Health IT Provisions Under ARRA:
Section 3: Validation of Meaningful Use
An initial focus for meaningful use on care coordination and medication management using laboratory results, medication histories and care summaries fits well within the criteria for Medicare and Medicaid incentives under Sections 4101-2 of ARRA:
- Meaningful use of certified electronic health record (EHR) technology, including e-prescribing.
- Connections to exchange information (e.g., laboratory, medication, or radiology data) to improve quality of care, such as care coordination.
- Reporting on clinical quality metrics determined by HHS.
The goal of validation is to establish whether a certified technology was used to achieve the objectives of meaningful use. This is distinct from the process of certification, which relates to system capability. In other words, processes for "certification" ask the question: "Does the health IT system have the capability to achieve the objectives of meaningful use?" whereas processes for "validation" ask the question: "Is the provider using the technology to achieve the meaningful use?"
Therefore, the term "validation" refers to the processes to qualify clinicians and hospitals for ARRA incentives based on meaningful use of IT.
The law envisions an evolving set of validation requirements to improve health care quality over time. The approach to validating meaningful use in the three areas designated in ARRA should:
- Allow for a broad range of providers to participate through a variety of mechanisms. A range of metrics and validation mechanisms will be needed to enable a wide diversity of providers in different practice settings and with varying systems—including primary care providers, specialists and hospitals—to demonstrate meaningful use.
- Clear and achievable. The metrics and the approach used to validate them should be clear and goal-oriented, and be achievable whenever possible through automatic reporting from electronic systems to avoid creating additional unnecessary reporting burden for clinicians.
- Motivate information use to improve health, but not over-specify how to get there. The metrics should not focus on specific features and functions of technology or software, but rather on the use of information to innovate care processes that improve care coordination and medication management.
- Stimulate market innovation and "information rich" health IT adoption and use. The approach to meaningful use can motivate market innovation for the development of increasingly usable, useful, and scalable technology approaches that can be used to achieve and demonstrate health improvement goals. Innovation toward high–value, more-affordable options is critical in the small-practice market, where adoption has been the slowest, costs for IT remain high, and IT support is most lacking.
- Consider ways to discourage fraud. Early in the processes for validating meaningful use, HHS should announce efforts to detect inappropriate requests for incentive payments. For example, HHS could announce that a certain number of audits will be performed.
ARRA contemplates several mechanisms for validating meaningful use, including through attestations, submissions of claims with appropriate coding, survey responses, and other means specified by HHS.
One of the key objectives of the new HIT Policy Committee will be to help HHS set strategies for meaningful use metrics that become more stringent over time. This, in turn, will require additional standards and certification requirements that also tighten over time. This pathway must be well-defined early in the ARRA implementation process.
