Here’s my analysis of the key changes in the Final Rule:

As we have recently stated,  HHS has adopted the HIT Policy Committee recommendation to frame Meaningful Use as core requirements and discretionary requirements. In so doing, they have reduced the total number of requirements and introduced choice.  There is still much to learn and implement prior to the CMS payments that begin May 2011.

Overall this final rule maintains a balance between the policy objectives sought and the technology changes possible that are achievable now. There will still be 3 stages of meaningful use and later stages will be more demanding. All the original stage 1 requirements will still be part of meaningful use by stage 2.

In January of 2011, the clinicians may begin the 90 day process of using a certified record per meaningful use requirements. Attestation of this use begins in April 2011. It is extremely important, prior to investing in a EMR product, that it not only meets the criteria of Meaningful Use but also supports the practices with the training needed to obtain the reimbursements from the government.