WASHINGTON Requirements for making "meaningful use" of an electronic health records system can't be too onerous, or physicians will be discouraged from buying and using an EHR, Dr. Neil Calman said at a health information technology meeting convened by the Department of Health and Human Services.

Under the Recovery Act, formally known as the American Recovery and Reinvestment Act, $19 billion in stimulus money has been set aside to encourage adoption of health information technology, including electronic health records (EHRs). The money includes $44,000 in financial incentives for each physician who purchases a certified EHR system and makes "meaningful use" of it by 2011; physicians who adopt EHRs later will also get an incentive, but the amount will diminish gradually over several years and disappear completely after 2014. Providers who have not adopted EHRs by 2015 will see reductions in their Medicare reimbursement.

To put the law into effect, the government has to define "meaningful use." A health information technology (HIT) Policy Committee will make recommendations for the definition; the actual regulations will be written by staff members at the Centers for Medicare and Medicaid Services (CMS).

At a recent meeting, HIT Policy Committee member Anthony Trenkle, director of the CMS Office of E-Health Standards and Services, said that the agency plans to issue draft regulations at the end of the year, with 60 days for a comment period. The final regulations are slated to be issued early next year.

The committee heard a preliminary report from the meaningful use subgroup, which outlined its suggestions for meaningful use requirements in 2011, 2013, and 2015 (see box). Committee members expressed varying opinions on whether the requirements were too few or too many.

"This is a very aggressive model," said Gayle Harrell, a former Florida state legislator. She described her recent visit to a Florida health system where administrators estimated it would take 3 years to install a computerized order entry system in its 35 clinics. "My great concern is that this is going to be difficult to achieve."

But Dr. Calman, who also serves on the committee, disagreed. "I don't think we should base our policy on what one organization is doing," he said. Dr. Calman is president and CEO of the Institute for Family Health, Bronx, New York. "We have lots of models [that have worked more efficiently] and we should focus on that."

David Lansky, Ph.D., of the Pacific Business Group on Health, said he would favor accelerating implementation of a small number of items, such as clinical decision support, from 2013 to 2011. "For 2013, we would [show that we have] a full slate of stringent requirements, so people know what's coming," he said. For example, physicians who don't purchase a system until 2014 would have to make sure their system met the meaningful use requirements for both 2011 and 2013.

The committee needs to be aware of how such changes would affect providers who adopt EHRs in later years, according to Dr. Calman.

"We're creating another incentive for people to adopt early," he said. Not only do the incentives get smaller and smaller, but the bar gets higher and higher over time. "If that's what we want to do, that's OK, but we ought to be conscious of that."

In reality there are two timelines: The first is based on what we'd like our delivery system to be able to do and the second is based on what somebody may be able to achieve in the first year or the second year, he said.

Proposed Definition Requirements by Year

In 2011:

▸ Capturing and sharing data. This encompasses maintaining a current problem list, maintaining an active medication list, recording vital signs, and incorporating test results into the EHR.

▸ Using computerized physician order entry (CPOE) for all types of orders. This includes electronic prescribing and similar functions, such as drug allergy and formulary checks.

▸ Managing patient populations. This begins with generating lists of patients sorted by condition and sending patient reminders as needed.

In 2013:

▸ Improving quality, safety, and efficiency. This involves using evidence-based order sets, implementing clinical decision support at the point of care, and reporting information to an external disease registry.

▸ Engaging patients and families. This includes offering patient-provider electronic messaging, documenting family medical history, and uploading data from home monitoring devices.

▸ Ensuring privacy and protecting security. This involves using de-identified data when reporting population-wide health information.

In 2015:

▸ Improving population and public health. This includes using data derived from EHRs, automating real-time patient surveillance, and generating ad hoc quality reports.

▸ Coordinating care. Accessing comprehensive patient data from available sources.

▸ Continue to engage patients and families. This is expanded to include providing access to a personal health record with data from the EHR, providing patients with self-management tools, and receiving electronic data on patients' experience of care.

Source: June 2009 HIT Policy Committee

HHS Getting Closer to Defining EHR's 'Meaningful Use'