Attaining Meaningful Use (MU) is not an event, but a process. As a practical matter, MU should be organized around packages of MU criteria in a sequence that leads to achieving Meaningful Use. For example, it would not be practical to provide patients with electronic access to their patient records (MU Menu Set 5), until you maintain an electronic copy of patient health information (MU Core Measure 12).
The MU requirements associated with prescriptions include 7 different MU criteria. The centerpiece of the prescriptions is computerized provider order entry but supporting MU criteria include medication allergies, active medications and drug/drug/allergy checking. You need to implement the supporting criteria to enable computerized provider order entry. For example, prescriptions need support from the drug-drug checking before you want to post prescriptions to your EHR and send out electronic prescriptions. Otherwise, your organization may be accountable for evolving standards of care and medical professional liability expectations.
Clinical Summary –
The Clinical Summary MU Core Measure requires prescriptions as well as information related to 5 other MU Criteria. Patient problem lists, vital signs, and lab test results MU Criteria have to be satisfied before you meet the Clinical Summary Core Measure. However, the Clinical Summary includes other clinical information not derived from MU requirements including diagnostic testing and information on the patient encounter.
Compiling the Clinical Summary requires analysis and planning beyond the itemized MU Criteria. You need a clear understanding of how your EHR produces the Clinical Summary and makes Clinical Summary information available to fulfill the reporting MU Criteria. For example, immunization information is needed for the clinical summary and to report to immunization registries, but the actual entry of immunization orders and recording the immunization information is not a separate Meaningful Use Criteria.
You need a complete inventory of the Clinical Summary Requirements to assure that you gather all of the information including all diagnostic tests and treatment plan items. Such analysis is particularly important if your organization will be attesting to compliance in 2011. Note that this may be especially difficult of you need to completely satisfy the Clinical Summary requirement but not the reporting standard.
Interestingly, there are several statistical dilemmas in the MU structure. For example, Clinical Summaries have to be available to 50% of patients within 3 business days of service. However, only 40% of patients with lab test results are required to meet the Lab Test Results MU Criteria. Similarly, computerized patient order entry of prescriptions is only required for 30% of patients receiving prescriptions. Indeed, you may find it difficult to meet the Clinical Summary MU Criteria with the minimal standards in the MU critical path to produce the Clinical Summary.
Distribution and Reporting –
Once you are able to product a clinical summary, you can now fulfill 10 different MU Criteria that require information from your clinical summary. Clinical Summary information is used to produce reports, or exchange information as well as produce patient reminders from the action plan in the Clinical Summary. If the Clinical Summary is not in place, meeting MU distribution and reporting requirements may be impractical or costly.
The sequence of MU attainment and your transition have to be carefully analyzed, designed and planned. For example, a patient portal is an effective strategy to support several MU Criteria including patient reminders, providing an electronic copy of the patient’s health information, and offering electronic access to patient information. However, a practice or healthcare organization may have difficulty communicating with patients that can avail themselves of the information through the portal while not confusing patients that do not have that option.
In order to attain Meaningful Use, you can construct a critical path plan that consists of three stages and approach each stage in sequence to assure that your build the infrastructure to enable compliance with the next steps in the logical path to MU fulfillment. Otherwise, you may find yourself backtracking in your process or encountering lapses in you plan that may delay attainment of MU and your Stimulus Monies.
(c) Sterling Solutions, Ltd., 2011
(c) Sterling Solutions, Ltd., 2011