Are Meaningful Use criteria ‘too many and too high’?

Are the 25 criteria for achieving Meaningful Use of Certified Electronic Health Records (EHRs) “too many and too high”? That is the complaint voiced at the Regional Healthcare Stimulus Exchange Conference by several large hospital systems – Catholic Healthcare West (CHW), Intermountain Healthcare and Kaiser Permanente.

Each of these integrated delivery systems have implemented massive, legacy EHR systems in their hospitals. They have also made hospital-based decisions to choose and push ambulatory EHRs out to their affiliated physicians (with variable ability of interfacing those ambulatory EHRs with the hospital’s systems). They have spent millions – even billions – installing and maintaining these systems. Their EHRs are from CCHIT-certified vendors. And they find that their systems are unable to achieve the 25 criteria needed in order to access Meaningful Use stimulus moneys, defined in ARRA/HITECH, by 2011.

Ambulatory physician practices stand to gain up to $44,000 in bonus payments through Medicare or Medicaid, paid out from 2011 to 2015, and thereafter risk payment reductions if they have not demonstrated meaningful use of a certified EHR after 2015. There has been considerable speculation as to whether this is enough to offset the costs of EHR implementation, particularly if the system is an expensive, locally-installed client/server system. Larger groups and hospital-centered systems have often followed that path, and are facing the expensive challenge of patching things together in order to demonstrate Meaningful Use in all 25 categories (26 categories on the hospital side).

On the other hand, hospitals stand to gain considerably more money from EHR stimulus payments than ambulatory physicians. A typical 275 bed hospital would be eligible for approximately $6 million in HITECH bonus money. And if the federal guidelines are not met by 2015, hospitals face reductions in Medicare reimbursement. Small wonder that hospital systems are the source of the loudest voices of concern over the proposed Meaningful Use rules.

From a theoretical standpoint, the hospital systems at the conference supported the general direction of interoperability and interconnectivity that is the underlying vision of the ONC. However, burdened by massive proprietary systems (built, by design, to be self-contained and all-encompassing, and not interoperable with outside, competitive, systems via agreed-upon standards), the uphill climb is costly and slow. Ironically, Richard Roth (of CHW) is quoted as stating “there’s a deep need for a lower-cost EMR in the $30 to $40 per month range; we’d love to see that level of innovation coming from health IT vendors” – reminder point here: Practice Fusion is free.

A very valid point was made at the conference, however – Meaningful Use should not be all-or-nothing. Efforts made by individual ambulatory physicians (our focus), or by hospital systems for that matter (the focus of many in the industry), should be “given credit” for the work that is done. There should be a system of proration, so that if, say, 18 of the 25 criteria of Meaningful Use are demonstrated by a given physician, then 18/25 of the stimulus money available are then paid out.

This criteria-by-criteria proration is a very reasonable approach that will encourage the progressive adoption of EHR technology (which is the goal, after all), rather than overwhelm physicians and result in throwing up one’s hands and giving up. We encourage CMS, who is still reviewing these proposals during the 60-day Open Comment period, to consider this recommendation.


Robert Rowley, MD
Chief Medical Officer, Practice Fusion, Inc.