Monday, May 25, 2009

More on Meaningful Use

I wrote earlier about what Meaningful Use is and why it is important. Recall that providers will be reimbursed for purchases of certified HIT products and that they will then recieve financial incentive for the "meaningful use" of that technololgy, but all that the legislation says is that meaningful use is:

1. ePrescribing
2. participation in an HIE
3. submission of quality measures

The importance of the definition is that it is the first step in a process that involves many others.

1. The HIT Standards committee will need to select the standards and implementation guides that support meaningful use
2. The certification body (which may be CCHIT, but HHS has not confirmed this) will need to align its certification criteria with these
3. Vendors may need to adjust their EHR Systems to ensure that it meets the criteria. This may require recertification.
4. HealthCare Organizations (HCOs) that already have technology in place may need to upgrade or adjust their systems so that they can meet the meaningful use criteria. Those organizations that do not have EHRs in place will likely wait until the vendors have caught up with the certification criteria before they begin implementing.

Until the definition is published, we can guess at what they mean, and try to be ready for it.

Money becomes available for the purchase of "certified" EHR systems in October, 2010. So, the timing is extremely tight.

These dates are from the website:

Standards Rulemaking: Recovery Act §3004 (B) (1) - No later than December 31, 2009, HHS shall adopt and publish an initial set of standards, implementation specifications, and certification criteria. The rulemaking for this initial set of standards, implementation specifications, and certification criteria may be issued on an interim, final basis. Fully competitive contract awards will be utilized to support the impact analysis.


Complete Draft Rule/ Regulatory Impact Analysis. Start: 05/01/2009 End: 08/26/2009

Submit for HHS Clearance. Start: 08/26/2009 end: 09/25/2009

Clear OMB (up to 90 day process) Start: 09/25/2009 End: 12/24/2009

Publish in Federal Register. Start: 12/24/2009 End: 12/31/2009

So, if the HIT Standards Committee is to meet the deadline of submitting the list of standards that are required to support “meaningful use” (August 26), the definition has to be published very, very soon.

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