Meaningful Use Clarification for Emergency Department Measures
For over a decade, ACEP has shared in the national goal of creating a patient focused healthcare system that maximizes quality, safety, efficiency, and effectiveness.1 ACEP believes widespread adoption of connected, interoperable, and secure electronic health records (EHRs) is foundational to achieving this goal. Such systems must be capable of securely and confidentially delivering complete and accurate data to the emergency physician and patient when and where it is needed. ACEP further believes it is critical that emergency physicians be involved at all levels to ensure that standards optimally support emergency care, that emergency department information systems (EDIS) are designed to enhance rather than frustrate the care process, and that emergency physicians play a prominent role in EDIS selection, implementation, training, and operation.
ACEP has been an active participant in efforts to define and implement pertinent aspects of the HITECH (Health Information Technology for Economic and Clinical Health) Act, which was an important component of the American Recovery and Reinvestment Act (ARRA) of 2009. ACEP participated in the comment period following release of the Meaningful Use Stage 1Notice of Proposed Rule Making (MU1-NPRM)2, expressing concern that incentives to deploy EHRs and HIT in the emergency department (ED) were inadvertently excluded. The Centers for Medicare and Medicaid Services (CMS) addressed these concerns in the Meaningful Use Stage 1Notice of Final Rule Making (MU1-NFRM)3. However, in so doing, CMS inadvertently created requirements that added significant new work that was of minimal value to the care of low-complexity patients who were treated and released after ED care. CMS recently responded to these concerns through a Frequently Asked Question (FAQ)4 that has also generated significant comment.
ACEP believes clarifications contained in the FAQ5 strike a reasonable balance between encouraging hospitals to implement computerized provider order entry (CPOE) and other EHR functionalities in the ED and providing hospitals and EDs with the flexibility needed to qualify for Stage 1 – Meaningful Use (MU-1) incentive payments. By excluding treated and released ED patients from the numerator and denominator of MU measures, CMS has maximized the opportunity to acquire clinically important data while minimizing the negative impact of marginally useful documentation. ACEP looks forward to working with Office of the National Coordinator for Health IT (ONC) and CMS on the implementation of MU-1 and the development of MU-2 and MU-3 measures and performance standards. To achieve true meaningful use, it is important that emergency physicians play in integral role in all aspects of the process.
1 "Health Information Technology", approved by the ACEP Board of Directors August 2008 replacing the policy, "Internet Access" that was rescinded August 2008 Revised and approved by the ACEP Board of Directors titled, "Internet Access" February 2003 Originally approved by the ACEP Board of Directors titled, "Internet Access" October 1998
2 Federal Register Vol 75, No.8, January 13, 2010, pages 2014-2047.
3 Federal Register Vol 75, No.144, July 28, 2010, pages 44314-44588.
5 defines denominator as all patients admitted to the hospital from all locations or placed in observation unit and numerator as all patients receiving a specified service in either the ED, observation unit, or inpatient unit