This Attachment Includes a Graphic Depiction of the Alternative Approach Recommended In

Attachment 1: Alternative Approach and Recommended Hospital Meaningful Use Objectives for 2011-2017

This attachment includes a graphic depiction of the alternative approach recommended in my comment letter and a complete list of the recommended hospital meaningful use objectives for 2011 to 2017, including recommended increases in the level of use, use of structured data, and health information exchange over time.

Alternative Approach to Defining Meaningful Use Recommendation: CMS should identify a single, expanded set of meaningful use objectives to be achieved between 2011 and 2017. Hospitals would be considered meaningful EHR users and qualify for the full EHR incentive payment if they meet a specified share of the hospital objectives in a given fiscal year. The specified share would increase over time. The payment schedule would not change. FY 14 FY 16 FY 17 • Incentive • Final year • No payment to receive incentive FY 11 - reduced FY 15 incentive payments Payment for newly payment available Program eligible • PENALTIES • Penalties • Penalties milestones Starts FY 12 FY 13 hospitals begin increase at max

FY FY FY FY FY FY FY 2011 2012 2013 2014 2015 2016 2017

CMS Proposed Stage 1 Proposed Stage 2 Proposed Stage 3 Proposal MU defined as MU defined as MU defined as MU defined as meeting AHA meeting 25% of meeting 50% of meeting 75% of substantially all of Proposal hospital objectives hospital objectives hospital objectives hospital objectives

Hospital objectives remain the same, but level of use, information exchange and use of structured data increase as available infrastructure and standards use increase

1 Attachment 1: Alternative Approach and Recommended Hospital Meaningful Use Objectives for 2011-2017

2011/2012 2013/2014 2015/2016 2017 Meet 25% (8) of: Meet 50% (17) of: Meet 75% (26) of: Meet substantially all of: < 100 beds Meet 15% (5) of: < 100 beds Meet 30% (10) of: < 100 beds Meet 60% (20) of:

1. CPOE (10% or more) 1. CPOE (10% or more) 1. CPOE (50% or more) 1. CPOE (substantially all) 2. Drug-drug/drug-allergy checks 2. Drug-drug/drug-allergy checks 2. Drug-drug/drug-allergy checks 2. Drug-drug/drug-allergy checks 3. Drug-formulary checks 3. Drug-formulary checks 3. Drug-formulary checks 3. Drug-formulary checks 4. Structured problem list 4. Structured problem list 4. Structured problem list 4. Structured problem list 5. Structured medication list 5. Structured medication list 5. Structured medication list 5. Structured medication list 6. Structured medication allergy 6. Structured medication allergy 6. Structured medication allergy 6. Structured medication allergy list list list list 7. Record demographics 7. Record demographics 7. Record demographics 7. Record demographics 8. Record vital signs 8. Record vital signs 8. Record vital signs 8. Record vital signs 9. Record smoking status 9. Record smoking status 9. Record smoking status 9. Record smoking status 10. Incorporate structured clinical- 10. Incorporate structured clinical- 10. Incorporate structured clinical- 10. Incorporate structured clinical- lab data (50%) lab data (50%) lab data (75%) lab data (subst. all) 11. Patient lists by condition 11. Patient lists by condition 11. Patient lists by condition 11. Patient lists by condition 12. 5 clinical decision support rules 12. 5 clinical decision support rules 12. 25 clinical decision support rules 12. 25 clinical decision support rules 13. Electronic copy of health 13. Electronic copy of health 13. Electronic copy of health 13. Electronic copy of health information to patients on information to patients on information to patients on information to patients on request request request request 14. Electronic copy of discharge 14. Electronic copy of discharge 14. Electronic copy of discharge 14. Electronic copy of discharge instructions and procedures at instructions and procedures at instructions and procedures at instructions and procedures at discharge, upon request discharge, upon request discharge, upon request discharge, upon request 15. Exchange key clinical 15. Exchange key clinical 15. Exchange key clinical 15. Exchange key clinical information information information (CCD) information (CCD) 16. Summary care record 16. Summary care record 16. Summary care record 16. Summary care record 17. Immunization registries 17. Immunization registries 17. Immunization registries (submit 17. Immunization registries (submit (capability) (capability) data if possible) data if possible) 18. Reportable lab results 18. Reportable lab results 18. Reportable lab results (submit 18. Reportable lab results (submit 2 Attachment 1: Alternative Approach and Recommended Hospital Meaningful Use Objectives for 2011-2017

(capability) (capability) data if possible) data if possible)

19. Syndromic surveillance data 19. Syndromic surveillance data 19. Syndromic surveillance data 19. Syndromic surveillance data (capability) (capability) (submit data if possible) (submit data if possible) 20. Conduct or review a security risk 20. Conduct or review a security risk 20. Conduct or review a security risk 20. Conduct or review a security risk analysis as required by HIPAA analysis as required by HIPAA analysis as required by HIPAA analysis as required by HIPAA and implement security updates and implement security updates and implement security updates and implement security updates as necessary as necessary as necessary as necessary 21. Use of evidence-based order sets 21. Use of evidence-based order sets 21. Use of evidence-based order sets 21. Use of evidence-based order sets (1 department) (3 departments) (5 departments) (substantially all departments) 22. Electronic medication 22. Electronic medication 22. Electronic medication 22. Electronic medication administration record (eMAR) (1 administration record (eMAR) (3 administration record (eMAR) (5 administration record (eMAR) department) departments) departments) (substantially all departments) 23. Bedside medication 23. Bedside medication 23. Bedside medication 23. Bedside medication administration support administration support administration support administration support (barcode/RFID) (1 department) (barcode/RFID) (3 departments) (barcode/RFID) (5 departments) (barcode/RFID) (substantially all 24. Record nursing assessment in 24. Record nursing assessment in 24. Record nursing assessment in departments) EHR (1 department) EHR (3 departments) EHR (5 departments) 24. Record nursing assessment in 25. Record nursing plan of care in 25. Record nursing plan of care in 25. Record nursing plan of care in EHR (substantially all EHR (1 department) EHR (3 departments) EHR (5 departments) departments) 26. Record physician assessment in 26. Record physician assessment in 26. Record physician assessment in 25. Record nursing plan of care in EHR (1 department) EHR (3 departments) EHR (5 departments) EHR (substantially all departments) 27. Record physician notes in EHR (1 27. Record physician notes in EHR (3 27. Record physician notes in EHR (5 department) departments) departments) 26. Record physician assessment in EHR (substantially all 28. Multimedia/Imaging integration 28. Multimedia/imaging integration 28. Multimedia/imaging integration departments) (e.g., X-Ray viewing) (e.g., X-Ray viewing) (e.g., X-Ray viewing) 27. Record physician notes in EHR (substantially all departments) 28. Multimedia/imaging integration (e.g., X-Ray viewing)

3 Attachment 1: Alternative Approach and Recommended Hospital Meaningful Use Objectives for 2011-2017

29. Generate permissible discharge 29. Generate permissible discharge 29. Generate and transmit 29. Generate and transmit prescriptions electronically prescriptions electronically permissible discharge permissible discharge prescriptions electronically 30. Contribute data to a PHR 30. Contribute data to a PHR prescriptions electronically 30. Contribute data to a PHR 31. Record patient preferences 31. Record patient preferences 30. Contribute data to a PHR (language, etc.) (language, etc.) 31. Record patient preferences 31. Record patient preferences (language, etc.) 32. Provide electronic access to 32. Provide electronic access to (language, etc.) patient-specific educational patient-specific educational 32. Provide electronic access to 32. Provide electronic access to resources resources patient-specific educational patient-specific educational resources 33. Reporting of RHQDAPU quality 33. Medication reconciliation across resources measures through existing settings of care (pilot) 33. Medication reconciliation across 33. Medication reconciliation across settings of care process 34. Reporting of some RHQDAPU settings of care (if possible) quality measures through EHR 34. Reporting of some RHQDAPU 34. Reporting of all appropriate quality measures through EHR RHQDAPU measures through EHR

Notes: 1. ITALICIZED objectives from the HIT PC recommendations for 2013 and 2015 2. List Excludes proposed objectives on electronic insurance verification and electronic billing in all years, and medication reconciliation in 2011/2012 only.