We will build on these objectives as we graduate through Stage 2 and 3 of the transition process. These objectives are part of a coherent, longer-range plan for EHR adoption and meaningful use. We identified the objectives that constituted meaningful use in Stage 1.In our final regulations, I believe HHS achieved the needed balance: From the beginning, this process was aimed at achieving the right balance – a balance between the need to achieve effective and rapid adoption of EHRs throughout the United States and at the same time to be realistic about the challenges facing providers on the road to meaningful use. To understand this two-part approach, we need to look back to the development of the meaningful use regulations. Possession means having a legal right to access and use, at the provider’s discretion, all of the Stage 1 functions of a fully-certified system – but it does not imply that the provider must fully implement every one of these functions. So even though a provider has the option of deferring some objectives during Stage 1, the EHR system in the provider’s possession must be certified against all functions. But as also stated in our final regulations, we require EHR systems themselves be certified against all criteria adopted by the Secretary.That means providers have flexibility to stage their adoption and implementation of EHRs in sync with their plans to defer certain menu set objectives. As stated in our final regulations, providers are given the flexibility to defer as many as five “menu set” objectives during Stage 1 and still achieve meaningful use. But we should make it equally clear that our policy has not changed: The new FAQ is meant to clarify this two-part requirement. “Today on our FAQ page, we are posting a revised Question and Answer regarding an issue that has recently caused confusion in our meaningful use regulations: namely, the flexibility that providers have to defer performance on some Stage 1 meaningful use objectives and how that squares with the requirement that providers must nonetheless possess fully-certified EHR systems. National Coordinator for HIT David Blumenthal, M.D.Ī letter from National Coordinator for Health IT David Blumenthal, M.D.:
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