The American Hospital Association (AHA) has offered an alternative approach for the definition of meaningful use, including the addition of 12 objectives to the Centers for Medicare & Medicaid Services (CMS).
The different approach was outlined in a letter sent by Rick Pollack, executive vice president of the AHA, to Charlene M. Frizzera, acting administrator for CMS.
"The AHA appreciates [the goals] CMS is trying to achieve," wrote Pollack. However, he recommended that the CMS identify a single, expanded set of meaningful use objectives to be achieved between 2011 and 2017.
"Hospitals would be considered meaningful EHR users and qualify for the full EHR incentive payment if they meet a specified percentage of the hospital objectives in a given fiscal year," Pollack wrote. "The required percentage would increase over time."
The alternative approach was made because, according to Pollack, the EHR incentive programs must be:
- Flexible to support organization-specific IT implementation strategies that account for strategic quality improvement goals, capital investment planning, careful approaches to positive work process change and staff and physician readiness;
- Future-oriented to provide a complete vision of the full set of objectives so hospitals can plan and prioritize their EHR adoption approach;
- Incremental, to mirror the natural health IT adoption process that begins with foundational IT systems and builds to highly advanced clinical decision support systems;
- Focused on objectives that have been proven to promote improved patient safety and quality; and
- Achievable for all hospitals.
AHA's alternative approach was laid out by Pollack as follows:
- Establish the full scope of meaningful use objectives up-front: According to Pollack, "yet-to-be-named" objectives for Stages 2 and 3 for meaningful use make it difficult for hospitals to plan their IT adoption activities. "The AHA believes the complete list of hospital meaningful use objectives should include those in the proposed rule (with some modifications) and should be expanded to include 12 additional objectives that have been discussed and proposed by the Health IT Policy Committee for FY2013 and FY2015," wrote Pollack.
- Lengthen the timeframe for achieving the ultimate vision for meaningful use: "To support incremental adoption, the goal-line for meeting meaningful use should be extended to 2017 and encompass four phases of increased functionality and use (2011/2012, 2013/2014, 2015/2016 and 2017)," Pollack wrote.
- Take a phased, flexible approach to defining meaningful use: In the four phases: AHA recommends that for most hospitals, meaningful users should build towards achieving the full set of meaningful use objectives over time instead of an "all or none" approach. Starting with 25 percent of the objectives (for FYs 2011/2012), the next phase would require at least 50 percent of the objectives (for FYs 2013/2014) moving onto at least 75 percent for FYs 2015/2016. For 2017 and for beyond, 100 percent of the objectives should be met, according to AHA. However, for smaller hospitals (100 beds or fewer), AHA recommended that the objective percentage required be lowered in the first three stages: 15 percent, 30 percent and 60 percent, respectively.
- Establish a Meaningful Use Technical Expert Panel.
Reiterating that these additional objectives are meant to describe the end-goal for 2017, the letter recommended the following changes to the set of CMS-proposed objectives to form the set of objectives to be included in the AHA preferred approach:
- Drop the two measures related to administrative cycles:
- Submit claims electronically to public and private payers and
- Check insurance eligibility electronically from public and private payers;
- Separate the clinically relevant medication alerts (drug-drug interaction alerts, drug-allergy interaction alerts) from the efficiency-related medication alert (drug-formulary alert);
- Defer medication reconciliation until 2013;
- Defer automated quality reporting until 2013; and
- Add additional objectives and measures to better define a more complete vision of a fully functioning and complete EHR, including:
- Use of evidence-based order sets;
- Electronic medication administration record (eMAR);
- Bedside medication administration support (barcode/RFID);
- Record nursing assessment in EHR;
- Record nursing plan of care in EHR;
- Record physician assessment in EHR;
- Record physician notes in EHR;