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Electronic Health Records – Meaningful Use, Certification, and the Regulatory Rulemaking Process
June 18, 2015
Lori Mihalich-Levin,[email protected]
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• STATUTE: American Recovery and Reinvestment Act (ARRA) of 2009 Medicare and Medicaid Incentives &
Penalties Tied to “meaningful use” (MU) of electronic
health records Must use “Certified Electronic Health Record
Technology” (CEHRT) Separate rules for hospitals vs. “eligible
professionals”• REGULATIONS: Implement the statute
A bit of history…
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• Centers for Medicare and Medicaid Services (CMS) Issues payment regulations MU Stages 1, 2, 3
• Office of the National Coordinator for Health Information Technology (ONC) Issues “Certification” regulations Focus is on standards
Two Government Agencies Involved in EHR-Related Regulatory Rulemaking
Rulemaking Process• HIT Policy and Standards Committees Advise
Agencies
• CMS and ONC issue a “proposed rule”
• Public has 60-day comment window
• CMS and ONC issue “final rule”
• For EHR regulations, NO deadlines for agency to issue final rules
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2015 Regulations: Three Proposed Rules from CMS & ONC• 2015-2017 Modifications – comments were due
June 15• MU Stage 3 – comments were due May 29• 2015 Edition Health IT – comments were due
May 29
Where are we NOW?
Proposed Stages of Meaningful Use By Payment YearFirst Payment Year for EP or Hospital
Payment Year & Stage of Meaningful Use
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020+
2011 1 1 1 2 Mod. 2 2 Mod. 2 or 3 (used to
require 3)
3 3 3
2012 1 1 2 Mod. 2 2 Mod. 2 or 3 (used to
require 3)
3 3 3
2013 1 1 Mod. 2 2 Mod. 2 or 3 (used to
require 3)
3 3 3
2014 1 1Mod. 2
2 Mod. 2 or 3 (was 2)
3 3 3
2015 1Mod. 2
1Mod. 2
1, Mod. 2, or 3 (was 2)
3 (used to permit 2)
3 3
2016 1Mod. 2
1, Mod. 2, or 3 (was 1)
3 (used to permit 2)
3 3
2017 1, Mod. 2, or 3 (was 1)
3 (used to permit 1)
3 3
2018 + 3 3 3
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2015 Edition Health IT Rule• Proposed rule addresses health disparities
• Options for social, psychological, and behavioral (SPB) data collection
• ONC sought feedback
• AAMC filed comment letter• Applauded ONC’s proposal to include
certification requirements for SPB data• Encouraged rigorous patient and community
engagement re: SPB data-collection • Offered to partner
• Next steps? Wait for final rule.