The revised definition is apparently more lenient to physicians than the one presented to the committee about a month ago. Among the requirements for 2011: â€¢ Implement one clinical decision support rule relevant to a specialty or a high clinical priority â€¢ Submit claims electronically to payers â€¢ Check insurance eligibility electronically when possible â€¢ Provide patients with timely electronic access to their health information â€¢ Provide patients, upon request, with an electronic copy of their discharge instructions and procedures at the time of discharge â€¢ Exchange health information where possible
Physicians will be expected to participate in the National Health Information Network by 2015, and will have to give patients access to personal health records to qualify for incentives in 2013. The PHR deadline is two years earlier than the one that was originally proposed.
Another big change from the earlier version is that physicians who apply for government subsidies for the first time after 2011 will only have to meet the 2011 criteria for meaningful use in the year when they apply. That will make it much easier for physicians who are just learning how to use their EHRs.
The government will use the recommendations in shaping its requirements for EHR incentives. HHS is expected to publish a final rule by the end of the year.
On another front, the HIT Policy Committee is also considering how EHRs should be certified for functionality. Earlier this week, it heard testimony concerning whether the Certification Commission for Health Information Technology (CCHIT) should continue to the be sole body that certifies EHRs. This is an important question, since only "qualified" EHRs--which many have interpreted as "certified"--will be eligible for government subsidies.
The committee members listened to hospital executives and others complain about the lack of interoperability among EHRs from different vendors. CCHIT chair Mark Leavitt, MD, noted that CCHIT is requiring that certified products be able to import and export the Continuity of Care Document (CCD), which includes key medical data. But he added, "There are not standardized HIEs [health information exchanges] and almost none of them is using the standardized format that the government approved."
Meanwhile, in a letter to the HIT Policy Committee's certification/adoption workgroup, an important organization of health IT professionals said that the CCHIT approach to certification should not continue. The American Medical Informatics Association stated, "We believe that highly prescriptive and detailed, one-size-fits-all requirements will ultimately be counterproductive."
CCHIT has drawn a great deal of fire of late, mainly from those who fear that continuing to raise the bar on certification criteria will cull down the health IT business to a handful of vendors that can bear the expense of continuing software development and certification fees. But I would ask CCHIT's critics the Voltairean question: If CCHIT did not exist, would it have to be invented?
A workgroup of the Health IT Policy Committee made a different suggestion on Thursday. It proposed that there be multiple certification bodies that would be designated by HHS. While criticizing CCHIT for paying "too much attention to specific features and functionality," the workgroup said that existing CCHIT-certified EHRs could be recognized by HHS as qualifying for 2011 incentives.