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CMS Meaningful Use Rules, Part 2

In part 1, we introduced the different stages of meaningful use criteria as defined by CMS in their final rules, released July 13, 2010. Many practices and hospitals breathed a collective sigh of relief on the one hand, as several criteria had thresholds that were less onerous than were originally proposed. It seems that CMS has been listening.

Thresholds for CPOE and e-Prescribing

For example, as we mentioned earlier, the threshold for meeting criteria for CPOE (computerized physician order entry) is now set at 30%. This means that only 30% of unique patients (not total patient visits) need to have at least one order entered into the electronic medical record system to meet those goals.

Another example is electronically transmitted prescriptions or e-Prescribing. Originally set at 75% of “permissible prescriptions”, this has been dropped to “at least 40%”. This was due in part to objections that (1) some pharmacies are not quite ready to accept e-Prescribing and (2) some patients insist on getting a paper prescription.

Structured Data vs Unstructured Data

Along the subject of prescriptions, an active medication list must be maintained on patients (with the default threshold of at least 80% of unique patients) in the form of “structured data”. Structured data refers to data that can be identified by the EMR system. In other words, if the word ‘aspirin’ is entered into a note, the EMR system has no way of knowing that that is a medication. Most, if not all, EMR systems have a medication module that allows medications to be entered as structured data. This is the only way the system can check for drug allergies and drug-drug interactions. Note that only one medication needs to be on this list to meet the criteria.

For specific criteria on each Core Set and Menu Set objectives, there are slight variations on the threshold – e.g., at least 50% of patients requesting an electronic copy of their records must receive them within 3 business days, at least 40% of lab results are entered as structured data, at least 50% of unique patients have smoking status recorded, at least 20% of unique patients are sent a reminder after their visit, etc. Due to objections raised by practices in managed care programs, some objectives such as “Submit claims electronically” and “Check insurance eligibility electronically” are being put on hold for now.

Here is a nice graphic from the New England Journal of Medicine (July 13, 2010, David Blumenthal, M.D., M.P.P., and Marilyn Tavenner, R.N., M.H.A.) on the Core Set Objectives and Menu Set Objectives as well as a brief overview of the rules.




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