EHR must possess all meaningful use capabilities: ONC

Even as the first tranche of funds from the EHR stimulus package is set to be allocated to eligible providers, a large number of potential beneficiaries are still seeking clarity on the requirements for fulfilling the meaningful use criteria. One of the most important clarifications to come out in this regard is that the EHR systems adopted by eligible providers must be capable of fulfilling all meaningful use objectives and not just those they intend to report on.

This clarification vis-à-vis the meaningful use of EHR was made by the Office of the National Coordinator for Health IT recently against a provider’s query. ONC makes it clear that “the EHR technology in your (provider’s) possession must have been tested and certified to all applicable certification criteria adopted for the setting (ambulatory or inpatient) for which it was designed”.

This means, irrespective of the CMS directive that providers need to report on any five of ten menu meaningful use objectives along with all core criteria, the EHR should still be capable to fulfill all objectives. It further elaborates on the meaning of “applicable certification criteria” as well as what is required for the EHR technology to meet the definition of Certified EHR Technology as follows:

Step 1: Possession of Certified EHR Technology

In the context of the meaningful use of EHR, Certified EHR Technology is expected to include either the physical possession of a medium on which a certified Complete EHR or a combination of certified EHR modules resides, or a legally enforceable right by an eligible provider to access and use, at its discretion, the capabilities of a certified Complete EHR or a combination of certified EHR modules. An eligible health care provider may determine the extent to which it will implement or use these capabilities, which will not affect the provider’s “possession” of Certified EHR Technology.

Step 2: Demonstrating Meaningful Use of Certified EHR Technology

Generally stated, to claim funds from the EHR stimulus package, eligible health care providers, upon satisfying the core set objectives and measures, can choose 5 out of 10 menu set objectives and associated measures to satisfy the meaningful use Stage 1 requirements.  Consequently, the general rule is that an eligible health care provider for meaningful use of EHR must attest to having satisfied a combined 19 (eligible hospital) or 20 (eligible professionals) core and selected menu set objectives and associated measures using capabilities and standards of a Certified EHR product. Stated another way, eligible health care providers will still be able to receive an incentive payment even if they are unable to demonstrate that they meet up to 5 of the meaningful use menu set objectives and associated measures.

To gain greater clarity on all the meaningful use guidelines, providers must visit the ONC website or seek guidance from their EHR vendors.

(Source: US Department of Health & Human Services)