The American Reinvestment & Recovery Act (ARRA) was enacted on February 17, 2009. ARRA included many measures to modernize our nation’s infrastructure, one of which was the “Health Information Technology for Economic and Clinical Health (HITECH) Act”. The HITECH Act included the concept of electronic health records – meaningful use [EHR-MU], an effort led by Centers for Medicare & Medicaid Services and the Office of the National Coordinator for Health IT (ONC). HITECH proposed the meaningful use of interoperable electronic health records throughout the United States health care delivery system as a critical national goal.
Meaningful Use was defined by the use of certified EHR technology in a meaningful manner (for example electronic prescribing); ensuring that the certified EHR technology connects in a manner that provides for the electronic exchange of health information to improve the quality of care. By using certified EHR technology, the provider must submit to the Secretary of Health & Human Services (HHS) information on the quality of care and other measures. The concept of meaningful use rested on the five pillars of health outcomes policy priorities, namely:
- Improving quality, safety, efficiency, and reducing health disparities
- Engage patients and families in their health
- Improve care coordination
- Improve population and public health
- Ensure adequate privacy and security protection for personal health information
Historically, the program consisted of three stages:
- Stage 1 set the foundation by establishing requirements for the electronic capture of clinical data, including providing patients with electronic copies of health information.
- Stage 2 expanded upon the Stage 1 criteria with a focus on advancing clinical processes and ensuring that the meaningful use of EHRs supported the aims and priorities of the National Quality Strategy. Stage 2 criteria encouraged the use of CEHRT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible.
- In October 2015, CMS released a final rule that established Stage 3 in 2017 and beyond, which focused on using CEHRT to improve health outcomes. In addition, this rule modified Stage 2 to ease reporting requirements and align with other CMS programs.
Beginning in 2018, all eligible healthcare professionals (EPs) or eligible clinicians (ECs) previously participating in the Medicare Promoting Interoperability Program were required to report on Quality Payment Program (QPP) requirements, as mentioned in the table below-
Proposed Scoring Methodology for Quality Payment Program (QPP)***
*Source: CMS QPP Final Rule
CMS renamed the EHR Incentive Programs as the Promoting Interoperability Programs in April 2018. This change has moved the programs beyond the existing requirements of meaningful use to a new phase of EHR measurement with an increased focus on interoperability and improving patient access to health information.
Eligible entities: Eligible Professionals (EPs) and Eligible Hospitals (EHs)/Critical Access Hospitals (CAHs), treating Medicare and Medicaid patients.
Public Health Objective included in the programs: Public Health Registry and Clinical Data Registry Reporting. The specific measures included under the above objective are-
- Immunization Registry Reporting.
- Syndromic Surveillance Reporting.
- Electronic Case Reporting.
- Public Health Registries Reporting*
- Clinical Data Registries Reporting
- Electronic Reportable Laboratory Test Reporting (for Hospitals only).
*includes- a) Cancer Reporting by EPs only to State Cancer Registries. b) Reporting data by EPs and EHs/CAHs to CDC/NCHS and CDC/NHSN programs for Health Care Surveys and Antibiotic Use (AU) & Antibiotic Resistance (AR).
EHs and CAHs must attest to at least two measures from 1 through 6 above. EPs must attest to at least two measures from the Public Health Reporting Objective, Measures 1 through 5 above.
Certified Electronic Health Record Technology (CEHRT) required in 2019: 2015 edition of CEHRT.
Electronic Health Records Reporting Period (from Healthcare providers to Public Health Agencies) – 90 days in CY 2019 and onwards.