Providers and vendors alike are anxiously waiting for HHS to establish a clear definition of "meaningful use" as a prerequisite for eligibility to tap into the $19 billion in EHR incentives available under the American Recovery and Reinvestment Act (ARRA) of 2009.
What we know is that for hospitals, meaningful use will include the ability to exchange health information, provide decision support for physician order entry, and submit data related to clinical quality and other measures that HHS selects. For physicians, it will also include an electronic prescribing capability.
One big unknown is the specific quality measures hospitals must report to be eligible for incentives.
The FY 2010 Inpatient Prospective Payment System (IPPS) proposed rule that CMS released May 1 referenced the Health Information Technology for Economic and Clinical Health Act, but only to say that HHS will select the ARRA measures in a separate rulemaking process.
The proposed rule also reiterated the fact that ARRA requires HHS to give preference to those clinical quality measures that have been selected for the RHQDAPU program, and it highlights the overlap between the two efforts. Specifically, the rule states the following:
The RHQDAPU program and the HITECH Act have important areas of overlap and synergy with respect to the reporting of quality measures using EHRs. We believe the financial incentives under the HITECH Act for the adoption and meaningful use of certified EHR technology by hospitals will encourage the adoption and use of certified EHRs for the reporting of clinical quality measures under the RHQDAPU program. Further, these efforts to test the submission of quality data through EHRs may provide a foundation for establishing the capacity of hospitals to send, and for CMS to receive, quality measures via hospital EHRs for future RHQDAPU program measures.
Another big unknown is what the requirements for decision support will entail. There a variety of different elements that decision support could include, says Kelly McLendon, RHIA, president of Health Information Xperts, LLC, in Titusville, FL. For example, it could include dose range, error checking, allergy notification, protocols, clinical pathways, or templates. All of these functions are part of decision support, he says, and each one has its own unique implementation challenges.
Interoperability is perhaps one of the largest unknowns. Aside from the technical and logistical aspects of exchanging information, hospitals should consider the ramifications of information exchange with other entities, McLendon says. "What information do we send and when? Will the information from another hospital become part of the receiving hospital's legal health record?"
The laundry list of unknowns has left providers trying to make sense of the regulation. But the lack of information hasn't precluded several professional organizations from weighing in with their thoughts on what a definition of meaningful use should entail.
The Healthcare Information and Management Systems Society (HIMSS) published its definition of meaningful use on April 27—one day before the National Committee on Vital and Health Statistics (NCVHS) would hold a two-day hearing in Washington, DC on the topic.