Meaningful Use and Electronic Medical Records for the Gastroenterology Practice

Abstract

Because we know that spiraling healthcare costs are crushing families and businesses alike, we're taking the most meaningful step in years towards modernizing out healthcare system. It's an investment that will take the long overdue step of computerizing America's medical records, to reduce the duplication and waste that costs billions of healthcare dollars and medical errors that cost thousands of lives each year…1President Barack Obama. February 17, 2009.Google ScholarThe American Recovery and Reinvestment Act, Health Information Technology for Economic and Clinical Health ActOn February 17, 2009, President Barack Obama signed public law 111-5, the American Recovery and Reinvestment Act (ARRA),2Pub L No. 111-5. American Recovery and Reinvestment Act of 2009.http://www.gpo.gov/fdsys/pkg/PLAW-111publ5/content-detail.htmlGoogle Scholar a stimulus bill intended to lift the American economy out of recession. An important component of the ARRA is the Health Information Technology for Economic and Clinical Health (HITECH) Act, created in an effort to stimulate the Medical Community to accept and incorporate electronic health records (EHRs) into their practices and to use these applications to promote best practices, with a national health information network as the desired end result.In addition to establishing the Office of the National Coordinator for Health Information Technology, the ARRA funded HITECH with an estimated 17 to 19 billion dollars in incentive funds for eligible hospitals and providers that adopt EHR technology before 2015. As shown in Table 1,3Interim Final Rule: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.Fed Regist. 2010; 75: 2014-2047Google Scholar the potential Medicare incentives for physicians are significant, totaling $44,000 per eligible professional who adopts an approved EHR by 2012.Table 1Maximum Total Amount of EHR Incentive Payments for a Medicare EPAdoption yearMaximum payment, $PFS penalty201120122013201420152016Total201118,00012,000800040002000044,000201218,00012,00080004000200044,000201315,00012,0008000400039,000201412,0008000400024,0002015−1%2016−2%2017+−3%PFS, Provider Fee Schedule. Open table in a new tab The Act provides that eligible providers (EPs) who are meaningful EHR users during the relevant EHR reporting period are entitled to an incentive payment amount equal to 75% of the Medicare allowed charges for covered professional services furnished by the EP during the relevant payment year, subject to an annual limit.Who Is an Eligible Professional?To qualify for incentive funds, one must be an EP. This is defined as a physician (either an MD or DO) who participates in either the Medicare and/or the Medicaid programs. An EP must choose to participate under either the Medicare or Medicaid incentive, not both; and physician assistants and nurse practitioners are not eligible as an EP under the Medicare incentive.The incentives do not apply to hospital-based physicians, defined as “Professionals who furnish substantially all services in a hospital setting (inpatient or outpatient) using facilities and equipment of the hospital,”2Pub L No. 111-5. American Recovery and Reinvestment Act of 2009.http://www.gpo.gov/fdsys/pkg/PLAW-111publ5/content-detail.htmlGoogle Scholar because such professionals generally are expected to use the EHR system of that hospital.The Rules: Interim Final Rule and Notice of Proposed RulemakingOn January 13, 2010, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology published a coordinated set of regulations establishing the requirements for eligible providers (EPs) and eligible hospitals to earn Medicare and Medicaid EHR incentives. Under the regulations, qualified hospitals and professionals earn the incentives, in the form of enhanced Medicare and Medicaid reimbursement, by demonstrating that they are “meaningful users” of “Certified EHR Technology.”The Interim Final Rule3Interim Final Rule: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.Fed Regist. 2010; 75: 2014-2047Google Scholar regulations contain the standards, implementation specifications, and certification criteria that EHR technology must meet to be a Certified EHR Technology. In the Notice of Proposed Rulemaking (NPRM),4Notice of Proposed Rule: Medicare and Medicaid Programs: Electronic Health Record Incentive Program.Fed Regist. 2010; 75: 1844-2011Google Scholar the CMS proposed a set of regulations containing criteria for showing meaningful use (MU) of the certified EHR technology. The NPRM defined 3 distinct stages of MU and included proposed Medicare and Medicaid regulations for the calculation and payment of the HITECH Act's incentives. The incentives are higher in the earlier years to encourage early adoption of EHR technology, and by mid-decade to convert into penalties for nonadopters.Meaningful UseTo understand the requirements of MU, it is important to understand the vision and priorities as outlined by the NPRM.VisionThe vision of the NPRM is to enable significant and measurable improvements in population health through a transformed health care delivery system.PrioritiesThe priorities of the NPRM are as follows: (1) to improve quality, safety, efficiency, and reduce health disparities; (2) to engage patients and their families; (3) to improve care coordination; (4) to improve population and public health; and (5) to ensure privacy and security protections for PHI.Definition of Meaningful UseMU is described in the Act as follows: (1) use of “Certified EHR technology in a meaningful manner” (which for physician incentives shall include the use of e-prescribing); electronic exchange of health information to improve the quality of care such as promoting coordination of care; and reporting on clinical quality measures (which shall become more stringent over time).Thus, to comply with MU, an EP must be using a Certified EHR that shows the ability to share information with others involved in the care or management of the patient, one that must have the ability to transmit quality data to central registries.Stages of Meaningful UseMU will be phased in over 3 stages. Stage one, which begins in 2011, is concerned predominantly with EPs capturing clinical data in an electronic format and initiating quality reporting. In 2013, stage 2 expands with the addition of Decision Support, and stage 3 adds Clinical Outcomes MU criteria in 2015 (Figure 1).Components of Stage 1 of Meaningful UseThe required components of MU in stage 1 include the following: (1) use of a Certified EHR, as defined in the Interim Final Rule; (2) the ability to participate in Health Information Exchanges; and (3) Quality Measure Reporting.Component 1: Certified EHRA certified EHR is a Complete EHR or a combination of EHR Modules, which has to show that it has been tested and certified in accordance with the certification program established by the National Coordinator. Although Certification up until now has been voluntary and largely performed by the Certification Commission for Healthcare Information Technology, it is anticipated that other certifying agencies will develop in the future.A Qualified EHR is an electronic record of health-related information that includes patient demographic and clinical health information, such as medical history and problem lists, and has the capacity to do the following: (1) to provide Clinical Decision Support; (2) to support Computerized Physician Order Entry; (3) to capture and query information relevant to health care quality; and (4) to exchange electronic health information with, and integrate such information from other sources.The bottom line is that gastroenterology practices should be using a certified EHR. If a practice currently has an EHR, is it MU certified? If it is not, what plans does your vendor have to get certified? If you have not yet migrated to an EHR, then one should be chosen from a company that is certified.Component 2: Health Information ExchangeUnder MU, EHRs must have the ability to exchange data with each other in a structured format. This means that scanned documents or PDFs of laboratory data will no longer be acceptable; they must be transmitted in separate fields (ie, hemoglobin, hematocrit, white blood count, and so forth). To be compliant in stage 1, an EP must certify that 50% of all data transmitted is done so in structured format. Transmission of health information must be able to be structured not only to other providers but to patients and government agencies as well.In the NPRM, 25 proposed objectives and measures were identified for physicians. Examples are shown in Table 2.Table 2Examples of Objectives and MeasuresStage 1 EP objectiveStage 1 EP measureGenerate and transmit permissible prescriptions electronically (eRx)At least 75% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technologyIncorporate clinical laboratory test results into EHR as structured dataAt least 50% of all clinical laboratory tests ordered whose results are in a positive/negative or numeric format are incorporated in certified EHR technology as structured dataMaintain active medication allergy listAt least 80% of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data Open table in a new tab Component 3: Quality ReportingQuality measures that will be reported can be summarized as follows: (1) measures of processes, experience, and/or outcomes of patient care; (2) observations or treatments that relate to one or more quality aims for health care such as effective, safe, efficient, patient-centered, equitable, and timely care; and (3) preference is given to clinical quality measures endorsed by the National Quality Foundation, including National Quality Foundation–endorsed measures that have been selected previously for the Physician Quality Reporting Initiative program.The proposed measures fall into 2 categories: a Core Group, which is to be reported by all physicians, and a Specialty Group. The HITECH Act did not require the use of National Quality Foundation–endorsed measures, or limit the measures to those included. The Core Measures are shown in Table 3.Table 3Core Quality MeasuresPreventive care and screening: inquiry regarding tobacco useBlood pressure measurementDrugs to be avoided in the elderly Patients who receive at least 1 drug to be avoided Patients who receive at least 2 different drugs to be avoided Open table in a new tab The following Specialty Quality Measures were proposed for Gastroenterology. Under the NPRM, all of these measures would need to be reported for the physician to indicate compliance with MU (Table 4).Table 4Gastroenterology-Specific Quality MeasuresClinical quality measure title and descriptionHepatitis C: antiviral treatment prescribedHepatitis C: counseling regarding risk of alcohol consumptionPreventive Care and Screening: colorectal cancer screeningHepatitis C: Hepatitis A vaccination in patients with HCVHepatitis C: Hepatitis B vaccination in patients with HCVEndoscopy and Polyp Surveillance: colonoscopy interval for patients with a history of adenomatous polyps – avoidance of inappropriate use Open table in a new tab Submitting Quality MeasuresThere are several potential routes to report quality information including the following: (1) using a CMS portal to upload output from your certified EHR module; (2) submit the required clinical quality measures data using certified EHR technology through Health Information Exchange/Health Information Organizations; and (3) accept submission through registries. The American Gastroenterological Association's Digestive Health Outcomes Registry (Bethesda, MD) will allow gastroenterology practices to submit their information for quality reporting.Noting that the earlier-described functions may not be available immediately, the NPRM has stated, “We do not anticipate that HHS will complete the necessary steps for us to have the capacity to electronically accept data on clinical quality measures from EHRs for the 2011 payment year … Therefore, for 2011, we propose that EPs and eligible hospitals use an attestation methodology to submit summary information to CMS on clinical quality measures as a condition of demonstrating meaningful use of certified EHR technology.”4Notice of Proposed Rule: Medicare and Medicaid Programs: Electronic Health Record Incentive Program.Fed Regist. 2010; 75: 1844-2011Google ScholarIn 2011, the EHR reporting period is any continuous 90-day period within a payment year. In subsequent years, the EHR reporting period must be the entire calendar year. CMS expects to move to electronic reporting starting with stage 2 in 2013.What Does This Mean for Gastroenterologists?▪The vision of integrated practice, clinical safety, appropriate care, and elimination of waste can be achieved with well-designed electronic health records and processes of care;▪Meaningful use is a game changer—maybe greater than Y2K or The Health Insurance Portability and Accountability Act (HIPAA);▪Detailed planning, change management, and process change, not just functionality, will be required by practices;▪Meaningful use will necessitate a fundamental change to clinician processes such as common tasks of documenting care during a visit;▪Quality measurement must become a byproduct of care and documentation.What Should Gastroenterologists Do Now?Gastroenterologist should adopt certified EHR technology, achieve meaningful use objectives, and apply for the incentive payment.The HITECH Act is the law now. It is not part of health care reform. The train has left, and it is incumbent for gastroenterology practices to be on it. EHR adoption and MU compliance will take time, so practices should choose an EHR from a company that has the ability to meet MU requirements. Because we know that spiraling healthcare costs are crushing families and businesses alike, we're taking the most meaningful step in years towards modernizing out healthcare system. It's an investment that will take the long overdue step of computerizing America's medical records, to reduce the duplication and waste that costs billions of healthcare dollars and medical errors that cost thousands of lives each year…1President Barack Obama. February 17, 2009.Google Scholar The American Recovery and Reinvestment Act, Health Information Technology for Economic and Clinical Health ActOn February 17, 2009, President Barack Obama signed public law 111-5, the American Recovery and Reinvestment Act (ARRA),2Pub L No. 111-5. American Recovery and Reinvestment Act of 2009.http://www.gpo.gov/fdsys/pkg/PLAW-111publ5/content-detail.htmlGoogle Scholar a stimulus bill intended to lift the American economy out of recession. An important component of the ARRA is the Health Information Technology for Economic and Clinical Health (HITECH) Act, created in an effort to stimulate the Medical Community to accept and incorporate electronic health records (EHRs) into their practices and to use these applications to promote best practices, with a national health information network as the desired end result.In addition to establishing the Office of the National Coordinator for Health Information Technology, the ARRA funded HITECH with an estimated 17 to 19 billion dollars in incentive funds for eligible hospitals and providers that adopt EHR technology before 2015. As shown in Table 1,3Interim Final Rule: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.Fed Regist. 2010; 75: 2014-2047Google Scholar the potential Medicare incentives for physicians are significant, totaling $44,000 per eligible professional who adopts an approved EHR by 2012.Table 1Maximum Total Amount of EHR Incentive Payments for a Medicare EPAdoption yearMaximum payment, $PFS penalty201120122013201420152016Total201118,00012,000800040002000044,000201218,00012,00080004000200044,000201315,00012,0008000400039,000201412,0008000400024,0002015−1%2016−2%2017+−3%PFS, Provider Fee Schedule. Open table in a new tab The Act provides that eligible providers (EPs) who are meaningful EHR users during the relevant EHR reporting period are entitled to an incentive payment amount equal to 75% of the Medicare allowed charges for covered professional services furnished by the EP during the relevant payment year, subject to an annual limit. On February 17, 2009, President Barack Obama signed public law 111-5, the American Recovery and Reinvestment Act (ARRA),2Pub L No. 111-5. American Recovery and Reinvestment Act of 2009.http://www.gpo.gov/fdsys/pkg/PLAW-111publ5/content-detail.htmlGoogle Scholar a stimulus bill intended to lift the American economy out of recession. An important component of the ARRA is the Health Information Technology for Economic and Clinical Health (HITECH) Act, created in an effort to stimulate the Medical Community to accept and incorporate electronic health records (EHRs) into their practices and to use these applications to promote best practices, with a national health information network as the desired end result. In addition to establishing the Office of the National Coordinator for Health Information Technology, the ARRA funded HITECH with an estimated 17 to 19 billion dollars in incentive funds for eligible hospitals and providers that adopt EHR technology before 2015. As shown in Table 1,3Interim Final Rule: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.Fed Regist. 2010; 75: 2014-2047Google Scholar the potential Medicare incentives for physicians are significant, totaling $44,000 per eligible professional who adopts an approved EHR by 2012. PFS, Provider Fee Schedule. The Act provides that eligible providers (EPs) who are meaningful EHR users during the relevant EHR reporting period are entitled to an incentive payment amount equal to 75% of the Medicare allowed charges for covered professional services furnished by the EP during the relevant payment year, subject to an annual limit. Who Is an Eligible Professional?To qualify for incentive funds, one must be an EP. This is defined as a physician (either an MD or DO) who participates in either the Medicare and/or the Medicaid programs. An EP must choose to participate under either the Medicare or Medicaid incentive, not both; and physician assistants and nurse practitioners are not eligible as an EP under the Medicare incentive.The incentives do not apply to hospital-based physicians, defined as “Professionals who furnish substantially all services in a hospital setting (inpatient or outpatient) using facilities and equipment of the hospital,”2Pub L No. 111-5. American Recovery and Reinvestment Act of 2009.http://www.gpo.gov/fdsys/pkg/PLAW-111publ5/content-detail.htmlGoogle Scholar because such professionals generally are expected to use the EHR system of that hospital. To qualify for incentive funds, one must be an EP. This is defined as a physician (either an MD or DO) who participates in either the Medicare and/or the Medicaid programs. An EP must choose to participate under either the Medicare or Medicaid incentive, not both; and physician assistants and nurse practitioners are not eligible as an EP under the Medicare incentive. The incentives do not apply to hospital-based physicians, defined as “Professionals who furnish substantially all services in a hospital setting (inpatient or outpatient) using facilities and equipment of the hospital,”2Pub L No. 111-5. American Recovery and Reinvestment Act of 2009.http://www.gpo.gov/fdsys/pkg/PLAW-111publ5/content-detail.htmlGoogle Scholar because such professionals generally are expected to use the EHR system of that hospital. The Rules: Interim Final Rule and Notice of Proposed RulemakingOn January 13, 2010, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology published a coordinated set of regulations establishing the requirements for eligible providers (EPs) and eligible hospitals to earn Medicare and Medicaid EHR incentives. Under the regulations, qualified hospitals and professionals earn the incentives, in the form of enhanced Medicare and Medicaid reimbursement, by demonstrating that they are “meaningful users” of “Certified EHR Technology.”The Interim Final Rule3Interim Final Rule: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.Fed Regist. 2010; 75: 2014-2047Google Scholar regulations contain the standards, implementation specifications, and certification criteria that EHR technology must meet to be a Certified EHR Technology. In the Notice of Proposed Rulemaking (NPRM),4Notice of Proposed Rule: Medicare and Medicaid Programs: Electronic Health Record Incentive Program.Fed Regist. 2010; 75: 1844-2011Google Scholar the CMS proposed a set of regulations containing criteria for showing meaningful use (MU) of the certified EHR technology. The NPRM defined 3 distinct stages of MU and included proposed Medicare and Medicaid regulations for the calculation and payment of the HITECH Act's incentives. The incentives are higher in the earlier years to encourage early adoption of EHR technology, and by mid-decade to convert into penalties for nonadopters. On January 13, 2010, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology published a coordinated set of regulations establishing the requirements for eligible providers (EPs) and eligible hospitals to earn Medicare and Medicaid EHR incentives. Under the regulations, qualified hospitals and professionals earn the incentives, in the form of enhanced Medicare and Medicaid reimbursement, by demonstrating that they are “meaningful users” of “Certified EHR Technology.” The Interim Final Rule3Interim Final Rule: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.Fed Regist. 2010; 75: 2014-2047Google Scholar regulations contain the standards, implementation specifications, and certification criteria that EHR technology must meet to be a Certified EHR Technology. In the Notice of Proposed Rulemaking (NPRM),4Notice of Proposed Rule: Medicare and Medicaid Programs: Electronic Health Record Incentive Program.Fed Regist. 2010; 75: 1844-2011Google Scholar the CMS proposed a set of regulations containing criteria for showing meaningful use (MU) of the certified EHR technology. The NPRM defined 3 distinct stages of MU and included proposed Medicare and Medicaid regulations for the calculation and payment of the HITECH Act's incentives. The incentives are higher in the earlier years to encourage early adoption of EHR technology, and by mid-decade to convert into penalties for nonadopters. Meaningful UseTo understand the requirements of MU, it is important to understand the vision and priorities as outlined by the NPRM.VisionThe vision of the NPRM is to enable significant and measurable improvements in population health through a transformed health care delivery system.PrioritiesThe priorities of the NPRM are as follows: (1) to improve quality, safety, efficiency, and reduce health disparities; (2) to engage patients and their families; (3) to improve care coordination; (4) to improve population and public health; and (5) to ensure privacy and security protections for PHI. To understand the requirements of MU, it is important to understand the vision and priorities as outlined by the NPRM. VisionThe vision of the NPRM is to enable significant and measurable improvements in population health through a transformed health care delivery system. The vision of the NPRM is to enable significant and measurable improvements in population health through a transformed health care delivery system. PrioritiesThe priorities of the NPRM are as follows: (1) to improve quality, safety, efficiency, and reduce health disparities; (2) to engage patients and their families; (3) to improve care coordination; (4) to improve population and public health; and (5) to ensure privacy and security protections for PHI. The priorities of the NPRM are as follows: (1) to improve quality, safety, efficiency, and reduce health disparities; (2) to engage patients and their families; (3) to improve care coordination; (4) to improve population and public health; and (5) to ensure privacy and security protections for PHI. Definition of Meaningful UseMU is described in the Act as follows: (1) use of “Certified EHR technology in a meaningful manner” (which for physician incentives shall include the use of e-prescribing); electronic exchange of health information to improve the quality of care such as promoting coordination of care; and reporting on clinical quality measures (which shall become more stringent over time).Thus, to comply with MU, an EP must be using a Certified EHR that shows the ability to share information with others involved in the care or management of the patient, one that must have the ability to transmit quality data to central registries. MU is described in the Act as follows: (1) use of “Certified EHR technology in a meaningful manner” (which for physician incentives shall include the use of e-prescribing); electronic exchange of health information to improve the quality of care such as promoting coordination of care; and reporting on clinical quality measures (which shall become more stringent over time). Thus, to comply with MU, an EP must be using a Certified EHR that shows the ability to share information with others involved in the care or management of the patient, one that must have the ability to transmit quality data to central registries. Stages of Meaningful UseMU will be phased in over 3 stages. Stage one, which begins in 2011, is concerned predominantly with EPs capturing clinical data in an electronic format and initiating quality reporting. In 2013, stage 2 expands with the addition of Decision Support, and stage 3 adds Clinical Outcomes MU criteria in 2015 (Figure 1). MU will be phased in over 3 stages. Stage one, which begins in 2011, is concerned predominantly with EPs capturing clinical data in an electronic format and initiating quality reporting. In 2013, stage 2 expands with the addition of Decision Support, and stage 3 adds Clinical Outcomes MU criteria in 2015 (Figure 1). Components of Stage 1 of Meaningful UseThe required components of MU in stage 1 include the following: (1) use of a Certified EHR, as defined in the Interim Final Rule; (2) the ability to participate in Health Information Exchanges; and (3) Quality Measure Reporting. The required components of MU in stage 1 include the following: (1) use of a Certified EHR, as defined in the Interim Final Rule; (2) the ability to participate in Health Information Exchanges; and (3) Quality Measure Reporting. Component 1: Certified EHRA certified EHR is a Complete EHR or a combination of EHR Modules, which has to show that it has been tested and certified in accordance with the certification program established by the National Coordinator. Although Certification up until now has been voluntary and largely performed by the Certification Commission for Healthcare Information Technology, it is anticipated that other certifying agencies will develop in the future.A Qualified EHR is an electronic record of health-related information that includes patient demographic and clinical health information, such as medical history and problem lists, and has the capacity to do the following: (1) to provide Clinical Decision Support; (2) to support Computerized Physician Order Entry; (3) to capture and query information relevant to health care quality; and (4) to exchange electronic health information with, and integrate such information from other sources.The bottom line is that gastroenterology practices should be using a certified EHR. If a practice currently has an EHR, is it MU certified? If it is not, what plans does your vendor have to get certified? If you have not yet migrated to an EHR, then one should be chosen from a company that is certified. A certified EHR is a Complete EHR or a combination of EHR Modules, which has to show that it has been tested and certified in accordance with the certification program established by the National Coordinator. Although Certification up until now has been voluntary and largely performed by the Certification Commission for Healthcare Information Technology, it is anticipated that other certifying agencies will develop in the future. A Qualified EHR is an electronic record of health-related information that includes patient demographic and clinical health information, such as medical history and problem lists, and has the capacity to do the following: (1) to provide Clinical Decision Support; (2) to support Computerized Physician Order Entry; (3) to capture and query information relevant to health care quality; and (4) to exchange electronic health information with, and integrate such information from other sources. The bottom line is that gastroenterology practices should be using a certified EHR. If a practice currently has an EHR, is it MU certified? If it is not, what plans does your vendor have to get certified? If you have not yet migrated to an EHR, then one should be chosen from a company that is certified. Component 2: Health Information ExchangeUnder MU, EHRs must have the ability to exchange data with each other in a structured format. This means that scanned documents or PDFs of laboratory data will no longer be acceptable; they must be transmitted in separate fields (ie, hemoglobin, hematocrit, white blood count, and so forth). To be compliant in stage 1, an EP must certify that 50% of all data transmitted is done so in structured format. Transmission of health information must be able to be structured not only to other providers but to patients and government agencies as well.In the NPRM, 25 proposed objectives and measures were identified for physicians. Examples are shown in Table 2.Table 2Examples of Objectives and MeasuresStage 1 EP objectiveStage 1 EP measureGenerate and transmit permissible prescriptions electronically (eRx)At least 75% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technologyIncorporate clinical laboratory test results into EHR as structured dataAt least 50% of all clinical laboratory tests ordered whose results are in a positive/negative or numeric format are incorporated in certified EHR technology as structured dataMaintain active medication allergy listAt least 80% of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data Open table in a new tab Under MU, EHRs must have the ability to exchange data with each other in a structured format. This means that scanned documents or PDFs of laboratory data will no longer be acceptable; they must be transmitted in separate fields (ie, hemoglobin, hematocrit, white blood count, and so forth). To be compliant in stage 1, an EP must certify that 50% of all data transmitted is done so in structured format. Transmission of health information must be able to be structured not only to other providers but to patients and government agencies as well. In the NPRM, 25 proposed objectives and measures were identified for physicians. Examples are shown in Table 2. Component 3: Quality ReportingQuality measures that will be reported can be summarized as follows: (1) measures of processes, experience, and/or outcomes of patient care; (2) observations or treatments that relate to one or more quality aims for health care such as effective, safe, efficient, patient-centered, equitable, and timely care; and (3) preference is given to clinical quality measures endorsed by the National Quality Foundation, including National Quality Foundation–endorsed measures that have been selected previously for the Physician Quality Reporting Initiative program.The proposed measures fall into 2 categories: a Core Group, which is to be reported by all physicians, and a Specialty Group. The HITECH Act did not require the use of National Quality Foundation–endorsed measures, or limit the measures to those included. The Core Measures are shown in Table 3.Table 3Core Quality MeasuresPreventive care and screening: inquiry regarding tobacco useBlood pressure measurementDrugs to be avoided in the elderly Patients who receive at least 1 drug to be avoided Patients who receive at least 2 different drugs to be avoided Open table in a new tab The following Specialty Quality Measures were proposed for Gastroenterology. Under the NPRM, all of these measures would need to be reported for the physician to indicate compliance with MU (Table 4).Table 4Gastroenterology-Specific Quality MeasuresClinical quality measure title and descriptionHepatitis C: antiviral treatment prescribedHepatitis C: counseling regarding risk of alcohol consumptionPreventive Care and Screening: colorectal cancer screeningHepatitis C: Hepatitis A vaccination in patients with HCVHepatitis C: Hepatitis B vaccination in patients with HCVEndoscopy and Polyp Surveillance: colonoscopy interval for patients with a history of adenomatous polyps – avoidance of inappropriate use Open table in a new tab Quality measures that will be reported can be summarized as follows: (1) measures of processes, experience, and/or outcomes of patient care; (2) observations or treatments that relate to one or more quality aims for health care such as effective, safe, efficient, patient-centered, equitable, and timely care; and (3) preference is given to clinical quality measures endorsed by the National Quality Foundation, including National Quality Foundation–endorsed measures that have been selected previously for the Physician Quality Reporting Initiative program. The proposed measures fall into 2 categories: a Core Group, which is to be reported by all physicians, and a Specialty Group. The HITECH Act did not require the use of National Quality Foundation–endorsed measures, or limit the measures to those included. The Core Measures are shown in Table 3. The following Specialty Quality Measures were proposed for Gastroenterology. Under the NPRM, all of these measures would need to be reported for the physician to indicate compliance with MU (Table 4). Submitting Quality MeasuresThere are several potential routes to report quality information including the following: (1) using a CMS portal to upload output from your certified EHR module; (2) submit the required clinical quality measures data using certified EHR technology through Health Information Exchange/Health Information Organizations; and (3) accept submission through registries. The American Gastroenterological Association's Digestive Health Outcomes Registry (Bethesda, MD) will allow gastroenterology practices to submit their information for quality reporting.Noting that the earlier-described functions may not be available immediately, the NPRM has stated, “We do not anticipate that HHS will complete the necessary steps for us to have the capacity to electronically accept data on clinical quality measures from EHRs for the 2011 payment year … Therefore, for 2011, we propose that EPs and eligible hospitals use an attestation methodology to submit summary information to CMS on clinical quality measures as a condition of demonstrating meaningful use of certified EHR technology.”4Notice of Proposed Rule: Medicare and Medicaid Programs: Electronic Health Record Incentive Program.Fed Regist. 2010; 75: 1844-2011Google ScholarIn 2011, the EHR reporting period is any continuous 90-day period within a payment year. In subsequent years, the EHR reporting period must be the entire calendar year. CMS expects to move to electronic reporting starting with stage 2 in 2013. There are several potential routes to report quality information including the following: (1) using a CMS portal to upload output from your certified EHR module; (2) submit the required clinical quality measures data using certified EHR technology through Health Information Exchange/Health Information Organizations; and (3) accept submission through registries. The American Gastroenterological Association's Digestive Health Outcomes Registry (Bethesda, MD) will allow gastroenterology practices to submit their information for quality reporting. Noting that the earlier-described functions may not be available immediately, the NPRM has stated, “We do not anticipate that HHS will complete the necessary steps for us to have the capacity to electronically accept data on clinical quality measures from EHRs for the 2011 payment year … Therefore, for 2011, we propose that EPs and eligible hospitals use an attestation methodology to submit summary information to CMS on clinical quality measures as a condition of demonstrating meaningful use of certified EHR technology.”4Notice of Proposed Rule: Medicare and Medicaid Programs: Electronic Health Record Incentive Program.Fed Regist. 2010; 75: 1844-2011Google Scholar In 2011, the EHR reporting period is any continuous 90-day period within a payment year. In subsequent years, the EHR reporting period must be the entire calendar year. CMS expects to move to electronic reporting starting with stage 2 in 2013. What Does This Mean for Gastroenterologists?▪The vision of integrated practice, clinical safety, appropriate care, and elimination of waste can be achieved with well-designed electronic health records and processes of care;▪Meaningful use is a game changer—maybe greater than Y2K or The Health Insurance Portability and Accountability Act (HIPAA);▪Detailed planning, change management, and process change, not just functionality, will be required by practices;▪Meaningful use will necessitate a fundamental change to clinician processes such as common tasks of documenting care during a visit;▪Quality measurement must become a byproduct of care and documentation. ▪The vision of integrated practice, clinical safety, appropriate care, and elimination of waste can be achieved with well-designed electronic health records and processes of care;▪Meaningful use is a game changer—maybe greater than Y2K or The Health Insurance Portability and Accountability Act (HIPAA);▪Detailed planning, change management, and process change, not just functionality, will be required by practices;▪Meaningful use will necessitate a fundamental change to clinician processes such as common tasks of documenting care during a visit;▪Quality measurement must become a byproduct of care and documentation. What Should Gastroenterologists Do Now?Gastroenterologist should adopt certified EHR technology, achieve meaningful use objectives, and apply for the incentive payment.The HITECH Act is the law now. It is not part of health care reform. The train has left, and it is incumbent for gastroenterology practices to be on it. EHR adoption and MU compliance will take time, so practices should choose an EHR from a company that has the ability to meet MU requirements. Gastroenterologist should adopt certified EHR technology, achieve meaningful use objectives, and apply for the incentive payment. The HITECH Act is the law now. It is not part of health care reform. The train has left, and it is incumbent for gastroenterology practices to be on it. EHR adoption and MU compliance will take time, so practices should choose an EHR from a company that has the ability to meet MU requirements.