Meaningful Use: What You Need to Know About Release of Information Requirements

According to HIMSS, meaningful use was the no. 1 priority of hospital information technology departments for 2011, and is likely to continue as a top concern. Meaningful use of certified health information technology impacts the financial incentives that healthcare providers may receive from CMS; therefore, it is important for providers to work to achieve MU. However, the criteria required for demonstrating MU can be challenging to achieve, including requirements around release of information to patients.

Qualifying for meaningful use

According to the final rule on meaningful use, which adopted an initial set of standards, implementation specifications and certification criteria for the first stage of MU objectives, eligible hospitals (EHs) and eligible professionals (EPs) must:

  • Demonstrate meaningful use of their EHR;
  • When required, use combinations of certified EHR modules or complete EHR systems to meet the meaningful use requirements.

The rule also specifies requirements for EHRs or EHR modules to achieve certification, including the ability to:

  • Capture demographic and clinical health information that provides support for clinical decisions and physician order entry;
  • Capture and query information relevant to healthcare quality; and
  • Permit the exchange of health information and integrate health information from other sources.

In addition, EHRs also must meet national standards for interoperability between other EHRs as well as governmental agencies, such as the Centers for Disease Control and immunization registries. These standards determine requirements for language and grammar for EHRs.

Release of information requirements
As it relates to the day-to-day duties of the HIM department, MU requirements are primarily focused on patients' access to electronic health information. Because this is a core objective, EHs and EPs failing to meet this objective will not be able to demonstrate MU.

Specifically, EHs and EPs must provide an electronic copy of medical records within three business days to at least 50 percent of patients who request it in that format. The HIM department must make sure there are appropriate procedures in place to meet this core objective.  

Stage One of MU is currently in effect and includes three core objectives involving release of information by an eligible hospital and two core objectives for eligible professional.

For an eligible hospital:

1.    Provide patients with an electronic copy of their own health information, upon request (EH Core Objective 11).
2.    Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request (EH Core Objective 12).
3.    Protect electronic health information (EH Core Objective 14).

For an eligible professional:

1.    Provide patients with an electronic copy of their own health information, upon request (EP Core Objective 12).
2.    Provide clinical summaries for each office visit (EP Core Objective 13).
3.    Protect electronic health information (EP Core Objective 14).

Core Objective 11 for EH and Core Objective 12 for EP
For these objectives, the requirements state that if a patient requests an electronic copy of diagnostic tests, problem lists, medication lists, allergies or procedure lists, and the information is available electronically, the EH or EP must provide a copy within three business days. According to Stage 1 of the MU requirements, both EHs and EPs must meet the threshold for this requirement 50 percent of the time.

Core Objective 12 for EH and 13 for EP

While arguably not a function of the HIM department, the requirements of Core Objectives 12 and 13 are both related to the release of medical information, specifically the discharge instructions for hospitals and the clinical summaries in the ambulatory setting. The requirements state that an electronic copy of a patient's discharge instructions or clinical summaries for the EP must be provided at the time of discharge or conclusion of clinic visit upon request. In Stage One, both EPs and EHs must meet the threshold for this requirement 50 percent of the time. In the ambulatory setting, the EP must provide the clinic summary electronically or in paper form within three business days; however, there is no clear guidance on the timeframe necessary for providing the discharge instructions information electronically for the hospital setting. Based on IOD hospital clients surveyed nationwide, the discharge instruction provision ranged from one hour up to 24 hours. IOD is awaiting clarification of the timeline from CMS.

The calculation for Core Objective 12 is expressed as a percentage of the total number of discharge instructions requested divided by the total number of records  delivered electronically to patients  discharged from the ER or inpatient setting who requested the electronic delivery.

Core Objective 13 is similar but is designed for an EP in the ambulatory care setting. This calculation is expressed as a percentage of the total number of electronic record clinic summary requests divided by the total number of delivered electronic clinic  summaries delivered within three business days to patients or patients' representatives following their clinic visit.

What factors make up 50 percent requirement for Core Objective 11?

  • Request must be made by a patient or a patient's personal representative (POA, executor, etc). All other requesters are excluded when calculating for this requirement.
  • Patient or patient’s personal representative must request delivery of an electronic copy of his/her medical records.
  • The records must be stored in a certified EHR technology (older records stored in other systems are excluded from MU calculations).
  • For hospitals, records must be either inpatient or ER service; outpatient recordsare excluded.

What factors make up the 50% requirement for Core Objectives 12 and 13?

  • Request must be made by a patient or a patient’s personal representative (POA, executor, etc). All other requesters are excluded when calculating for this requirement.
  • The records must be stored in a certified EHR technology (older records stored in other systems are excluded from MU calculations).
  • For hospitals, records must be either inpatient or ER service; outpatient records are excluded.

CMS states that the clinical summary can be delivered to the patient via a patient portal on a website, secure e-mail, CD, USB fob or printed copy. CMS has also stated that if the EP chooses an electronic media, the EP would be required to provide the patient a paper copy upon request.

Keep in mind, if the patient's visit lasts several days and the patient is seen by multiple EPs, a single clinical summary at the end of the visit can be used to meet the MU objective.

Calculating the measures
CMS addresses whether the percentage of requests released from a certified EHR and delivered in electronic format within three business days must be calculated using a certified EHR technology on its website (www.cms.gov):

Q: If data is captured using certified electronic health record (EHR) technology, can an eligible professional or eligible hospital use a different system to generate reports used to demonstrate meaningful use for the Medicare and Medicaid EHR Incentive Programs?

A: By definition, certified EHR technology must include the capability to electronically record the numerator and denominator and generate a report including the numerator, denominator, and resulting percentage for all percentage-based meaningful use measures (specified in the certification criterion adopted at 45 CFR 170.302(n)). However, the meaningful use measures do not specify that this capability must be used to calculate the numerators and denominators. Eligible professionals and eligible hospitals may use a separate, non-certified system to calculate numerators and denominators and to generate reports on the measures of the core and menu set meaningful use objectives. [emphasis added]

As you can see from the CMS answer, you may use a separate system, to calculate the numerator and denominator and generate reports on the core and menu set meaningful use objectives (which include CE 11, 12 and 13 above), therefore assisting you to track and report on these meaningful use objectives. Several release of information software systems have received meaningful use certification, including IOD's PRISM software. PRISM earned ONC-ATCB MU certification for both the ambulatory and inpatient practice type on Dec. 20, 2011.

Conclusion
While many providers and facilities have already met Stage One MU, many more are waiting to take advantage of CMS EHR incentives until they can ensure  their compliance with the stated core objectives. Providers should be careful to include HIM departments in the pursuit of MU incentives, particularly with regard to Core Objectives 11, 12, 13 and 14. These rules lay the groundwork for greater patient engagement and will continue to be an important part of the meaningful use of EHRs for many years to come.

Related Articles on Meaningful Use:

Hospitals Receive $1.8B in EHR Incentive Payments in CY 2011
ONC Outlines Five Steps for EHR Implementation

 

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