Meaningful Use Definition - Updated

Congrats to the committee for quickly getting input and continuing to evolve this hotly debated area. Here is the link to the updated matrix on "Meaningful Use Definition":
http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_10741_876940_0_0_18/Meaningful%20Use%20Matrix%2007162009.pdf

Some of the clarifications they note:
1 The HIT Policy Committee recommends that incentives be paid according to an “adoption year” timeframe rather than a calendar year timeframe. Under this scenario, qualifying for the first-year incentive payment would be assessed using the “2011 Measures.” The payment rate and phaseout of payments would follow the calendar dates in the statute, but qualifying for incentives would use the “adoption-year” approach. [Extra info: a ppt slide clarifies latest year to start adoption is 2014, and in that case, max amount of incentive would be $24,000 rather than $44,000].

2 CPOE requires computer-based entry by providers of orders (medication, laboratory, procedure, diagnostic imaging, immunization, referral) but electronic interfaces to receiving entities are not required in 2011

3 Race and ethnicity codes should follow federal guidelines (see Census Bureau)

Things I like
- Implement one clinical decision rule relevant to high clinical priority: That provides value, is realistic with most EMRs, and ideally "gets the ball rolling". Of course, this depends on what they allow as a "clinical decision rule"


Things that worry me:
- Provide patient access to electronic health information: very few EMRs do that now, and yet they moved it up to 2011 ("Year One" measures) - that seems to be wishful thinking.
- % of all medications entered into EHR as generic, when generic options exist in the relevant drug class: I have no idea how one would measure that, and furthermore- it is not very realistic. For example, I presribe a lot of meds with their brand name, but check off "may substitute" - so the patient can make the final choice as to whether they want the generic. Also, to be honest- it's a lot easier to manage a med list made up of brnad names than generic ones!
- Does ePrescribing mean prescriptions transmitted electronically?: I continue to be baffled as to whether this will truly be a requirement as compared to just creating the Rx via an EMR. Specifically, if I create a prescription online (which implies it is electronic and I do get clinical decision support/alerts) and then print it for the patient - shouldn't that be good enough at least to start with? Why insiste that I also have to send it via EDI to a pharmacy - especially in a world where patients don't always know where they want it sent, and not all pharmacies support this process yet. I do some occasional eRx transmittals, and I've gotten upset calls from some patients because the pharmacy truly does not understand the concept (usually, they have the IT, they don't have the training).
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Link to full text of HITECH bill:
http://www.opencongress.org/bill/111-s350/text