The Recovery Act that initiated the process of providing incentive payments for the adoption and use of Electronic Health Records (EHR) included the provision that such systems support “meaningful use” if they are to be certified and funded. Of course if you have to have meaningful use, then meaningful use has to be defined, and them measured. After a round or two of proposals and comments, CMS issued an Interim Final Rule on December 30, 2009. (The idea that a Final Rule can be Interim is itself a masterwork of government speak.) The governments discussion of this process is available here. The Interim Final Rule itself (which runs over 30 pages) is entitled “Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology; Interim Final Rule” and it is available here.  A companion rule posted in the Federal Register (FR) on January 13, 2010, “Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Proposed Rule” is available here.  All of this is part of the Health Information Technology project in the Department of Health and Human Services which is lead by Dr. David Blumenthal who is the National Coordinator for Health IT.

These rules defines 25 functions that together constitute meaningful use. Each of these also has a level of performance that is required for ultimate certification (as listed in the January 13th FR). For example, the first use (see below) of “Use Computer Provider Order Entry (CPOE)” has the criteria that it is used for at least 80% of all orders; but only 10% for hospitals. How an EHR is actually used by the provider is an interesting and important distinction from what the system is capable of, i.e. if the system provides for CPOE but if the users don’t use that capability to an adequate degree, then by these definitions meaningful use is not achieved. Thus what the EHR can do is a necessary but sufficient condition to establish its certifiablity.

The 25 elements and an abbreviated statement of the associated measures are:

1. Use Computer Provider Order Entry (CPOE) (80%/10% hospitals)

2. Implement drug/allergy checks (Enabled)

3. Maintain an up-to-date problem list of current and active diagnoses (80%)

4. E-prescribing (Eligible Professional (EP) only) (75%) Continue →