The following list of items represent an initial clinical interpretation of the criteria described in last summer's Meaningful Use Matrix compared with the proposed interim final rule (IFR) 42 CFR Parts 412, 413, 422, and 495 for Meaningful Use Criteria as published December 30th.The items below represent changes to the original matrix published last summer.
The proposed IFR states that many of these items represent standards that must be calculated over an Electronic Health Record reporting period (a.k.a Stages), and that these standards should become an integral part of the “Daily Work Processes” in clinical environments to demonstrate "Meaningful Use." Why is this important? Because it describes the information that needs to be captured and reported in order for eligible providers and hospitals to get paid their incentives.
That said, a basic understanding of the reporting measures and their associated calculation or definition should be emphasized in clinical environments to insure that an EHR system is used in a manner that captures the specific information described below. For insight into the implications of this IFR, please read commentary at the end of this post.
42 CFR Parts 412, 413, 422, and 495
Medicare and Medicaid Programs; Electronic Health Record Incentive Program
Implications for Stage 1 (2011)
| 1. CPOE |
Standard: 80% of Eligible Providers and 10% of Inpatient Facilities Numerator: Number of unique Patients seen or admitted under “eligible CCN” during Electronic Health Record reporting period (ERP) with at least 1 ICD-9 or SNOMED entry or “None” Denominator: Number of unique patients seen or admitted under CCN during ERP. Note: Where designated by ERP, as stated in the IFR, specific commentary describes the need to ensure that a capability/measure is continuously utilized and it is not sufficient to demonstrate use of the capability only once, but rather, an EP or facility must utilize this capability as part of their daily work process. |
| 2. e-Prescribing (e-Rx) |
Standard: 75% of “permissible” prescriptions electronically prescribed Numerator: Number of prescriptions (other than controlled substances) generated and transmitted during an ERP Denominator: Number of prescriptions written (other than controlled substances). |
| 3. Active Medication Lists |
Standard: 80% of unique patients have at least 1 entroy or “None” in structured format including medication, dose, frequency, route, etc. Numerator: Number of unique patients with at least 1 entry or “None” Denominator: Number of unique patients seen during ERP. |
| 4. Record Demographics |
Standard: 80% of unique patients have demographics recorded as “structured data” within the EHR. Numerator: Number of unique patients with: preferred language, insurance type, gender, race, ethnicity, date of birth, and for hospitals, date and cause of death. Denominator: Number of unique patients seen or admitted during ERP. |
| 5. Record Vital Signs in chart with changes over time |
Standard: 80% of unique patients ages 2 and above with recorded blood pressure, calculated BMI, and for those patients 2-20 years old, plotted on growth charts. Numerator: Number of unique patients age 2 and above with information charted. Denominator: Number of unique patients ages 2 and above during ERP. |
| 6. Record Smoking Status |
Standard: 80% of unique patients ages 13+ with recorded status. Numerator: Number of unique patients ages 13 and above with status recorded. Denominator: Number of unique patients ages 13 and above seen or admitted to a facility. |
| 7. Lab Results |
Standard: incorporate lab results as “structured data. 50% of all lab results recorded in an EHR during an ERP as positive or negative numerical data in a structured format. Numerator: Number of lab tests ordered during ERP with positive or negative structured numerical data in an EHR. Denominator: Number of lab tests ordered during an ERP. Note: This criterion is reliant on electronic exchange of information even though, in parts of the country, this infrastructure does not yet exist. |
| 8. Patient lists by condition for quality management, reducing disparities, research, and outreach |
Standard: Generate at least 1 report listing patients with a specific condition during the ERP. Compliance will be determined via attestation and no specific reports were mentioned in the IFR. |
| 9. Report Ambulatory quality measures to CMS or States |
Standard: For Stage 1 (2011) aggregate numerator and denominator through attestation in 11.A.3 (page 83) |
| 10. Report Hospital quality measures to CMS or States |
Standard: For Stage 1 (2011) aggregate numerator and denominator through attestation. |
| 11. Send reminders for preventative care per Patient preferences |
Standard: 50% of unique patients seen or admitted that are age 50 or older. Numerator: Number of unique patients age 50 or older during ERP who were provided with reminders. Denominator: Number of unique patients seen, aged 50 or above. |
| 12. Five (5) Clinical Decision Support Rules |
Standard: Clinical Decision Support Rules (CDSR) are those that are relevant to a specialty or high clinical priority, including diagnostic test ordering, with the ability to track compliance with the rules. |
| 13. Electronically check Insurance Eligibility |
Standard: 80% of unique patients seen or admitted that had their insurance eligibility checked electronically for public and private payers. Numerator: Number of unique patients seen or admitted whose insurance eligibility was checked electronically. Denominator: Number of unique patients seen or admitted to an eligible hospital CCN during the ERP whose insurer allows electronic verification of eligibility. Note: The ability to electronically check insurance eligibility is a standard HIPAA transaction and relies on electronic data exchange. |
| 14. Submit claims electronically to public and private payers |
Numerator: Number of claims submitted electronically using a “Certified EHR" for patients seen by an eligible provider or admitted to an eligible hospital during the ERP. Denominator: Number of claims filed electronically using a “Certified EHR" for patients seen by an eligible provider or admitted to an eligible hospital during the ERP. |
Implications for education and use:
The standards and calculations mentioned above should be an integral part of an education program for clinicians that creates a checklist of sorts for patients seen in a practice or admitted to a facility. The ability to report on these measures implies that the data is captured in a timely fashion and is a "routine" aspect of inpatient or ambulatory patient care delivery.
If clinicians have a reference and/or checklist, the information will be captured at an appropriate point in the patient care cycle, preferably at the onset in both inpatient and ambulatory centers. In short, capture of this information should be part of "intake" processing for patients.
The IFR also provides background and thought processes that led to the adoption of these criteria in the proposed rules.
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