What Certifications Mean for Meaningful Use
When choosing an electronic health record (EHR), it is important to look for a solution that is complete, with integrated practice management and EHR functionality, as well as certified to meet all Meaningful Use criteria.
The Office of the National Coordinator for Health Information Technology (ONC) was created under Executive Order 133365 and signed by President Bush in 2004. The ONC was charged with moving the health care industry to interoperable health records by 2015. Under President Obama, health IT was legislated and capital was placed behind the initiative with the signing of the American Recovery and Reinvestment Act of 2009 (ARRA), thereby bringing a subcomponent, Health Information Technology for Economic and Clinical Health Act (HITECH), into law.
HITECH charged the ONC with authorizing certification bodies to vet EHR vendors on a voluntary basis against test scripts that were designed by the National Institute of Standards and Technology (NIST). ONC Authorized Testing and Certification Bodies (ATCBs) are designated on a temporary basis through December 31, 2011, and will eventually be superseded by permanent certifying organizations. These permanent certifying organizations are currently scheduled to take over the certification process before the December 31, 2011 deadline.
Some ATCBs, such as the Certification Commission for Health Information Technology (CCHIT), will likely test and certify beyond the ONC requirements; vendors touting additional certifications from these bodies will have demonstrated an ability to adapt to and meet ever-increasing standards.
According to the ONC, “Under HITECH, eligible health care professionals and hospitals can qualify for Medicare and Medicaid incentive payments when they adopt certified EHR technology and use it to achieve specified objectives.” The achievement of these objectives, termed “Meaningful Use,” is calculated by the capture and reporting of a set of measures.
To meet Stage 1 requirements for Meaningful Use, Eligible Providers (EPs) must capture and report a predefined set of data. The data is divided into two main groups, the first being a set of 15 “core” measures that all EPs are required to report, and the second a set of 10 discretionary, or “menu,” measures from which EPs are required to choose five. A provider is described as having “achieved” Meaningful Use when these measures are successfully captured and reported and the required threshholds are met.
Complete EHRs vs. EHR Modules
The ONC’s certification bodies are authorized to report vendor certifications as either “EHR Module” or “Complete EHR” solutions.
An “EHR Module” encompasses only a single component of the baseline software needed by health care providers. For example, if an EHR does not include practice management capabilities, the solution is only a component part, or an “EHR Module,” and will require additional ONC-certified software to meet the Meaningful Use requirements.
According to the HIT Policy Committee, EHR Modules will have to be sold with a label indicating that Health and Human Services (HHS) has not tested or certified the module for interoperability with other modules.
A “Complete EHR” has both practice management and EHR capabilities, and incorporates all 25 Meaningful Use criteria in a single database solution. Using a Complete EHR removes the concern over interoperability issues between software modules, and also addresses the need to capture all required Meaningful Use measures.
The Physician Quality Reporting System
The Physician Quality Reporting Initiative (PQRI) – now known as the Physician Quality Reporting System (PQRS) – was born out of a piece of tax legislation, specifically the Tax Relief and Health Care Act of 2006. Under this Act, CMS collects clinical quality data to research and identify what constitutes quality. The data measures collected are known as Clinical Quality Measures (CQMs).
With the signing of ARRA / HITECH into law, eligible providers must report CQM’s to either CMS or the state, depending on the provider's elected EHR incentive program. Though other forms of reporting are currently allowed, CMS is moving towards EHR-based reporting for all CQM’s. Furthermore, with the signing of the Affordable Care Act in March 2010, CMS is required to bring its methodologies for reporting Meaningful Use into alignment with PQRS.
While the Final Rule for Meaningful Use does not require electronic reporting of CQMs in 2011, it will be required by 2012. With this in mind, it makes sense to choose a vendor that has been tested and vetted by CMS for EHR-based PQRS reporting.
What This Means for Incentives
In order to receive incentive dollars under the Medicare and Medicaid HITECH programs, a provider is required by statute to use a certified EHR technology. Providers are also eligible to receive incentives under PQRS, as long as they achieve all reporting criteria.
Choosing a complete certified EHR/Practice Management solution that has also received EHR-based PQRS certification is the best option for providers. The assurance of having a complete technology that has been certified to capture all Meaningful Use measures, as well as all required CQMs, positions providers to actually achieve Meaningful Use and obtain all incentive payments for which they are eligible.