Definitions of Meaningful Use Do Not Define Exactly What Must Be Done

Meaningful Use vs meaningful useMeaningful Use vs meaningful use

William A. Hyman
Professor Emeritus, Biomedical Engineering
Texas A&M University,

As readers of HITECH Answers know, Meaningful Use (MU) is a set of requirements for EHR certification and utilization under the CMS incentive payment program for adoption of EHRs. The carrot of incentives will in turn be replaced by the stick of reduced payments to providers who do not adopt certified EHRs and achieve MU. MU is not static as it is being developed through t least three Stages. We currently are in Stage 2, with Stage 3 under discussion. Because MU is part of the incentive program, what constitutes MU is the exclusive domain of the federal government requirements. In this regard MU may or may not coincide with other general or specific notions of meaningful use (mu). In fact in some cases it might be argued that at least some required MU is in fact not meaningful in terms of patient outcomes. And it comes with a compliance burden. At a minimum there has not been much if any demonstration that specific MU requirements actually result in improved outcomes. There have been a few studies that claim to have demonstrated that EHR use can be effective but these usually have a weak if any control group. Furthermore there may be meaningful uses of an EHR that are not part of MU, i.e. beneficial uses that the provider does not get MU credit for because those uses are not specifically required.

MU does have a broad general definition which is using a certified EHR to “improve quality, safety, efficiency, and reduce health disparities, engage patients and family, improve care coordination, and population and public health, and maintain privacy and security of patient health information”. The MU value proposition is also generically described: “Ultimately, it is hoped that the meaningful use compliance will result in better clinical outcomes, improved population health outcomes, increased transparency and efficiency, empowered individuals, and more robust research data on health systems”. The use here of the term “hoped” is perhaps curious. Is “hoped” less than “expected”? Moreover if it turns out that this hope is not realized, all the EHR money will already have been spent.

While the overall definitions of MU is of interest, it does not define exactly what must be done. This is where the applicable Stage core and menu objectives come into play. While it does make sense for the government to strictly define what it is that must be in place in order for those eligible to receive incentive payments, any such set of specific requirements is likely to have a mixture of the good, bad and indifferent, despite public input and comment periods. An alternative might have been to allow an individual to attempt to attest to the general definition rather than the detailed specifics, i.e. to establish their own fundable mu. This would have the challenge of perhaps being even more demanding on the part of the claimant, and on the government reviewers, and might lead to uneven and arbitrary results. Instead we have a more-or-less clear set of requirements as well as their measures (e.g. percentage of patients communicating electronically), with an assumed value meeting them. Maybe there could have been one “other” that allowed for a brief assertion of a non MU mu, but such is not the case.

Fortunately non MU mu is not precluded, so there is still opportunity to be creative in finding EHR applications that make sense in a local or wider environment.