UPDATE: Who knows what HHS is up to, but the original links I had for these documents were moved and/or taken down. So, I found some new links, but the new links have different page numbers. Although, all it looks like HHS did was reformat it with a smaller font and cut it into multiple parts. I wonder if this is just them trying to lower the number of pages since the PR they got for the initial documents was so bad. Looks like there are more of essentially the same documents on Regulations.gov where you can provide feedback on the proposed rules.
As I’ve suggested in my previous posts, I’m planning to do some future blog post analysis of the Meaningful Use Interim Final Rule that was recently released by ONC. However, I can’t help but comment on the amount of legalese (is that even a word) that surrounds these types of regulations. The meaningful use interim final rule (PDF of rule) is 556 pages long. The “Standards & Certification Interim Final Rule: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology” (PDF of rule) otherwise known as the EHR certification requirements is a mere 136 pages.
Yep, that’s a full 692 pages. Granted much of it can quickly be ignored (ie. the glossary, background, etc). However, it’s no wonder that it takes so long to do anything in government if it’s going to take 692 pages to digest what needs to be done. I’m sure there’s a ton of background to why this is the way it is but it’s really quite sad.
Of course, that’s probably why a site like mine will be of benefit to readers. Hopefully I can take those 692 pages and help to summarize the important details and what it will mean to those interested in the EMR stimulus. I also won’t be shy in linking to other people who provide great summaries of the HITECH act. If you know of any, let me know as well so we can all learn and grow together.
Until then, feel free to take a look at ONC/HHS pages on meaningful use and certified EHR. ONC still hasn’t posted the details on EHR certification bodies. So, don’t go looking for that. Much more to come.
Finally, 2 interesting quotes I heard recently (paraphrased):
“Whether you like the health care reform or not, it’s been amazing at how much more educated we are about the legislative process thanks to health care reform.”
I think this is also true in regards to the HITECH act EMR stimulus money.
“It’ll be a great year decade for the EMR consultants….”
Oh dear. Wishful thinking, I’m sure, but any chance David Blumenthal’s office is working on a summary of say, 30 -50 pages to be produced soon? Someone who subscribes to your blog, John (or you?), may know him and could inquire/request?
Eunice,
I’m pretty sure we won’t be getting a simplified version from ONC. Probably some legal issues if they try to summarize it. That’s why it’s so long I’m sure.
[…] Does this scare anyone else? First, you have to wonder what those people are doing on the committee. Second, you have to ask if the committee (who should be well educated on these subjects) has a challenge understanding their recommendations how are busy doctors going to do with the regulations? Doctors must be so excited to go through the 692 pages of Meaningful Use regulations. […]
I agree. And will this slow the adoption of EMRs even more? Those of us who provide EMR services were looking forward to moving ahead quickly to help doctors out with EMR recommendations and support in 2010, but now….
Eunice,
Considering the wait for the details of this legislation basically brought EHR adoption to a stand still, then I think we can expect EHR adoption to finally come out of the grid lock and a number of places to implement an EHR.
Certainly many will be trying for the stimulus money. Especially larger organizations that can afford to wade through the bureaucracy. However, I think a number of smaller clinics will also start adopting for reasons other than the stimulus money.
Just how relevant is “interim final”?
If an organization does not know that it’s own efforts will surpass the Meaningful Use missive, the fault lays with their leadership, not the requirements.
Paul,
Well, “interim final” is the government term that they use while it’s open for public comment. Then, they’ll make it final. What’s weird for me is that it’s enforceable 30 days after, but is open for comment for 60 days. Government work.
I’m not sure I agree that leadership should be judged so harshly if they choose not to meet meaningful use. The fact is that meaningful use as defined by HITECH is different than what a practice defines as meaningful use (see this previous post: https://www.healthcareittoday.com/2009/12/22/arra-ehr-stimulus-bill-benefits/ ).
What’s up with this part of the interim final rule?
“We have decided to proceed with a separate notice and comment rule making (which we anticipate publishing shortly after this interim final rule) to establish the policies for the certification of HIT and the process a certification body will need to follow to become an
authorized certification body, as determined by the National Coordinator.”
Isn’t this the most important part?
“Interim Final” is slang for the new 40.
Steve,
That’s always been the plan to have 2 different rules. One for “meaningful use” and one for “certified EHR.” Meaningful use had a strict deadline of the end of the year. Certified EHR didn’t have such a deadline. Thus the result.
I’m not sure one is more important than the other. They’re both going to be required and both will take some work by the EMR vendor and the clinic to achieve.
Well said John.
I’m a vendor trying to get a grasp on how CMS will certify an EHR. Can you be certified without paying one of the authorized bodies. It’s cost prohibitive to become certified through CCHIT.
I was hoping that if you are a CMS approved EHR vendor for reporting on PQRI and eRx then you show meaningful use. Here’s a link from CMS:
http://www.cms.hhs.gov/PQRI/20_AlternativeReportingMechanisms.asp#TopOfPage
Steve,
I’m quite sure that you’ll have to be a certified vendor. However, it does look like there will be options besides CCHIT to meet the “certified EHR” criteria. The only question is, how much will these other certifying bodies cost? It’s too early in the process for them to give a price tag since HHS hasn’t finalized what will be required of the certifying bodies.
I don’t think the PQRI approval will mean much of anything as far as access to the HITECH money.
I think that if a physician is e-prescribing and
using a registry to report electronically for certain PQRI measures then they are showing meaningful use. I guess I should add this during the comment period?
John, forgive me for being off topic, but I have a question and think you either know the answer or can point me to it.
With hospitals and ARRA, the max refund I’ve seen is between $2.4-2.6 million. If it is a hospital chain, is there a multiplier effect for the number of hospitals/clinics? I don’t think there is. Do you know with any certainty?
Steve,
You should add it. Seems like they have made meaningful use complicated. Something like what you suggested is more reasonable. Although, many have had troubles meeting the PQRI measures as well.
Paul,
I haven’t seen anything addressing that in what I’ve read. However, I’m far from an expert on hospitals. I focus more on ambulatory clinics.
[…] good job listing the 25 meaningful use objectives in a simple to read format. Much better than the 692 pages of Meaningful Use and Certified EHR information HHS put out. Here’s the 25 Meaningful Use Objectives you’ll need to meet to get the EMR […]
[…] not guaranteeing that YOU will get the money. You are still responsible for understanding the 692 pages of Meaningful Use documentation to make sure you’re using all your EMR’s features that will get you the EMR stimulus […]
[…] chunk out sections of the regulations that really matter. I remember my shock when I heard that the Meaningful Use regulation was 692 pages. Then, as I looked at the regulation, I realized that there were really only a small number of […]
[…] For example, they chunk out sections of the regulations that really matter. For example, the Meaningful Use regulation…it has 692 pages. By using HCPro, you will know that there are really only a small number of pages in the middle […]