The Centers for Medicare & Medicaid Services (CMS) issued its draft definition for the “meaningful use” of electronic health records (EHRs) today as part of its notice of proposed rulemaking (NPRM).  The NPRM describes the proposed implementation of incentives to providers for the adoption and meaningful use of certified EHRs.  This NPRM from CMS kicks off a 60-day public comment period to help inform its development of the final 2011 meaningful use criteria.

Closely linked and also issued today from the Office of the National Coordinator for Health Information Technology (ONC) is an interim final rule (IFR) on Standards & Certification Criteria.  The IFR provides details on requirements for “certified” EHR systems, and what technical specifications are needed to support secure, interoperable, nationwide electronic exchange and meaningful use of health information.  The standards and certification criteria in the IFR are specifically designed to support the 2011 meaningful use criteria.

As part of the rulemaking process, the Standards & Certification Criteria IFR will go into effect 30 days after publication.  There will be an opportunity for public comment for 60 days from publication, after which the rule will be finalized.

There have been a number of opportunities for stakeholders to weigh in as meaningful use criteria and the standards and certification criteria have evolved.  These rulemaking processes attempt to take into account the input to date.  The resulting language in both the NPRM and the IFR should therefore seem familiar to many of you.  But the public now has another opportunity to offer useful suggestions before they are finalized.

Of course, meaningful use as defined for 2011 and the standards and certification criteria to support it are but the first major steps in a continuing process.  These criteria will set a level of expectation for what can be achieved today and in the near future through the adoption and use of a certified EHR system.  We fully expect that, over time, as needs and technologies evolve, the expectations can evolve as well.  We will learn, and the use and value of EHRs in medical practice will continue to improve.  That’s one benefit of the kind of learning health care system we can enable through the appropriate use of health information exchange.

Our next steps begin with you.  Your input on the draft meaningful use definition and standards and certification criteria during these open public comment periods is essential to informing the final regulations due to be published in spring 2010.  There is a formal process for submitting your comments available at:

• Click here to submit comments on the Meaningful Use NPRM during the 60-day comment period
• Click here to submit comments on the Standards & Certification Criteria IFR during the 60-day comment period

All submissions will be considered and a compilation of this input will be posted to http://www.regulations.gov.

Your perspectives are important as we all play a different role in the delivery of care.  Whether you are a provider, technologist, administrator, caregiver, researcher, patient, consumer, or other member of the health care community, your input is valuable as we all work together to provide patient-centered, quality health care.

We also hope you will use this blog to start a dialogue about meaningful use, and how we can leverage this important concept, and the specific incentives, to strengthen patient care.

— David Blumenthal, M.D., M.P.P. – National Coordinator for Health Information Technology