Final MU Objectives: Electronic Health Information, Discharge Instructions, Timely Electronic Access, Clinical Summaries, Educational Resources
This is the fifth in a series of hospital-focused summaries of the final Stage 1 meaningful use objectives and measures. The goal of these entries is to support rural community hospital personnel in their efforts to meet specific meaningful use objectives. Notations marked “implications…” are my interpretations, which may or may not be correct.
Objectives # 1-16 were covered in previous blogs.
Objective #17: Provide Patients with Electronic Copy of Health Information (Core Set)
The proposed “provide patients with electronic health information” objective for EPs was: “Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication list, allergies) upon request.” And for hospitals was: “Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication list, allergies, discharge summary, procedures), upon request.”
The final “provide patients with electronic health information” objective for EPs is: “Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies) upon request.” And for hospitals is: “Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies, discharge summary, procedures), upon request.”
CMS supporting language: “We limit the information that must be provided electronically to that information that exists electronically in or accessible from the certified EHR technology and is maintained by or behalf of the EP, eligible hospital, or CAH.” Additionally, subject to certain potential withholdings (45 C.F.R 164.524), “an EP, eligible hospital, or CAH should provide a patient with all of the health information they have available electronically. At a minimum, this would include, the elements listed in the ONC final rule.” Additionally, “the media could be any electronic form such as patient portal, PHR, CD, USB fob, etc. … [providers] are expected to make reasonable accommodations for patient preference as outlined in 45 CFR 164.522(b).”
The objective must be achieved using certified EHR technology as defined in the final certification rule. The definition of “ability to provide patients with an electronic copy of their health information” in the final certification rule is:
For EPs, “Electronic copy of health information: Enable a user to create an electronic copy of a patient’s clinical information, including, at a minimum, diagnostic test results, problem list, medication list, and medication allergy list in: (1) Human readable format; and (2) On electronic media or through some other electronic means in accordance with: (i) The standard (and applicable implementation specifications) specified in §170.205(a)(1) or §170.205(a)(2); and (ii) For the following data elements the applicable standard must be used: (A) Problems. The standard specified in §170.207(a)(1) or, at a minimum, the version of the standard specified in §170.207(a)(2); (B)Laboratory test results. At a minimum, the version of the standard specified in §170.207(c); and (C) Medications. The standard specified in §170.207(d).”
For Hospitals, (1) Enable a user to create an electronic copy of a patient’s clinical information, including, at a minimum, diagnostic test results, problem list, medication list, medication allergy list, and procedures: (i) In human readable format; and (ii) On electronic media or through some other electronic means in accordance with: (A) The standard (and applicable implementation specifications) specified in §170.205(a)(1) or §170.205(a)(2); and (B) For the following data elements the applicable standard must be used: (1) Problems. The standard specified in §170.207(a)(1) or, at a minimum, the version of the standard specified in §170.207(a)(2); (2) Procedures. The standard specified in §170.207(b)(1) or §170.207(b)(2); (3) Laboratory test results. At a minimum, the version of the standard specified in §170.207(c); and (4) Medications. The standard specified in §170.207(d). (2) Enable a user to create an electronic copy of a patient’s discharge summary in human readable format and on electronic media or through some other electronic means.
ONC supporting language: “… in order to meet this certification criterion, Certified EHR Technology must be able to generate an electronic copy that is in human readable format and as a CCD or CCR. If Certified EHR Technology is capable of generating one copy that could meet both of these requirements, we would consider that to be a compliant implementation of this capability.”
Implications of the above: Community hospital information systems (HIS) may face some challenges in meeting the electronic health information standards specified in the ONC final certification rule. Providers should verify that existing vendors can (or at least are working to) meet the certification and standards requirements as defined.
The proposed “provide patients with electronic health information” measure for EPs and hospitals was: “At least 80% of all patients who request an electronic copy of their health information are provided it within 48 hours.”
The final “provide patients with electronic health information” measure for EPs and hospitals is: “More than 50% of all patients of the EP or the inpatient or emergency departments of the eligible hospital pr CAH (POS 21 or 23) who request an electronic copy of their health information are provided it within 3 business days.”
The ability to calculate the measure will be included in the certified EHR technology as a certification requirement. (“We believe that as long as the request by the patient is accurately recorded in the certified EHR technology then the certified EHR technology should be able to calculate the measure.”)
The Denominator is: “The number of patients of the EP or eligible hospital’s or CAH’s inpatient or emergency departments (POS 21 or 23) who request an electronic copy of their electronic health information four business days prior to the end of the EHR reporting period.” (The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology).
The Numerator is: “The number of patients in the denominator who receive an electronic copy of their electronic health information within 3 business days.”
The Threshold is: “The resulting percentage must be more than 50% in order for an EP, eligible hospital, or CAH to meet this measure.”
Exclusion: “If the EP, eligible hospital, or CAH has no requests from patients or their agents for an electronic copy of patient health information during the EHR reporting period they would be excluded from the requirement.”
Objective #18: Provide Patients with Electronic Copy of Discharge Instructions (Core Set: for hospitals only)
The proposed “provide patients with electronic discharge instructions” objective for hospitals was: “Provide patients with an electronic copy of their discharge instructions and procedures at time of discharge, upon request.”
The final “provide patients with electronic discharge instructions” objective is: No change: finalized as proposed.
“The term ‘instructions’ means any directions that the patient must follow after discharge to attend to any residual conditions that need to be addressed personally by the patient, home care attendants, and other clinicians on an outpatient basis.”
CMS supporting language: “The media could be any electronic form such as patient portal, PHR, CD, USB fob, etc. EPs, eligible hospitals and CAHs are expected to make reasonable accommodations for patient preference as outlined in 45 CFR 164.522(b)”
The objective must be achieved using certified EHR technology as defined in the final certification rule. The definition of “provide patients with electronic discharge instructions” in the final certification rule is: “Electronic copy of discharge instructions. Enable a user to create an electronic copy of the discharge instructions for a patient, in human readable format, at the time of discharge on electronic media or through some other electronic means.”
Implications of the above: Community hospital information system (HIS) vendors generally engage in contractual relationships with discharge instruction vendors such as ExitCare, Logicare, Micromedix, and others to provide clients with discharge instruction functionality. Providers should identify their HIS vendor’s strategy for discharge instruction vendor certification (will they be certifying together for a “complete EHR” designation, and/or will the discharge instruction vendor be certifying their product as a “modular EHR?”). Providers should also verify that existing discharge instruction system vendors can (or at least are working to) meet the certification requirements as defined.
The proposed “provide patients with electronic discharge instructions” measure for hospitals was: “At least 80% of all patients who are discharged from an eligible hospital and who request an electronic copy of their discharge instructions and procedures are provided it.”
The final “provide patients with electronic discharge instructions” measure is: “More than 50% of all patients who are discharged from an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) and who request an electronic copy of their discharge instructions and procedures are provided it.”
The ability to calculate the measure will be included in the certified EHR technology as a certification requirement. (“We believe that as long as the request by the patient is accurately recorded in the certified EHR technology then the certified EHR technology should be able to calculate the measure.”)
The Denominator is: “Number of patients discharged from an eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) who request an electronic copy of their discharge instructions and procedures during the EHR reporting period.” (The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology).
The Numerator is: “The number of patients in the denominator who are provided an electronic copy of discharge instructions.”
The Threshold is: “The resulting percentage must be more than 50% in order for an EP, eligible professional, or CAH to meet this measure.”
Exclusion: “If the eligible hospital or CAH has no requests from patients or their agents for an electronic copy during the EHR reporting period they would be excluded from this requirement.”
Objective #19: Provide Patients with Timely Electronic Access (Menu Set: for EPs only)
The proposed “timely electronic access” objective for EPs was: “Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, and allergies) within 96 hours of the information being available to the EP.”
The final “timely electronic access” objective for EPs is: “Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP.”
CMS supporting language: “We believe we inadvertently created confusion by listing the examples of electronic media (CD or USB drive) in which this access could be provided. As many commenters inferred, it was our intention that this be information that the patient could access on demand such as through a patient portal or PHR.”
The objective must be achieved using certified EHR technology as defined in the final certification rule. The definition of providing timely electronic access in the final certification rule is: “Timely access. Enable a user to provide patients with online access to their clinical information, including, at a minimum, lab test results, problem list, medication list, and medication allergy list.”
Implications of the above: EPs will need to implement a certified vendor’s patient portal or PHR functionality in order to comply with this menu set objective.
The proposed “timely electronic access” measure for EPs was: “At least 10% of all unique patients seen by the EP are provided timely electronic access to their health information.”
The final “timely electronic access” measure is: “At least 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified technology) electronic access to their health information subject to the EP’s discretion to withhold certain information.”
“Unique patient” means that if the patient is seen more than once during the reporting period, he or she only counts once in the denominator.
CMS supporting language: “…we define the four business days as the time frame when the information is updated in the certified EHR technology to when it is available electronically to the patient, unless the provider indicates that the information should be withheld. It is acceptable for a provider to set an automated withhold on certain information at their discretion.”
The ability to calculate the measure will be included in the certified EHR technology as a certification requirement.
The Denominator is: “Number of unique patients seen by the EP during the EHR reporting period.”
The Numerator is: “The number of patients in the denominator who have timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information online.”
The Threshold is: “The resulting percentage must be at least 10% in order for an EP to meet this measure.”
Exclusion: “If an EP neither orders nor creates any of the information listed in the ONC final rule … for this objective during the EHR reporting period they would be excluded from this requirement.”
Objective #20: Provide Clinical Summary for each Office Visit (Core Set: for EPs only)
The proposed “clinical summary: objective (for EPs) was: “Provide clinical summaries for each office visit.”
The final “clinical summary” objective is: No change: finalized as proposed.
CMS definitions: “An office visit is defined as any billable visit that includes: 1) Concurrent care or transfer of care visits, 2) Consultant visits and 3) Prolonged Physician Service without Direct (Face-To-Face) Patient Contact (telehealth). A consultant visit occurs when a provider is asked to render an expert opinion/service for a specific condition or problem by a referring provider.” Additionally, “we define clinical summary as an after-visit summary that provides a patient with relevant and actionable information and instructions containing, but not limited to, the patient name, provider’s office contact information, date and location of visit, an updated medication list and summary of current medications, updated vitals, reason(s) for visit, procedures and other instructions based on clinical discussions that took place during the office visit, any updates to a problem list, immunizations or medications administered during visit, summary of topics covered/considered during visit, time and location of next appointment/testing if scheduled, or a recommended appointment time if not scheduled, list of other appointments and testing patient needs to schedule with contact information, recommended patient decision aids, laboratory and other diagnostic test orders, test/laboratory results (if received before 24 hours after visit), and symptoms.”
CMS supporting language: “The EP could choose any of the listed means from the proposed rule of PHR, patient portal on a web site, secure email, electronic media such as CD or USB fob, or printed copy. If the EP chooses an electronic media, they would be required to provide the patient a paper copy upon request. Both forms can be and should be produced by certified EHR technology.”
The objective must be achieved using certified EHR technology as defined in the final certification rule. The definition of providing clinical summary functionality in the final certification rule is: “Clinical summaries. Enable a user to provide clinical summaries to patients for each office visit that include, at a minimum, diagnostic test results, problem list, medication list, and medication allergy list. If the clinical summary is provided electronically it must be: (1) Provided in human readable format; and (2) Provided on electronic media or through some other electronic means in accordance with: (i) The standard (and applicable implementation specifications) specified in §170.205(a)(1) or §170.205(a)(2); and (ii) For the following data elements the applicable standard must be used: (A) Problems. The standard specified in §170.207(a)(1) or, at a minimum, the version of the standard specified in §170.207(a)(2); (B)Laboratory test results. At a minimum, the version of the standard specified in §170.207(c); and (C) Medications. The standard specified in §170.207(d).”
The proposed “clinical summary” measure for EPs was: “Clinical summaries provided to patients for at least 80% of all office visits.”
The final “clinical summary” measure is: “Clinical summaries provided to patients for more than 50% of all office visits within 3 business days.”
The ability to calculate the measure will be included in the certified EHR technology as a certification requirement.
The Denominator is: “Number of unique patients seen by the EP for an office visit during the EHR reporting period.” (The only patients that are included in the denominator are those patients whose records are maintained using certified EHR technology).
The Numerator is: “The number of patients in the denominator who are provided a clinical summary of their visit with three business days..”
The Threshold is: “The resulting percentage must be more than 50% in order for an EP to meet this measure.”
Exclusion: “EPs that have no office visits during the EHR reporting period are excluded from this requirement…”
Objective #21: Patient Specific Educational Resources (Menu Set)
The discussed (but not proposed) “patient specific educational resource” objective for EPs and hospitals was: “Provide access to patient specific education resources upon request.”
The final “patient specific educational resource” objective for EPs and hospitals is: “Use certified EHR technology to identify patient-specific educational resources and provide those resources to the patient if appropriate.”
The objective must be achieved using certified EHR technology as defined in the final certification rule. The definition of “patient specific educational resource” functionality in the final certification rule is: “Patient-specific education resources. Enable a user to electronically identify and provide patient-specific education resources according to, at a minimum, the data elements included in the patient’s: problem list; medication list; and laboratory test results; as well as provide such resources to the patient.”
ONC supporting language: “We clarify that we do not specify how Certified EHR Technology must be used to provide such resources to a patient. That is, such resources could be printed out, faxed, or emailed.”
The proposed “patient specific education resource” measure for EPs and hospitals was: Not Applicable.
The final “patient specific education resource” measure is: “More than 10% of all unique patients seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) are provided patient specific educational resources.”
“Unique patient” means that if the patient is seen more than once during the reporting period, he or she only counts once in the denominator.
The ability to calculate the measure will be included in the certified EHR technology as a certification requirement.
The Denominator is: “Number of unique patients seen by the EP or admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) during the EHR reporting period.”
The Numerator is: “The number of patients in the denominator who are provided patient education specific resources.”
The Threshold is: “The resulting percentage must be more than 10% in order for an EP, eligible hospital, or CAH to meet this measure.”
Exclusion: There are no exclusions.
