Medicare’s New Requirement for Evidence-based Order Sets

The following is a guest post by Sean Benson. Sean Benson is co-founder of ProVation Medical and Vice President of Innovation at Wolters Kluwer Health.

In-house creation and maintenance of order sets by hospital staff just got a bit more challenging.

Without much fanfare, a small but significant change to Medicare’s Conditions of Participation (CoP) for hospitals went into effect in mid-July.  The Centers for Medicare and Medicaid Services (CMS) has decreed that Medicare-participating hospitals that use order sets, pre-printed or electronic standing orders and protocols for patient orders must ensure that they are consistent with nationally recognized and evidence-based guidelines and recommendations.

To be clear, this new CoP rule does not prohibit an individual hospital from developing its own pre-printed and electronic order sets. It does define the criteria for doing so, however.  CMS expects a hospital to look to nationally recognized guidelines, which should always be evidence-based, and to its own experiences and in-house studies and data.  CMS wants hospitals to avoid using anecdotal evidence, theories that have not been proven effective, or the old fallback of ‘that’s the way we’ve always done it’ as a basis for establishing its orders and protocols.

In-house creation of order sets has always presented challenges for hospitals.  Significant staff time must be devoted to drafting individual order sets, which can number in the hundreds at some institutions.  Subsequent review and consensus-building by the appropriate clinicians can also prove burdensome and difficult.  And then there is the need to periodically check and update existing order sets to make sure they reflect best practices.

Now CMS has added the requirement that order sets be based on the latest evidence and guidelines. The sheer volume of new medical evidence scattered across hundreds of sources that must be evaluated when creating an order set – an estimated 2 million scientific articles are published each year – means compliance will be a significant drain on internal resources. It also means that flow of evidence must be continuously monitored to determine when it necessitates a change in practice and, thus, a change in one or more existing order sets.

Compliance with the new CoP requirement can readily be achieved by “going digital”.  Electronic order set authoring tools offer pre-defined templates populated with content drawn from medical reference databases that track the latest clinical advances. This streamlines creation of new order sets and maintenance of existing ones, which remain linked to the reference databases. Alerts are generated whenever new evidence or guidelines necessitate a protocol change and, in some cases, impacted order sets can be updated with a single click.

Order Set authoring tools are already being widely deployed in many hospitals seeking to achieve the Computerized Physician Order Entry (CPOE) requirements of Meaningful Use.  Hospitals that have joined new accountable care organizations are also leveraging these solutions to help promote evidence-based medicine in their care coordination efforts.  Medicare’s new CoP rule requiring evidence-based order sets offers CIOs and CMIOs with yet one more incentive to digitize the order set creation process.

About the author

John Lynn

John Lynn

John Lynn is the Founder of, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference,, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.

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