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Meaningful Use Rules Hit the Streets

by John Moore | December 31, 2009

Late yesterday afternoon, the Center for Medicare and Medicaid Services (CMS) who holds the big bucket of ARRA incentive funds for EHR adoption, released two major documents for public review and comment that will basically define healthcare IT for the next decade.

The first document, at 136 pgs, titled: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology is targeted at EHR vendors and those who wish to develop their own EHR platform.  This document lays out what a “certified EHR” will be as the original legislation of ARRA’s HITECH Act specifically states that incentives payments will go to those providers and hospitals who “meaningfully use certified EHR technology.”  This document does not specify any single organization (e.g. CCHIT) that will be responsible for certifying EHRs, but does provide some provisions for grandfathering those EHRs/EMRs that have previously received certification from CCHIT.

The second document at 556 pgs titled: Medicare and Medicaid Programs; Electronic Health Record Incentive Program addresses the meaningful use criteria that providers and hospitals will be required to meet to receive reimbursement for EHR adoption and use.  Hint, if you wish to begin reviewing this document, start on pg 103, Table 2.  Table 2 provides a fairly clear picture of exactly what CMS will be seeking in the meaningful use of EHRs.  In a quick cursory review CMS is keeping the bar fairly high for how physicians will use an EHR within their practice or hospital with a focus on quality reporting, CPOE, e-Prescribing and the like.  They have also maintained the right of citizens to obtain a digital copy of their medical records.  An area where they pulled back significantly is on information exchange for care coordination.  Somewhat surprising in that this was one of the key requirements written into the original ARRA legislation.  But then again not so surprising as frankly, the infrastructure (health information exchanges, HIEs) is simply not there to support such exchange of information.  A long road ahead on that front.

In Closing…

As I am on vacation and today is a powder day here in the Rockies, I will come back to this at a later date after I have had some time to review and digest these two documents.  First thought though that comes to mind is that the only initial winners here will be the consultants as few doctors have the time or inclination to pour over the 556pgs of the incentive program.  Heck, in my own brief encounters with many doctors, most have only the most cursory knowledge of the HITECH Act and that knowledge is most often full of inaccuracies.  Hopefully, those regional extension centers that HHS will be funding will go live in the very near future as there is a tremendous amount of education that needs to occur to insure this program’s future success.

8 responses to “Meaningful Use Rules Hit the Streets”

  1. Hi John,

    Nice coverage of the MU definitions. I extracted the actual required objectives and measures for both eligible providers and for eligible hospitals from the CMS proposed rule and posted them at our Web site. Since I’m not sure of the etiquette on your blog, I won’t provide direct links to them unless you invite me to. Or you can feel free to link to those yourself, if you find them valuable.

    Happy New Year,


    • John says:

      Happy New Year to you Jack.

      As to etiquette of the Chilmark Research blog, I will, upon request allow others to post links to other stories and sites if it helps inform the broader community and is not simply some form of veiled or even blatant advertisement. Therefore, please feel free to post links to your publication’s site that provides the lists of the actual measures which physicians/hospitals will need to demonstrate to achieve meaningful use and subsequently receive reimbursement.


  2. Hello John:

    I agree with you that most solo physicians do not have time for 500+ pages. However, most of us are aware of the basic. I think it is all over the healthcare provider’s community now, including MD24 Physicians Network.

    Thanks for educating my mentor/advisor, Keith Stoneback, the other day.

    Lastly, I believe most EHR platforms are too general and expensive for ROI. You should check out the http://www.worldvista.com community (Clarification: I have no incentive link here :-)). It is moving forward, next conference 1/10.


  3. […] Article John Moore, Chilmark Research, 31 December 2009 SHARETHIS.addEntry({ title: "Meaningful Use Rules Hit the Streets", url: "http://articles.icmcc.org/2010/01/01/meaningful-use-rules-hit-the-streets/" }); […]

  4. Well they said it’d be out at the end of 2009, I guess they weren’t kidding!

  5. John and all,

    Here are the links to the “meaningful use” criteria that I abstracted from the CMS beast.

    For eligible providers, see the criteria here:

    For eligible hospitals, see the criteria here:


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