't this something that hospitals gearing up to start meaningful use when fiscal 2012 starts in October should know now?

Providers preparing for meaningful use are doing so using their own good-faith interpretations of the final rule. Will good faith be good enough if they are audited?

Beginning on or around January 3, provider organizations can register for the meaningful use program via a Web site. Beginning around April 4, organizations that have completed a 90-day reporting period can attest that they are meaningful users and apply for first-year incentive payments.

Let's hope ONC in January gives a ton of guidance along with the registration site.


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