Keep Up-to-Date on ARRA

On July 13, the Department of Health and Human Services (HHS) released the final rules for meaningful use and certification standards of electronic health record (EHR) systems under the HITECH provisions of the American Recovery and Reinvestment Act (ARRA). The rules establish the requirements for eligible hospitals and providers to qualify for Medicare and Medicaid incentives for meaningful use of certified EHRs.

Overall, the final rules are what McKesson expected, and we are pleased with the results. Eligible hospitals and providers now have the flexibility to achieve meaningful use by taking different paths to implementing an EHR based on their needs and priorities, which is critical to adoption. We believe the changes position more healthcare providers to be able to participate in the program in a timely manner.

The final meaningful use rule (which applies to healthcare providers) reflects the real-world perspective and changes requested in industry and public comments. Key changes include:

  • Two categories of requirements are established (Core and Menu):
    1. The 15 Core set of objectives are not optional, and the specified measurement for each objective must be achieved.
    2. The Menu set of objectives allows eligible hospitals and physicians to select five of the 10 objectives based on their current stage of EHR implementation.
  • Achievement levels of many of the objectives have been reduced.
  • Administrative and financial objectives (electronic claims submission and eligibility checking) have been deferred to Stage 2.
  • The proposed meaningful use rule limited all process and measurements to the inpatient setting (Point of Service Code 21). The final rule includes the Emergency Department for process and measurements (Point of Service Code 23) for eligible hospitals

Other changes to note under both sets of meaningful use objectives:

Core:

  • For computerized provider order entry (CPOE), the final rule requires 30% of patients to have one medication order entered via CPOE vs. the previous proposal of 10% of all clinical orders.
  • Security and Privacy requirements call for a security risk analysis, implementation of security updates and deficiency correction.
  • For electronic prescribing, the final rule requires 40% of all permissible prescriptions written by the physician are transmitted electronically down from the previous 75%.
  • One clinical decision support rule must be implemented vs. the previous proposal of five.
  • Information exchange will be required for reporting quality measures.
  • Providers must be able to electronically exchange key clinical information among providers (pass at least one test transaction).

Menu:

  • Incorporate lab results as structured data (at 40% level).
  • Generate lists of patients by specific conditions (at least one condition).
  • Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies) upon request for more than 50% of all patients that request it within 3 business days vs. the previous 80% within 48 hours.
  • Provide clinical summaries to patients for more than 50% of all offices visits within 3 business days down from the previous 80%.
  • New: Use the EHR to identify patient-specific education resources (10% level).
  • New: Record an Advance Directives indicator for patients over the age of 65 (for more than 50% of patients).
  • Perform Medication Reconciliation between care settings (for more than 50% of transitions of care).

Next Steps

Though the wait for the final rules is over, there are a number of details needed for a successful program. First, the industry must have Authorized Testing and Certification Bodies (ATCBs) in place to conduct certification of EHR technology. As of today, the government projects that ATCBs will be operational in late summer and the first EHRs will be certified in early fall.

Providers can now confirm their roadmaps and finalize the needed work to achieve meaningful use. For more than a year, McKesson has been actively moving our EHR systems toward having the capabilities our customers need to achieve the proposed objectives. We believe we are well-positioned to achieve certification of our EHR systems, and we are committed to supporting your efforts to achieve meaningful use.

This is McKesson's initial assessment of the final rules. We will post more details as our teams fully analyze the meaningful use and certification requirements.