Untangling the CMS proposed rules on EMR “meaningful use.”
Friday, January 29th, 2010Just when you thought you had it down, you need another skill set–legal eagle. Untangling the proposed rules by the CMS for meaningful use of EMRs is a challenge that would best the best of ‘em! Here’s a quick and dirty take on the latest rules set out by the Center for Medicare and Medicaid Services EMR Incentive program, from Jan 13.
Points of interest:
- sections apply to both inpatient and outpatient providers/hospitals.
- EMRs must contain problem lists which CMS notes : “Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®. We believe the term ”problem list” requires additional clarification. We describe a ”problem list” as a list of current and active diagnoses as well as past diagnoses relevant to the current care of the patient. “
- EMRS should contain active medications
- EMRs should contain active allergies
- EMRs should have CPOE (!)
- EMRs must note if a patient smokes(amongst other requirements.)
- Patients must have access to copy of electronic health record
- Providers must have a way to share electronically with other providers.
- Providers will get incentive money based on the percentage of medicaid/medicare charges submitted by the physician. Therefore, if you have a high percentage of medicare patients you will get more incentive money.
Wow! The last two requirements open a huge can of worms: the questions of interoperability (how to share a record with a provider that doesn’t have the same EMR) comes up, as well as concerns for patient privacy.
What would I do if I was in the market for an EMR? Honestly, I would carefully examine the amount of medicare/medicaid patients my practice has. If I had a large amount of these patients, and actively saw them, it may be worth while to go after incentive money to get an EMR. However, if you have a small population of these patients, your incentive may be little to none. The entire program is slated to go away in 2016, with decreasing incentives available each year. However, the incentives don’t get smaller until 2012, so it would pay to be diligent in researching your population and careful in your selection of EMR.
The CMS rules were tough reading. Please let me know if you have a different interpretation!
Click here for the link to the PDF from CMS.
