The definition of meaningful use of health information technology in the form of electronic health records will evolve in stages, with the earliest stage focusing on data capture and basic use of that information, according to a proposal by CMS.

"Under this phased approach to meaningful use, we intend to update the criteria of meaningful use through future rulemaking," the agency said in a notice of proposed rulemaking for the first-stage criteria, released Dec. 30 and scheduled for publication in the Federal Register Jan. 13.

"We will continue to evaluate the progression of the meaningful use definition for consistency with legislative instructions and new statutory requirements relating to quality measurements and simplification," the NPRM says.

The agency is soliciting comments on "how best to balance the relevant goals, including promoting the adoption of [electronic health records], avoiding excessive or unnecessary burdens, and improving health care."

During a Dec. 30 conference call with reporters to introduce the ¹ NPRM and a ² companion interim final rule regarding the initial set of standards, implementation specifications and certification criteria for electronic health records, HHS Office of the National Coordinator for Health Information Technology Director David Blumenthal added that it's "possible that future meaningful use requirements will be different either as software changes or as we learn more about the way an electronic health record can in fact improve our health system."

CMS said that the stage 1 definition of meaningful use focuses on "electronically capturing health information in a coded format, using that information to track key clinical conditions, communicating that information for care coordination purposes, and initiating the reporting of clinical quality measures and public health information."

The stage 1 criteria will go into effect in 2011.

In the NPRM, CMS outlines 25 objectives/measures that must be met by eligible providers and 23 objectives/measures that must be met by hospitals to be considered meaningful users, which would enable them to collect financial incentives for meaningful use of health IT provided through the American Recovery and Reinvestment Act (³ Also see "Adoption Of E-Health Records Gets Stimulus Of Medicare Rewards, Penalties" - Pink Sheet, 2 March, 2009.).

The objectives stem from the draft definition of meaningful use offered by CMS in June 2009 (⁴ Also see "Definition Of Health IT “Meaningful Use” Could Change Depending On Setting" - Pink Sheet, 22 June, 2009.).

The stage 2 criteria will expand upon the stage 1 criteria "in the areas of disease management, clinical decision support, medication management, support for patient access to their health information, transitions in care, quality management and research, and bi-directional communications with public health agencies," the agency said. An NPRM for stage 2 criteria is expected by the end of 2011.

Stage 3 will "focus on achieving improvements in quality, safety and efficiency, focus on decision support for national high-priority conditions, patient access to self management tools, access to comprehensive patient data, and improving population health outcomes." The proposal for stage 3 will be offered for comment by the end of 2013.

Widespread adoption of health IT is seen as having a positive impact in a number of areas across the health care industry, including comparative effectiveness research.

Stage 1 Goals

During the call, Blumenthal offered a top-level perspective on what the agency was hoping to accomplish with the NPRM.

"What we tried to do in this ... stage 1 level of meaningful use is to develop a closely linked set of meaningful use requirements, related standards and related certification criteria that, based on today's technology and based on what we know about the capabilities of records, are most likely to be useful to have and capable of adoption by eligible professionals and hospitals," Blumenthal said.

The ⁵ meaningful use criteria are organized by stating broad health outcomes policy priorities, which are then narrowed into specific care goals, objectives to meet those goals, and finally metrics that will be used to measure whether the objectives are met.

At the highest level, the stage 1 health outcomes policy priority is divided into five categories:

Improve quality, safety, efficiency, and reduce health disparities (care goals include: provide access to comprehensive patient health data for a patient's health care team; use evidence-based order sets and computerized provider order entry; apply clinical decision support at the point of care; generate lists of patients who need care and use them to reach out to plans; and report information for quality improvement and public reporting).

Engage patients and families in their health care (provide patients and families with timely access to data, knowledge and tools to make informed decisions and to manage their health).

Improve care coordination (exchange meaningful clinical information among professional health care teams).

Improve population and public health (communicate with public health agencies).

Ensure adequate privacy and security protections for personal health information (ensure privacy and security protections for confidential information through operating policies, procedures and technologies and compliance with applicable law; provide transparency of data sharing to patients).

Objections Already Surfacing

The new regulations are not being greeted with open arms within the physician community, with at least one group already questioning them.

The Medical Group Management Association in a Dec. 31 statement described the rules as overly complex and said medical groups will face significant challenges in meeting the requirements, including "unreasonable thresholds for some of the meaningful use criteria (i.e. computerized prescription order entry, electronic claim submission, electronic insurance eligibility verification, and others); potentially difficult meaningful use attestation after the first year; and a requirement that physician offices provide patients and others with electronic copies of medical records."

The group argued that overly burdensome regulations will serve only to discourage adoption.

- Gregory Twachtman ( ⁶ g.twachtman@elsevier.com )

Health IT "Meaningful Use" Definition To Evolve In Stages, CMS Rule Says

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