Tuesday, June 22, 2010

Rule on meaningful use of EHR is coming soon

We are getting very close to having a final rule issued on meaningful use. I believe the final rule will have some significant changes from the proposed rule regarding how high a bar we must reach to qualify for the first year incentive payments. The proposed rule contains 25 measures that providers must use to qualify for federal incentives beginning January 2011. The rule also contains 23 measures through which hospitals must demonstrate meaningful use of healthcare IT for incentives beginning Oct. 1, 2011. I do not think the timelines will change, and I think that the measures are likely to stay basically intact. It is very difficult to substantially change a proposed rule, without requiring a whole new comment period.

So what exactly can they do make the rule more palatable and allow the greatest number of providers and hospitals to participate in incentive payments? It would be a terrible thing to offer a stimulus that few could qualify for... There were many, many comments submitted on the proposed rule, from every area of the industry, and I think most pointed in the same direction. We need to flatten the slope of adoption or we could see some massive failure points, particularly in rural and underserved areas, which actually need the stimulus the most.

A few thoughts on what may be possible:

  • Only require a certain number of measures to be met in the first year and move away from "all or nothing approach" - this will almost certainly happen, and it will be interesting to see how far they are dialed back
  • Reduce the number of quality measure reporting requirements by allowing identification of selected clinically relevant measures
  • Clearer definition of terms such as "health information" and making "48 hours" something achievable by using business days instead
  • Tweaking the definition of a "hospital-based physician" even further than accomplished through recent changes in legislation
  • Reduction in administrative burden of reporting computerized physician order entry measures
  • Scale back objectives and measures that don't directly apply to EHR adoption, such as checking insurance eligibility electronically

This is but a small sampling of what might be in store. There will certainly be some scaling back of the requirements. Hopefully, it will be enough to encourage adoption without making it too difficult in the out years to achieve the later stages. If stage one meaningful use is too far watered down, then it will be a long jump to stages two and three. I think we will see the final rule before the Fourth of July - possibly even this week. You can bet there will be tweets and blog postings galore when this baby drops

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