A Meaningful End to “Meaningful Use?”

The era of meaningful use came to a relatively quiet end this summer with the release of the Final Inpatient Prospective Payment Systems rule by the Center for Medicare and Medicaid Systems (CMS) this past August. The rule put into place most of what had been in the proposed rule earlier in the year. Although the rule has much detail on what healthcare organizations must achieve to receive incentive payments and/or avoid penalties, a large symbolic change is the renaming of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs now be called Promoting Interoperability Programs. The "meaningful use" moniker goes away, although under the new program, eligible professionals and hospitals still must demonstrate they are "meaningful users" of health information technology.

As someone who had a front-row seat in meaningful use and how it impacted the informatics world (in my case more teaching about it than being in the trenches implementing it), it is the end of an era that brought our field to national visibility. There is some success to be celebrated by the fact that 96% of hospitals and 85% of office-based clinicians have adopted some form of EHR. Overall, the new rules seem logical and fair, although some would argue that incentive payments should be based more on outcomes than process measures. In any case, there is still important work ahead as we step up to challenge to making EHR systems better and leveraging the data in them to truly benefit health and healthcare.

Unlike in the past, when summaries of the updates were released with great fanfare by multiple sources, there are few summaries of the new rule that provide enough content to understand the details without having to read the hundreds of pages in the government publication. Two good sources I have found are:

• AMIA - https://www.amia.org/sites/default/files/FY19-IPPS-Final-Rule-Detailed-Summary.pdf
• Healthcelerate - https://www.healthcelerate.com/s/Healthcelerate-Promoting-Interoperability-Guide_August-2018.pdf

The meaningful use moniker for the criteria for eligible professionals went away last year with the introduction of the new CMS Quality Payment Program (QPP) that integrated all previous federal quality programs into a single quality-payment program, with 25% of inventive payment or penalty tied to Advancing Care Information (ACI). The ACI changed from a so-called threshold (all or none) approach to a performance (score-based) one. The ACI portion of QPP is now also renamed as being part of the Promoting Interoperability Program.

The new CMS rule now applies a similar approach to eligible hospitals. The new rule groups Promoting Interoperability into four overall objectives, each of which has one or more measures and a maximum number of points for achieving them. The new rule also streamlines some of the quality reporting measures required by the program as well as limits the reporting period to one quarter of the year.

A final change in the new rule is the requirement that systems use the 2015 Edition Certified EHR Technology (CEHRT) criteria to be eligible for the program. One key requirement of the 2015 CEHRT edition is the implementation of an application programming interface (API) that can (with appropriate authentication and security) access data directly in the EHR. Most vendors are implementing this capability using the emerging Fast Healthcare Interoperability Resources (FHIR) standard. Probably the best-known (but certainly not the only) application of this is the Apple Health app that allows patients to download the so-called Argonaut data set of 21 data elements.

The new Promoting Interoperability measures include:
1. e-Prescribing (1 required, 2 optional measures in 2019 that will be required in 2020)

• e-Prescribing
• Query of Prescription Drug Monitoring Program (PDMP)
• Verify Opioid Treatment Agreement

2. Health Information Exchange (2 required measures)

• Support Electronic Referral Loops by Sending Health Information
• Support Electronic Referral Loops by Receiving and Incorporating Health Information

3. Provider to Patient Exchange (1 required measure)

• Provide Patients Electronic Access to Their Health Information

4. Public Health and Clinical Data Exchange (2 required measures from following)

• Syndromic Surveillance Reporting
• Immunization Registry Reporting
• Electronic Case Reporting
• Public Health Registry Reporting
• Clinical Data Registry Reporting
• Electronic Reportable Laboratory Result Reporting

The final rule contains a table of the above with the scoring algorithm for the measures. The official details of the new program are at:
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/

It is hard not to wax somewhat nostalgic about these changes, especially in this blog that started about the time of the introduction of the Health Information Technology for Clinical and Economic Health (HITECH) Act that seems like eons ago. Although the goal was not just to put computers into hospitals and clinicians’ offices, that is an accomplishment and hopefully lays the foundation for improving healthcare and leveraging data going forward.