Both the meaningful use and health IT standards and certification proposed rules officially appeared in the Federal Register March 7, which automatically launched the countdown for public comments for 60 days. The public may comment on the proposed rule online through May 6.

The Centers for Medicare and Medicaid Services published the requirements for meaningful use of electronic health records Stage 2, while the Office of the National Coordinator for Health IT published the 2014 Edition of standards and certification. Both agencies expect to release their final rules during the summer.

The proposed rules highlight the question of what is the most effective way to use EHRs, said Farzad Mostashari, MD, the national health IT coordinator. The systematic review of research evidence shows that EHRs have the ability to give providers the tools and the power to effectively improve quality and reduce cost, he said at the March 7 meeting of the advisory Health IT Policy Committee.

“Appropriately, the conversation is now focused on how will we use the progress in health IT to make effective use of these tools, and I see meaningful use as just another tool,” he said.

Mostashari said that some providers were effectively using EHRs, while others viewed meaningful use requirements as a checklist just to qualify for incentive payments. For example, EHRs may collect data on smoking status, but then the provider has to open a separate form to collect smoking status the meaningful use way in order to qualify for the incentives.

“No wonder providers are saying that meaningful use is adding work and not making sense to them. We have a lot of learning to make meaningful use of meaningful use,” he said.

For Stage 2 of meaningful use, there is a lot of staying the course from Stage 1 “because it just takes time for vendors, providers, for us all to make the most meaningful use of the tools that we have,” he said.

Robert Anthony, a specialist from the CMS Office of E-Health Standards and Services, discussed some aspects of the Stage 2 proposed rule. Although not set in stone yet, CMS is trying to align reporting of clinical quality measures for meaningful use with other quality programs, such as the Physicians Quality Reporting System (PQRS) and accountable care organizations (ACOs), in time for 2014 when Stage 2 takes effect.

To align them, CMS is exploring the use of the same measures for different program measure sets and identify ways to minimize multiple submission requirements and methods, he said. Doing so will reduce the administrative burden for providers and establish and harmonize what the data exchange priorities are across all the quality measurement programs.

“It may not be down to a single submission for everything but we’re proposing something that I think is pretty close,” Anthony said.

The clinical quality measures from Stage 1 will remain the same through 2013. Providers may continue to report them by attestation through the CMS website or through 2012 electronic reporting pilots, which have been extended to 2013 while CMS develops technology for 2014 for electronic submission.

In 2014, CMS is proposing reporting clinical quality measures that are only for the EHR incentive program through an aggregate XML-based file format specified by CMS and that EHRs could generate. 

For measures that are aligned for meaningful use and PQRS, a submission through PQRS would “essentially be deemed as having submitted meaningful use measures for the EHR incentive program,” he said. Other options for group reporting, such as the Medicare Shared Savings Program, would also serve as qualifying for the EHR incentive program, Anthony said.