Reaction to the Final Rule EHR Incentives

On July 13, 2010 the Center for Medicare and Medicaid Services released their Final Rule regarding the Electronic Health Record Incentive Program, known within our industry as the definition of “meaningful use” of an EHR.

Senator Russ Feingold’s office contacted Ministry Health Care to get our reaction to the regulations. We greatly appreciate the Senator taking the time find out how such rulings impact our organization and our ability to live out our mission of improving the health of the patients we serve, especially the poor. Here is our response:

Thank you for asking for Ministry Health Care’s reaction to the Final Rule on HIT – Meaningful Use.

Our overall reaction is favorable.  While there may still be challenges associated with timing and certification, we do believe some specific comments from Ministry Health Care and others were heard and addressed in the Final Rule.

Under the Draft Rule, we viewed the Meaningful Use regulations as a disincentive, requiring too-much-too-quickly for an entire healthcare industry.  Given the changes in the Final Rule, we are re-evaluating our plans with an eye toward accelerating Electronic Health Record plans at many of our hospitals.  This is good news for our patients!

The true measure for us is Ministry Saint Clare’s Hospital in Weston.  Under the Draft Rule, Ministry was challenged just to reach Stage 1 meaningful use in Weston, where Ministry Saint Clare’s is Wisconsin’s first all-digital hospital and the only hospital in the state recognized by The Leapfrog Group as having fully implemented Computerized Physician Order Entry (CPOE) (by the way, the invitation for the Senator to visit Ministry Saint Clare’s to see this firsthand is always open).  This was a sign that the originally-proposed incentives were not rational.  Under the changes in the Final Rule, the path to Stage 1 meaningful use is more easily accomplished for Ministry Saint Clare’s: Wisconsin’s most IT-advanced hospital that has been perfecting its EHR since opening in 2005.

Likewise, Ministry Medical Group would not have been able to easily achieve Stage 1 meaningful use despite our project to deploy the Marshfield Clinic’s EHR (CattailsMD). We were not sure that the 1,000 Wisconsin doctors were going to be able to receive EHR incentives using that system.  Under the Final Rule, we feel there is an achievable effort to reach Stage 1 Meaningful Use, which is an incentive to start improving the system in order to meet Stage 2.

Our only significant concern at this point in time is the EHR certification process.  We are now nine weeks from the October 1, 2010 start of the EHR Incentive Program, and none of the EHR products on the market today are certified to meet Stage 1 meaningful use criteria.  As of today, ONC has yet to identify an Authorized Certification Body.

Ministry could implement the most sophisticated and beneficial Electronic Health Record in the world and still be denied EHR incentive payments due to the EHR certification requirements.  These requirements, in our opinion, have not been well defined or well conceived.  The certification process does not seem to take into consideration that a large sophisticated health system, such as Ministry, implements EHRs using a combination of commercial products and internal software development.  While no single piece of the puzzle is a certified EHR, the combination of these solutions result in an Electronic Health Record that exceeds the certification requirements.  The uncertainty over the certification process is now a much greater concern than the final meaningful use requirements.

3 thoughts on “Reaction to the Final Rule EHR Incentives

  1. “The uncertainty over the certification process is now a much greater concern than the final meaningful use requirements.”

    I completely agree with this statement! The certification process being talked about can only be useful if every organization and eligible physician can easily understand what needs to be in a “meaningfully structured” set of parameters that define the health care treatment process. The “must have” parameters must be tested in a simulated event, and then transmitted immediately to a designated secure remote depository that can confirm receipt of the record being stored for future reference purposes by authorized personnel. The e-Prescribing process is the ideal first step that should be used to validate each electronic health record being submitted for certification.


  2. I also agree with the statement that the uncertainty over the certification process is now a much greater concern than the final meaningful use requirements. Time is definitely running out to identify an Authorized Certification Body.

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