Background on Meaningful Use Criteria
The CMS Final Rule has delineated precise criteria for hospitals and eligible professionals to achieve meaningful use of certified EHR technology. To start, eligible professionals need to fulfill 15 core objectives, cherry-pick five out of a menu set of 10, and ensure accurate reporting of six Clinical Quality Measures (CQMs) as stipulated by the HHS Secretary.
Hospitals have their set of requirements, which include 14 mandatory core objectives, along with five objectives selected from another set of 10. Additionally, they are tasked with reporting on 15 CQMs to confirm their meaningful use adherence.
Compliance often hinges on percentage-based measures. For instance, a minimum of 80% of patients should have their records maintained within certified EHR technology. Another key requirement is the activation of clinical decision support rules.
Within the Stage 1 objectives, providers must also attest to their use of certified EHR technology. Furthermore, they should be willing to take part in ONC Health IT Certification Program reviews by the Office of the National Coordinator for Health Information Technology, aiding in the continuous improvement of health IT.
Understanding Certification Criteria
The certification of Electronic Health Record (EHR) technology is a critical component of the health IT ecosystem, directly impacting care providers, hospitals, and the patients they serve. To comprehend the full scope of this certification, one must recognize the two distinct types of certifications that address different functionalities and requirements within an EHR system: the CCHIT and ONC-ATCB certifications.
The Certification Commission for Health Information Technology (CCHIT) focuses on evaluating whether an EHR system can perform tasks typically expected of such technology, by using test scripts that scrutinize its programming code. However, it does not guarantee that the system will qualify for meaningful use incentive payments.
In contrast, the ONC-Authorized Testing and Certification Bodies (ONC-ATCB) certification is borne out of the federal government’s effort to ensure that an EHR system meets the technical requirements that enable clinicians to satisfy the meaningful use criteria. These criteria are closely tied to specific incentive programs aimed at encouraging the adoption of EHRs. ONC-ATCB certification is offered in two forms: Complete EHR certification, which satisfies all the criteria for Stage 1 Meaningful Use, and EHR Module certification, which meets a subset of these criteria.
Instances like the case of Greenway in 2019, which incurred penalties for fraudulently achieving health IT certification, underscore the importance of rigorous adherence to certification requirements. This not only ensures patient safety but also the proper allocation of government resources and the preservation of industry reputation.
Certification Criteria for Electronic Health Record Technology
The 2015 Edition certification criteria delineate the capabilities, standards, and technical specifications that Electronic Health Record technology must meet. These criteria are pivotal for health care providers seeking to achieve meaningful use and, consequently, participate in the Promoting Interoperability (PI) Programs, formerly known as the Medicare and Medicaid EHR Incentive Programs.
For health care providers, using an EHR that complies with these certification criteria is mandatory to avoid Medicare payment adjustments or to receive Medicaid incentive payments. The certified EHR technology (CEHRT) must facilitate the capture, sharing, and efficient use of patient data in a structured format, enhancing the overall quality of patient care.
Applicable Certification Criteria for Health Information Exchanges
Health Information Exchanges (HIEs) are integral to the seamless sharing of health information across different organizations and systems. The 2015 Edition certification criteria include specific provisions for HIEs, mandating that they showcase the capability for safe and secure electronic data interchange, including clinical summaries and continuity of care documents.
To support care coordination and the elevation of patient care quality, HIEs must adhere to the standards and specifications specified by the certification criteria which focus on interoperability. This ensures the accessibility and utility of health information across various health IT platforms and is crucial for the meaningful use of EHRs in a diverse range of health care settings.
Scope of Practice for Health Care Providers
Medicaid Services specifies exclusions and patient volume criteria for health care providers seeking incentive payments under the Medicaid EHR Incentive Program. Eligible professionals (EPs) such as physicians, dentists, nurse practitioners, and others in the scope of practice must not be hospital-based to qualify. Among qualifications, there is a threshold for patient volume, which requires a minimum percentage of patient encounters to be Medicaid patients, demonstrating the significance of CEHRT in their practice.
For acute care hospitals vying for these payments, at least a 10 percent Medicaid patient volume is necessary, while children’s hospitals are exempt. These particulars underscore the centrality of specific patient demographics and health care environments in the pursuit of EHR technology integration, augmented by the government’s incentive programs.
Incentive Programs and Incentive Payments
The landscape of incentive programs in the healthcare sector has been significantly transformed to encourage the adoption and meaningful use of Certified Electronic Health Record Technology (CEHRT). Central to these transformations is the distribution of incentive payments, devised to support healthcare providers in implementing and maintaining advanced EHR systems. Critical Access Hospitals (CAHs) are a primary example, with qualifying CAHs able to obtain incentive payments for the purchase of CEHRT based on reasonable costs. These payments focus on the Medicare share percentage calculated over the reporting period and are designed to cover costs in one payment year, including expenses related to depreciation and interest.
However, there is a delineated timeframe and limitations for these payments: CAHs can only receive incentive payments for cost reporting periods from FY 2011 through FY 2015, and are limited to four consecutive payment years. Those CAHs that do not meet the qualifying criteria may experience payment reductions, except if they fall under certain exemptions.
As incentive programs evolve, the Merit-based Incentive Payment System (MIPS) has emerged as a significant successor to previous quality reporting initiatives. MIPS stimulates quality improvements and incentivizes superior patient care by evaluating healthcare providers on specific performance domains. Eligible clinicians must meet the participation thresholds to avoid negative adjustments and potentially earn positive payment adjustments. The success in these areas is directly tied to the provider’s proficiency in employing health IT products, such as certified EHR systems, to meet the stipulated performance scores.
Merit-based Incentive Payment System (MIPS)
The introduction of MIPS by the Centers for Medicare & Medicaid Services marked a pivotal shift towards value-based healthcare delivery. MIPS consolidates the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VM), and the Medicare EHR Incentive Program into one cohesive framework. By evaluating performance across four categories—Quality, Cost, Improvement Activities, and Promoting Interoperability—MIPS incentivizes healthcare providers to surpass traditional care delivery standards.
Clinicians including physicians, physician assistants, nurse practitioners, and others who meet the necessary billing threshold with Medicare Part B are mandated to participate in MIPS. Their performances are scrutinized, scored, and subsequently, payment adjustments are applied. These adjustments, reflective of the clinician’s adherence to MIPS’ comprehensive quality measures, hinge upon the meaningful integration of CEHRT into their practice and their ability to demonstrate meaningful use objectives effectively.
Reporting Period for Incentive Programs
The administrative aspect of incentive programs necessitates stringent reporting protocols to ensure compliance and accurate distribution of funds. States are obligated to submit annual reports to CMS within 60 days following the closure of the second quarter of the Federal fiscal year. These reports are crucial and contain a wealth of data, including adoption, implementation, and upgrading activities related to CEHRT by Medicaid EPs and eligible hospitals, alongside aggregated measures of meaningful use.
To fulfill these requirements, states must thoroughly track and verify the related activities for each payment year, as dictated in the State Medicaid HIT Plan. Such meticulous monitoring and verification include plans for regular audits to maintain integrity in the program. In cases where the required reports are not furnished to CMS within the timeframe, states run the risk of losing funding, emphasizing the symbiotic relationship between healthcare providers’ technological capability and their financial incentives.
The dynamic interplay between various incentive programs and their corresponding criteria, reporting periods, and payment adjustments delineate the driving forces behind the widespread adoption and meaningful use of EHR technology. These initiatives not only spur technological advancements but also aim to elevate the overall quality of care and patient outcomes across the healthcare spectrum.
Patient Care and Quality Measures
Electronic Health Records (EHRs) are at the forefront of enhancing patient care and refining clinical quality measures (CQMs). They provide a comprehensive and structured format for health care providers to report and analyze various aspects of patient treatment and outcomes. This translates to improved patient engagement, heightened safety, optimized care coordination, bolstered public health, and efficient utilization of healthcare resources.
The advent of certified EHR technology aids in the meticulous process of automatically recording, calculating, and exporting quality measure results. These critical processes adhere to the standardized format of Health Level Seven (HL7) Quality Reporting Document Architecture (QRDA), which is essential to align with meaningful use criteria and demonstrate the effective use of EHRs.
In the pursuit of maintaining a high degree of patient-record integrity, certified EHRs undergo rigorous security evaluations to assure the privacy and security of patient electronic health data. Hence, the impetus is not just on the technological capability but also on the safeguarding of sensitive information. This includes implementing robust features such as audit trails to track access and changes to patient data, employing data encryption to prevent unauthorized access, and requiring password protection to control provider access.
Clinical Quality Measures for Patient Record and Health Information
The framework of CQMs for patient records encapsulates numerous facets, including enhanced patient engagement and safety. These measures are predicated on technological capabilities such as computerized provider order entry (CPOE) and clinical decision support. EHRs must be adept at capturing and communicating pertinent information for laboratory testing and other critical patient health details, which form an integral part of the meaningful use objectives.
Ensuring that EHRs can automatically record, calculate, and export CQM results is pivotal. It qualifies for incentive payments under the HITECH Act and upholds the assurance to purchasers and healthcare providers regarding the value and efficacy of their health IT investments. To facilitate this, EHR systems must utilize a structured format like HL7 QRDA for reporting, signifying their compliance with applicable certification criteria and positioning them as crucial tools in the health information technology landscape.
Care Coordination and Quality of Care
Care coordination, fortified by certified EHRs, is instrumental in elevating the quality of care provided to patients. It encompasses the secure and efficient exchange of eReferrals and health information across varied health IT systems, an operation made possible through adherence to HL7 Consolidated Clinical Document Architecture (C-CDA) standards in XML format.
The technological infrastructure of an EHR system is designed to foster seamless communication, employing protocols such as IHE XDR, SMTP, POP3, and IMAP4. These protocols facilitate the transition of care and compilation of comprehensive patient records, fortifying the scope of practice for healthcare professionals. This harmonized exchange of data ensures that electronic prescribing, care plans, and patient health information are shared between the patient’s entire care team.
Recognizing the importance of reporting CQMs, providers must leverage EHR systems to track and submit these metrics accurately, employing the standardized HL7 QRDA format. The overarching goal is to use these systems not merely for documentation but as powerful tools in the drive towards proactive care, enriched patient health outcomes, and improved patient engagement.
Assurance to Purchasers
When it comes to investing in Electronic Health Record (EHR) technology, assurance to purchasers is a key consideration. The Office of the National Coordinator for Health Information Technology (ONC) plays a critical role in this process through their certification of EHR systems. This certification is a stamp of approval indicating that the technology has met rigorous standards of functionality, security, and interoperability.
Purchasers of certified EHRs can confidently expect systems that not only support the complex tasks of patient care but also contribute to the broader objectives of enhancing healthcare quality and efficiency. This assurance is critical for healthcare organizations that rely on EHRs to manage sensitive patient information and to engage with other healthcare providers and organizations seamlessly.
The certification process affirms the ability of EHR systems to support the exchange of health information within a framework that ensures a high degree of usability. This is essential for healthcare professionals across various clinical settings who depend on intuitive interfaces and efficient workflows. Moreover, certified EHR technology provides the necessary infrastructure for reporting clinical quality measures, which is vital for the delivery of high-standard patient care and the achievement of healthcare quality improvement milestones.
Technological Capability and Assurance for Health IT Products
Purchasers and users of health IT products require certainty that their investment is sound. The ONC Health IT Certification Program delivers this by thoroughly evaluating whether certified health IT products possess the technological capability to perform effectively according to industry standards. These standards encompass essential aspects such as functionality, security, and the ability to interoperate among disparate systems—providing a high level of confidence to purchasers.
Health IT products that have secured ONC certification have proven conformance to established criteria. They are recognized for improving the delivery of healthcare by streamlining operations, enhancing patient safety, and maintaining robust privacy and security of patient information. The products’ usability and efficient operation are of particular importance to healthcare professionals who rely on these tools daily.
The Certified Health IT Product List (CHPL) is an invaluable resource, providing a comprehensive directory of all ONC-certified health IT products—ensuring transparency and making it easier for purchasers to verify the credentials of the technology they are considering.
Assurance of Electronic Health Record Technology for Health Care Providers
Healthcare providers face a significant challenge: integrating EHR technology into their practice in a way that meets current regulatory requirements. The CMS EHR Incentive Program, underpinned by the HITECH Act, stipulates that providers must utilize certified EHR technology (CEHRT) to avoid penalties such as decreased Medicare reimbursements.
For physicians and hospitals, the adoption of CEHRT is incentivized through meaningful use achievement, which involves meeting preset targets that are evaluated against the functional and technical criteria set forth in the legislation. By aligning EHR certification criteria with these targets, the HITECH Act ensures that the technology is not only certified for safety and efficiency but is also equipped to satisfy the specific demands of modern healthcare reporting.
The increasing prevalence of EHR adoption also amplifies the expectation for electronic data exchange capabilities, notably for laboratory information. Consequently, laboratories and practices now need to grapple with the technical and operational demands of integrating their systems with EHR technology that lives up to meaningful use criteria. This presents unique challenges but also serves as a commitment to raise the standard of patient care and to streamline healthcare operations across the board.