The long awaited “Meaningful Use” (MU) Final Rule for EHR Incentives through the HITECH Act was released last week by the Centers for Medicare and Medicaid Services (CMS). Although Registered Dietitians (RD) are not presently on the list of Eligible Providers (EPs)—those who qualify for the financial incentives--the dietetics profession will be significantly impacted by this ruling. As a result of health care reform, the First Lady’s “Lets Move” initiative, and the HITECH Act, the health care environment is very strongly focused on prevention, wellness and obesity. HITECH initiatives are driving standards harmonization, quality measures development and care coordination—amongst a long list of improvements.

This Rule constitutes Phase I (“Round One”) of MU—a baseline for using EHR technology to improve health outcomes.  There are three phases (2011, 2013, and 2015) of the HITECH Program—each of which will build upon the past phase in terms of potential impact on health care.  The ADA submitted detailed comments during the Open Public Comment Period for Phase 1, and was fortunate to have had multiple suggestions incorporated into this MU Final Rule by CMS.

Following are areas that will likely have the greatest impact on RDs/DTRs.

Referrals to RDs

Following ADA’s suggestion to include weight screening (BMI) as a “Core Measure” (specific patient data all EP are required to report to CMS, in order to receive incentive payments for EHR adoption), CMS added “Adult Weight Screening and Follow-up” (“PQRI 128/NQF 0421 Preventive Care and Screening: BMI Screening and Follow-up”) as one of three core measures.  The other two are blood pressure (hypertension) screening and tobacco use assessment.   It is logical to expect that this screening will generate additional referrals to RDs and—most importantly “follow-ups” with dietitians. Since the primary focus of HITECH is to improve health outcomes, weight screening and follow-up  will be an area highly evaluated with regard to the impact on individual and population health. The dietetics profession needs to be prepared for a “front and center” role as a critical team member as HITECH drives EHR adoption.

Patient Education

After much ado—and passionate input from commenters, (including ADA!) CMS was convinced to keep the following measure: - “EPs and hospitals should report on the percentage of patients for whom they use the EHR to suggest patient-specific education resources.”  CMS had alleged that there is a “paucity of knowledge resources that are integrated within EHRs, that are widely available, and that meet these criteria, particularly in multiple languages.” EHR vendors need to be aware of our recommended education resources—such as the new public section of Eatright.org.  

Improved Outcomes/Quality

In short, CMS acknowledges additional work is needed to create useful quality measures across all areas of care.  “Nutrition-related” quality measures are on the radar screen for the National Quality Forum —and are listed in the MU Final Rule as areas of future work.

Standards Development

Phase 1 requires EPs to track “medication allergies.” ADA expressed concern that “non-medication allergies”, such as food allergies should be documented and handled in the same fashion as medication allergies, as the potential adverse impact on patients is the same.  CMS responded that the ability to identify other types of allergies in a “structured data format” is not consistent to the extent necessary to require EPs  to report them to CMS in Stage 1 of meaningful use.  They encouraged commenters and vendors to continue to include this data in EHRs.  Additional work needs to be undertaken to assure a consistent method of recording food allergies and verifying that this data is transferred between providers.

The public comment period for Phase II and III will occur as the next phases for MU are developed. Let us know your thoughts by commenting on this blog!