The long awaited “Meaningful Use” (MU) Final Rule for EHR Incentives through the HITECH Act was released yesterday—all 864 pages.  This is the rule issued by Centers for Medicare and Medicaid Services (CMS) in response to the Notice of Proposed Rulemaking (NPRM) that ADA provided comments to back on March 15, 2010.  This Final Rule outlines what “eligible providers” (EP)—those who qualify for the incentive payments-- must accomplish to receive incentive payments for EHR adoption through the HITECH Act. 

At present, Registered Dietitians (RD) are not included in the list of EPs.  The same holds true for Social Workers, Physical Therapists, Occupational Therapists, etc.  What is refreshing about this rule is the hint that perhaps additional health care workers should be added to the list of Eligible Providers.  While I approach this with guarded optimism, it is certainly a nice acknowledgement of the “health care team” approach from CMS.  I’ll add details based upon our comments shortly—the early impression by leaders following HITECH is that CMS and the Office of the National Coordinator (ONC) struck a reasonable middle ground for this first Phase of Meaningful Use—providing EP with the capability to report on and accomplish what best represents their abilities for the present. 

Keep in mind that this first phase is the starting point and more robust, refined guidance will occur in the next two phases of the HITECH Act (2013, and 2015).  This final rule allows a great amount of work to begin.  More to come!