Meaningful Use: Practical Considerations for Physicians

Making Sense of a Confusing Subject

For almost a year physicians have been hearing about the meaningful use criteria that must be demonstrated (or at least attested to in the first year of incentive funding) to be eligible to receive CMS incentive funding. Of course, achieving meaningful use (hereafter referred to simply as “MU”) is only one component of qualifying for incentive funds. Physicians must also be “eligible providers” (certain hospital-based physician specialties are excluded from incentive funding on the principle that they use electronic health records purchased by the hospital). Physicians as well must use an EHR from a certified vendor — subsequent federal rules and guidance have been issued on how vendors can become certified. Certification itself requires the vendor demonstrate they have the functionality and capability to meet each of the MU criteria. The MU criteria are designed to be met in three stages over a period from 2011 through 2015.

The complete set of MU criteria and measures to demonstrate they have been achieved was released in the “Medicare and Medicaid Programs: Electronic Health Record Initiative Program A” Proposed Rule, released Dec. 30, 2009. This proposed rule generated hundreds of public comments, most of them challenging the MU criteria as too complicated, difficult, or inappropriate, as well as unlikely to be successfully reached by healthcare providers in the allotted timeframe. Timeframes for achieving MU are also tied to the incentive funding timeframe itself. Incentive funding has a limited shelf life and, as proposed, decreases in amount and finally disappears. Thus physicians are faced with the challenge of not achieving MU in the prescribed timeframe and either losing incentive funding opportunities or receiving a reduced incentive.

The proposed MU criteria are organized into several categories that support a health outcomes policy priority, each with a specific goal. For the most part, these make sense and contribute to overall improved patient quality and outcomes, practice efficiency, and even privacy and security of patient information. The categories are the following:

• Improving quality, safety, and efficiency, and reducing disparities. Some of the criteria in this category are the use of computerized order entry for diagnostic tests or medication prescribing. This category is the largest, with 16 criteria.
• Engage patients and their families in their healthcare, with criteria including the ability to provide patients with a clinical summary of their office-based visit or with timely electronic access to their health information, such as laboratory test results.
• Improve care coordination. An example of the criteria in this category is performing medication reconciliation (prescription medications, home medications, and so forth).
• Improve population and public health. An example of the criteria in this category would be exchanging immunization data with the San Diego County immunization registry program.
• Ensure adequate privacy and security protections for personal health information. This category has only one criterion, which can be demonstrated by showing that you have conducted or reviewed a security risk analysis as required by the HIPAA security rule and have implemented security updates as necessary.

It remains to be seen how responsive CMS will be to the public comments and to what degree MU criteria will be modified. In the meantime, there are a few practical tips that can be initiated for any medical practice. These are based on implementing those criteria today that make good sense from a practice efficiency and compliance perspective.

1. Submit claims electronically. Using electronic claims submission generally results in faster reimbursement and better claims adjudication accuracy. Even if your practice management software cannot generate an electronic claim, there are clearinghouses that can help.
2. Check insurance plan eligibility and benefits electronically. The average wait time for telephone eligibility verification nationally is still longer than 20 minutes! This is a terrible waste of office personnel time and very inefficient. Even if you use a clearinghouse and must pay a small per-eligibility inquiry fee, the cost is usually well worth the time saved!
3. Complete your HIPAA security compliance plan, including the risk analysis. Many medical practices have not completed the security rule compliance, even though it went into effect in 2005. Maintaining privacy safeguards and providing the forms (such as the notice of privacy practices) is not a complete compliance program! There are easy-to-use tools to help you achieve compliance and complete a risk analysis.

These three tasks are appropriate and, in the case of HIPAA, required now. They are also three of the proposed MU criteria your practice can achieve early.