EHR and Health IT Consulting
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EHR and Health IT Consulting
Technical Doctor's insights and information collated from various sources on EHR selection, EHR implementation, EMR relevance for providers and decision makers
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CMS Announces $284 Million Saved in Pioneer ACO Program After Two Years

CMS Announces $284 Million Saved in Pioneer ACO Program After Two Years | EHR and Health IT Consulting | Scoop.it

After two years in existence, the Pioneer Accountable Care Organization (ACO) program has saved the Medicare program $384 million in total, or $300 per Medicare beneficiary per year. Participating providers saved Medicare $279.7 million in 2012 and $104.5 million in 2013. That amount of savings was announced on the website of the Department of Health and Human Services (HHS), and came via an independent evaluation report released May 4 by HHS. What’s more, as the announcement noted, the independent Office of the Actuary in the Centers for Medicare and Medicaid Services (CMS) has certified that the Pioneer ACO program is model “is the first to meet expansion to a larger population of Medicare beneficiaries.”


According to the announcement, “The independent evaluation report for CMS found that the Pioneer Accountable Care Organization (ACO) Model generated over $384 million in savings to Medicare over its first two years – an average of approximately $300 per participating beneficiary per year – while continuing to deliver high-quality patient care. The Actuary’s certification that expansion of Pioneer ACOs would reduce net Medicare spending, coupled with Secretary Sylvia Mathews Burwell’s determination that expansion would maintain or improve patient care without limiting coverage or benefits, means that HHS will consider ways to scale the Pioneer ACO Model into other Medicare programs.”


Reacting to the development, HHS Secretary Sylvia Mathews Burwell was quoted in the online announcement as saying, “This is a crucial milestone in our efforts to build a health care system that delivers better care, spends our health care dollars more wisely, and results in healthier people. The Affordable Care Act gave us powerful new tools to test better ways to improve patient care and keep communities healthier. The Pioneer ACO Model has demonstrated that patients can get high quality and coordinated care at the right time, and we can generate savings for Medicare and the health care system at large.”

The Pioneer ACO Model, one of the first payment models launched by CMS, gives experienced health care organizations accountability for quality and cost outcomes for their Medicare patients. Doctors and hospitals who form Pioneer ACOs can share in savings generated for Medicare if they work to coordinate patient care, keep patients healthy and meet certain quality performance standards, or they may be required to pay a share of any losses generated.


Currently, more than 600,000 Medicare beneficiaries are assigned to Pioneer ACO organizations.


The announcement touted the fact that Medicare beneficiaries enrolled in Pioneer ACOs, on average, “report more timely care and better communication with their providers; use inpatient hospital services less and have fewer tests and procedures;  have more follow-up visits from their providers after hospital discharge.” The announcement also noted that the Pioneer ACO program’s evolution harmonizes with broader federal efforts, including with Secretary Burwell’s goal of tying 30 percent of Medicare payments to quality and value through alternative payment models by 2016 and 50 percent to such models by 2018.

Reacting to Monday’s news, the Charlotte-based Premier Inc. released a statement, attributed to Blair Childs, senior vice president for public policy for the nationwide health alliance. “Today’s announcement proves that innovative care delivery models such as the Pioneer ACO  program are effective at generating cost savings, while simultaneously improving quality and beneficiary satisfaction with care,” Childs said. “For more than a decade, members of the Premier alliance have been national leaders implementing payment and delivery reforms that improve quality while safely reducing costs.”


Still, Premier’s Childs said in the statement that, “While we support the desire to expand the Pioneer ACO program through track 3, as described in the Medicare Shared Savings Program (MSSP) proposed rule, we believe important changes need to be made, including:

  • Strengthen the assignment process by allowing Medicare beneficiaries to attest to participation in ACOs;
  • Establish a more appropriate balance between risk and reward, including higher shared savings for high-quality providers and a period where risk can be phased in over time;
  • Modify the current benchmark methodology to mitigate the impact on ACOs that lower expenses and achieve savings, and to allow ACOs to decide how to best account for regional and local cost trends;
  • Employ a risk-adjustment methodology that truly takes into account  an individual beneficiary’s acuity;
  • Adopt payment waivers to eliminate barriers to care coordination; and
  •  Provide more comprehensive and timelier data on ACOs’ patients.”


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AAFP Calls MU Audits Into Question

AAFP Calls MU Audits Into Question | EHR and Health IT Consulting | Scoop.it

The American Academy of Family Physicians (AAFP) has sent a letter to Centers for Medicare & Medicaid Services (CMS) acting administrator Andy Slavitt, expressing concerns with meaningful use audits.


Specifically, the letter states that “auditors are causing undue hardship for family physicians with unreasonable and burdensome documentation requests...” This is despite the fact that many family physicians have implemented and use electronic health records (EHRs) in the full spirit of the meaningful use program, the letter attests. “They therefore have a reasonable expectation that the meaningful use financial subsidy would help offset the implementation costs and associated initial decrease in practice productivity.”


The letter, written by AAFP board chair Reid B. Blackwelder, M.D., says that when auditors demand that family physician practices produce documentation years after the fact, unreasonable burden is created. “This is especially burdensome for family physicians who have made changes to their practice or have been acquired by a larger healthcare organization,” the letter says.


Another concern, according to AAFP, stems from employed physician situations, since many employment contracts include a clause stating all Medicare payments are turned over to the practice. “This creates an issue when the practice received the meaningful use subsidy, but years later, the individual physician is held responsible for repaying the payment after a failed audit.”


The letter also calls into question the effectiveness, responsiveness, and expertise of the auditors, as well as saying that the program’s “all or nothing” nature means that missing one document may lead to a failed audit and a repayment of the full subsidy payment. In reality, says AAFP, the audit program does not appear to take into consideration the high likelihood that a failed audit can be caused simply by missing documentation rather than by not achieving the meaningful use requirements.


AAFP calls for increased transparency from the federal government regarding audit statistics including the number of audits and the failure rate. “It would be helpful to have a report on what documentation was missing from failed audits. That would enable eligible professionals to have a better understanding over the type and granularity of documentation required,” the letter says.


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How Does ONC Plan to Expand Health Information Exchange?

How Does ONC Plan to Expand Health Information Exchange? | EHR and Health IT Consulting | Scoop.it

With the vast amounts of data collected in the healthcare industry, providers, vendors, and other stakeholders are putting more focus into developing health information exchange (HIE) and greater EHR interoperability. The Office of the National Coordinator for Health IT (ONC) released a report to Congress – Update on the Adoption of Health Information Technology and Related Efforts to Facilitate the Electronic Use and Exchange of Health Information – to offer policy guidance on the best ways for optimizing health IT systems and supporting HIEs.


Ever since the federal government passed the Health Information Technology for Economic and Clinical Health (HITECH) Act, the number of hospitals and physician practices adopting EHR systems has grown substantially. Currently, more than half of hospitals have at least a basic EHR system in place while, in 2013, 48 percent of physicians had EHRs at their practice.


Additionally, eligible professionals and eligible hospitals across the country are participating in the Medicare and Medicaid EHR Incentive Programs. While there has been significant progress in implementing health IT, there are still barriers that are halting widespread health information exchange across healthcare organizations and vendor products.


For example, if an individual from Maine takes a vacation in Florida and experiences a patient encounter, their primary care provider from Maine would likely not be informed nor would be able to access the patient’s emergency care data.


The report states that some of the common barriers to EHR adoption and thereby challenges for expanding health information exchange include the cost of purchasing a system, loss of productivity, training difficulties, the costs of annual maintenance, and obstacles related to finding an EHR system that supports practice needs. Nonetheless, in 2013, eight in ten physicians were using an EHR system or planning to adopt one, according to an ONC data brief.


ONC explains in its report that some of the reasons health information exchange is lacking is due to inconsistent structure, format, and even medical vocabulary used across different EHR systems and vendor products. ONC outlines key actions the Department of Health and Human Services (HHS) will need to take to improve nationwide EHR interoperability. These actions include:


  1. Creating new standards that are integral to the development of a connected healthcare system
  2. Requiring more staff in the health IT workforce to support the implementation of electronic records
  3. Improving the sharing of data among providers and public health agencies
  4. Collaborating, advising, and sharing studies with states, communities, and providers to stimulate IT solutions in the healthcare field
  5. Driving patient engagement with their health information


ONC hopes that Stage 2 Meaningful Use requirements will also catalyze a widespread data exchange network within the healthcare sector. By using these five strategies, HHS plans to further advance health information exchange and invest in health IT usability throughout the nation.


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Why Providers Seek EHR Flexibility Standards From CMS

Why Providers Seek EHR Flexibility Standards From CMS | EHR and Health IT Consulting | Scoop.it

Over the last several years, a multitude of providers have found meaningful use requirements too complex and advanced to reach as quickly as the Centers for Medicare & Medicaid Services (CMS) mandates. Specifically, the healthcare industry is calling for more EHR flexibility when integrating these systems.


Due to the large volume of concerns from stakeholders and healthcare providers, CMS did move forward with revising some aspects of the meaningful use requirements. For example, instead of reporting on EHR use in a full calendar year, CMS decided to implement a 90-day reporting period instead.


“We continue to support the long-term goals of the meaningful use program and share the Department of Health and Human Services’ commitment to elevating patient-centered care and improving health outcomes, but greater flexibility is needed to support the providers and make participation less daunting,” American Academy of Family Physicians President Dr. Robert Wergin said in a public statement.

Along with concerns over meaningful use requirements, the lack of sharing capabilities among EHR systems is also causing providers to worry. The lack of EHR flexibility and interoperability is a significant concern, which the Office of the National Coordinator for Health IT (ONC) recently addressed by releasing a 10-year roadmap.


While approximately half of providers and 59 percent of hospitals have implemented EHR technology, not nearly as many physicians have the EHR flexibility necessary to communicate with doctors at other establishments. The Department of Health and Human Services (HHS) reported that, in 2013, only 14 percent of physicians electronically shared data with ambulatory care providers or hospitals that were outside of their facility.


Additionally, that same year only 10 percent of hospitals were offering their patients online access to view, download, and distribute their personal health records based on their hospital stay.

On March 18, the American Hospital Association (AHA) advised Congress to allow providers more EHR flexibility when implementing these systems. With the ICD-10 transition taking place on October 1, providers will need more secure and flexible products when adopting the new coding set.


Additionally, the recent release of the Stage 3 Meaningful Use proposed rule sets 2018 as the anticipated year for meeting the requirements. This may be difficult to achieve for providers that are still struggling to attain Stage 2 Meaningful Use regulations.

In a statement by AHA to the Senate Committee on Health, Education, Labor and Pensions, the organization commented on how health IT tools do not support a high level of health information sharing. AHA asks for the development of policy that supports EHR flexibility and the designing of systems to securely adapt to the ICD-10 coding set.

AHA also highlights the importance of delivering health IT products that promote patient safety and quality improvements. The various EHR issues including data exchange concerns will need to be addressed by the federal government over the coming months, as the ICD-10 transition is currently set to take place on October 1, 2015.


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Brief History of EHR Incentive Payments, Payment Adjustments

Brief History of EHR Incentive Payments, Payment Adjustments | EHR and Health IT Consulting | Scoop.it

The Centers for Medicare & Medicaid Services (CMS) oversee the Medicare and Medicaid EHR Incentive Programs, meaningful use payments, and payment adjustments for eligible professionals and hospitals including critical access hospitals (CAHs).

Under the Medicare EHR Incentive Program, healthcare facilities may receive a maximum incentive payments of $44,000 over the course of five sequential years. The payments first started in 2011 and will continue until the end of 2016. Meanwhile, the Medicaid EHR Incentive Program confers a maximum of $63,750 over six years. In order to receive these incentives, eligible professionals and hospitals must prove they are meaningfully using certified EHR technology (CEHRT) in their practices. After first-year entities participated in the program, they could obtain as much as $18,000. In subsequent years, incentive payments were lower, ending with $2,000 by the fifth year for Medicare eligible professionals.

In 2009, Congress passed a ruling within the American Recovery and Reinvestment Act that assigned payment adjustments or penalties to eligible medical professionals and hospitals that did not meet meaningful use requirements of CEHRT under the Medicare EHR incentive program. Eligible providers who do not meet meaningful use will receive one-percent payment reduction in the first year, which will rise in every subsequent year to a maximum of five percent.

Healthcare providers who are eligible only for the Medicaid program will not have the burden of these payment adjustments. For those who serve both Medicare and Medicaid patients, they will be subject to payment adjustments if they fail to meet meaningful use requirements.

The first penalties began on October 1, 2014 for Medicare hospitals. Eligible professionals who did not meet meaningful use requirements received their first payment adjustment after January 1, 2015. Recently, CMS announced that approximately 78,000 eligible professionals are subject to meaningful use penalties of more than $2,000.

“The penalties physicians are facing as a result of the Meaningful Use program undermine the program’s goals and take valuable resources away from physician practices that could be spent investing in better and additional technologies and moving to alternative models of care,” Steven J. Stack, MD, President of the American Medical Association, said in a statement. “The AMA continues to work with the Administration to improve the Meaningful Use program and looks forward to seeing how CMS’ anticipated new rules address these issues this spring.”

Despite the burden of the penalties, CMS does offer exceptions to those truly having difficulty implementing CEHRT and meeting the requirements of meaningful use. Those who are eligible but unable to meet meaningful use requirements due to a significant hardship are allowed to file for a meaningful use hardship exemption by completing an application. Upon approval of the hardship, it is valid for one year only and a subsequent application must be presented the following year. A hardship exemption may not be granted for any longer than five years.

There are also a handful of cases in which entities will not need to submit hardship exemption applications but will automatically be given an exception. These include new providers in their first year of service and professionals of specific PECOS specialties among others.

For those who wish to avoid a payment penalty in subsequent years, the National Library of Medicine offers tools that help providers meet EHR certification conditions and reach meaningful use stipulations.


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Modifications to Meaningful Use for 2015 through 2017

Modifications to Meaningful Use for 2015 through 2017 | EHR and Health IT Consulting | Scoop.it

On April 10, 2015, the Centers for Medicare & Medicaid Services issued a new proposed rule for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs to align Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3, to build progress toward program milestones, to reduce complexity, and to simplify providers’ reporting. These modifications would allow providers to focus more closely on the advanced use of certified EHR technology to support health information exchange and quality improvement.

Better Care, Smarter Spending and Healthier People
The proposed rule is just one part of a larger effort across HHS to deliver better care, spend health dollars more wisely, and have healthier people and communities by working in three core areas: improving the way providers are paid, improving the way care is delivered, and improving the way information is shared to support transparency for consumers, health care providers, and researchers and to strengthen decision-making.


Vision for the Future


The proposed rule issued today is a critical step forward in helping to support the long-term goals of delivery system reform; especially those goals of a nationwide interoperable learning health system and patient-centered care. CMS is also simplifying the structure and reducing the reporting requirements for providers participating in the program by removing measures which have become duplicative, redundant, and reached wide-spread adoption (i.e., are “topped out”). This will allow providers to refocus on the advanced use objectives and measures. These advanced measures are at the core of health IT supported health care which drives toward improving the way electronic health information is shared among providers and with their patients, enhancing the ability to measure quality and set improvement goals, and ultimately improving the way health care is delivered and experienced.


Simplifying and Streamlining


The proposed rule would streamline reporting requirements. To accomplish these goals, the NPRM proposes:

  • Reducing the overall number of objectives to focus on advanced use of EHRs;
  • Removing measures that have become redundant, duplicative or have reached wide-spread adoption;
  • Realigning the reporting period beginning in 2015, so hospitals would participate on the calendar year instead of the fiscal year; and
  • Allowing a 90 day reporting period in 2015 to accommodate the implementation of these proposed changes in 2015.


Supporting Interoperability and the Adoption of Electronic Health Records


The EHR Incentive Programs support the adoption and meaningful use of certified EHR technology to allow providers and patients to exchange and access health information electronically and support interoperability broadly. The program supports interoperability by requiring the capture of data in structured formats as well as the exchange of data in standardized form as well as the sharing of this data electronically with other providers and with patients.

The proposed rule would reduce required reporting, allowing providers to focus on objectives which support advanced use of EHR technology and quality improvement, including health information exchange.


Improving Outcomes for Patients


The rule would support improved outcomes and measurement of those outcomes. By proposing to simplify the reporting requirements, the proposed rule would allow providers to focus on objectives that support advanced use of EHR technology, including quality measurement and quality improvement. The rule supports providers leveraging their resources and health IT to coordinate care for patients, to provide patients with access to their health information, and to support data collection in a format that can be shared across multiple health care organizations.


Program Registration and Participation Milestones


As of March 1, 2015, more than 525,000 providers have registered to participate in the Medicare and Medicaid EHR Incentive Programs. In addition, more than 438, 000 eligible professionals, eligible hospitals, and CAHs have received an EHR incentive payment. As of the end of 2014, 95% of eligible hospitals and CAHs, and more than 62% of eligible professionals have successfully demonstrated meaningful use of certified EHR technology.


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The Dire Need for Healthcare Interoperability

The Dire Need for Healthcare Interoperability | EHR and Health IT Consulting | Scoop.it

In a recently published study, "Emergency Physician Perceptions of Medically Unnecessary Advanced Diagnostic Imaging," physician Hemal Kanzaria and co-authors uncovered that 97 percent of the over 700 responding ED physicians admit that nearly one in four advanced diagnostic imaging studies they personally order are "medically unnecessary." Worse yet, most in-hospital diagnostic imaging studies cost about five times more than their independent counterparts for the same work.

"The main perceived contributors were fear of missing a low-probability diagnosis and fear of litigation," according to the study abstract. The real contributor is that emergency physicians, and virtually every other consulting physician, is being forced to treat immediate crisis in the blind under looming threat of litigation, a callously perverse system that costs Medicare and Medicaid hundreds of billions of dollars each year, and the overall healthcare system arguably close to a trillion dollars per year in waste.


Emergency physicians, hospitalists, specialists, and even primary-care doctors, which pretty much covers anyone with a prescription pad, order lots of unnecessary or redundant tests not because the vast majority are intentionally wasteful but, because they, with rare exceptions, have no idea of what has or has not been done before them and must treat patients in the moment of crisis, not in the continuum of care.


This does not mean that ED doctors are bad at their jobs. It's just that doctors working in teams are proven to provide better care at lower cost. Much lower cost. As much as 30 percent.


Doctors work best if they can work in teams using the same information. Unfortunately, EHRs do not provide the kind of information that doctors need to be effective. They need information that helps them make informed decisions and they need to be responsible for all care and costs. When this happens, the quality of care improves. People get and stay healthier, and, costs go down.

Interoperability Hurdles


So, has spending $24.6 billion in taxpayer dollars on EHR systems been a bad idea? Not irreversibly. Some conflicts of interest that strongly inhibit the flow of data need to be addressed first:


1. It's good for EHR vendors to make it as hard as possible to move data to a competing system, denying the healthcare system as a whole.


2. It's good business for hospitals and their sub-specialist employees, whose stability relies on a steady stream of people in medical crisis, to keep data within their own walls and away from competitors.


3. It's good business for the industry as a whole because a free-flow of data means price, quality, and effectiveness transparency, forcing healthcare to compete like the rest of the economy.

And, the federal government obliges everyone with a cloak to hide behind: HIPAA.


The public is the only stakeholder in healthcare that restricting access to data is not good for.


The key to saving our healthcare system is to achieve a free flow of data and to convert that data into actionable clinical, price, and quality information for primary-care physicians, called interoperability.

Interoperability is the ability for different information technology systems and software applications to communicate, exchange data, and use the information that has been exchanged. It solves three of the most vexing problems the healthcare system and its providers face:


1. It unites a fragmented healthcare delivery system;


2. It streamlines and standardizes communication among providers; and,


3. It eliminates duplication of services.


Three Solutions to Move Forward


Karen DeSalvo, a physician and the former national coordinator for health information technology, set a goal to get the basic infrastructure in place by 2017 and to have a fully interoperable national system by 2024. That deadline has since been moved to 2017.


Considering that literally hundreds of thousands of doctors do not have or cannot afford EHR systems, nor can they afford to jump through the annual labyrinth of regulatory hoops to meet the federal government's definition of "meaningful use," and over 150 EHR manufacturers fighting for the only thing that keeps them in business — proprietary data — this goal is not only unrealistic, it is disingenuous.


But, there are companies already operational and their population health, analytics, and quality measurement systems combined with primary-care practice operational transformation, best practices training, and support that unleashes the power of that information, already generating high quality care and superior clinical outcomes at lower cost.


They do this by cutting waste and managing chronic disease effectively, which keeps patients out of the hospital. As a result, they must be independent of hospitals to avoid the conflict of interest.

Hospitals and their unions, whose lament you are already hearing, realize their vulnerability, and will fight unless you change the system to protect them. Hospitals are necessary to the public welfare and our national security.


Three simple actions can accelerate the process:


1. Funding the expansion of our interoperability capabilities and use of a common population health and analytics system with practice transformation, and requiring EHR companies to format their data in the same way and put it in the same place;


2. Limiting "out-of-network" payments to a reasonable percentage of Medicare to protect both patients and providers to protect patients and shared savings and risk programs from predatory practices; and,


3. Indemnifying doctors that use and document best practices from frivolous lawsuits.


With the kind of savings programs like these can deliver, investing the savings from just four or five Medicare beneficiaries per year for each enabled primary-care practice,  the return on investment generates savings of 100 times or more.


The hardest part is mentally disengaging from the misperception that hospitals are healthcare providers. They are not. Hospitals are medical crisis treatment and rehabilitation facilities. Hospitals cannot so much as dispense an aspirin without a doctor's approval, and doctors need to be clear of conflict of interest.


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Strategies for Dealing with Value-Based Modifiers

Strategies for Dealing with Value-Based Modifiers | EHR and Health IT Consulting | Scoop.it

As we know many payers are implementing various approaches to pay-for-performance reimbursement or value-based reimbursement programs. Medicare has announced significant goals in modifying payment models; rolling out value-based payment modifiers (VBPM) this year. Patient care activity in 2015 will impact every Medicare payment in 2017. Physician groups of 100 or more will have payments affected this year, groups of 10 or more in 2016, and all groups in 2017. Medicare will determine the amount of payment incentive or adjustment based on the information noted below. The range is from - 4 percent to + 4 percent of Medicare payments.

Below are some thoughts on how you can respond to VBPMs and optimize the care provided patients and maintain or gain financial viability.


1. Continue to participate in PQRS which is the basis for the Medicare Value-Based Payment Modifier program. Understand how your profile fits within the six domains (check meaningful use): clinical process/effectiveness; patient and family engagement; population/public health; patient safety; care coordination; and efficient use of healthcare resources.


2. Access your practice Quality and Resource Use Report, QRUR, by obtaining an IACS number from CMS. This report was published by CMS last fall and compares your practice to peers on both quality and cost measures. This can be downloaded in both PDF and excel formats. It's complex but worth spending time on to both understand and identify your practice profile.


3. Monitor your entire provider panel in key measures:

Quality:

a. Preventable hospital admissions:

• Patients with acute episodes of dehydration, UTI, and bacterial pneumonia

• Chronic patients with heart failure, COPD, and diabetes

b. All cause hospital readmissions

Cost — your practice status:

a. All Part A and Part B payments (Part D excluded)

b. For disease categories: COPD, heart failure, coronary artery disease, and diabetes

c. Medicare Spend Per Beneficiary, MSPB, for three days prior to and 30 days post discharge

d. Total Medicare Allowable per applicable CPT code

4. Report monthly on what is occurring.

a. Your practice will not know the Medicare ranking until the end of period.

b. Rankings are determined by the eligible provider (EP) who has a "plurality" of primary-care codes assigned and the Medicare allowable charge amount assigned. Primary-care providers will be considered first, but any specialist may qualify.

c. A minimum of 20 episodes per measure (see quality above) hence the need to monitor your practice. If insufficient numbers are there, you may not see either the incentive or adjustment.


5. Regular review and reporting will help lead the practice toward a more "quality" impact and focus. When all staff, not just providers, work together, the cumbersome nature of reporting will become easier and part of everyday practice life — since in many cases the impact is not significant this year. It will however become more impactful in the years to come, as not only VBPM programs come into play, but overall payment model reforms are implemented. There will be an eventual culture change!


Long term outcomes for practices should be improved patient care, compliance with the new paradigm, and an improved financial picture. How you approach it now may determine the long-term success and viability of your practice in the future.


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There Are Some Things You Just Can’t Do Without an EHR

There Are Some Things You Just Can’t Do Without an EHR | EHR and Health IT Consulting | Scoop.it

Over the past two years, there has been a lot of talk about a big EHR switching trend. Some of this has been because of Meaningful Use, and some of it has been because of market changes. There are simply more options today if you are unhappy with your current EHR.

Surveys show that many physicians are frustrated with the cost or functionality in their EHR, which has prompted considering a switch. There is also frustration with too much third party interference and regulation. Despite some of these challenges, one thing is clear. Most physicians believe EHRs improve care, reduces errors, and improve billing.


What sometimes gets left out are the other opportunities created by using an EHR. Some of these are new revenue sources that might be impossible or very hard to access without one. Here are a few examples, but certainly not the only ones.


Medicare Programs


There are some new codes that have come out in the last two years for services that are revenue generators, but you really do need an EHR to manage them. The first is transitional care management (TCM). While TCM doesn’t require you to use an EHR, the complexity of it makes it hard to do without one. The ability to easily put in your notes and set reminders for needed follow up makes managing TCM much easier. With reimbursement ranging anywhere from about $100 to over $200 per patient, this can be a great opportunity for providers who see many patients who need post hospitalization follow ups.


The other Medicare program is newer and does require the use of a certified EHR. It is the Chronic Care Management (CCM) code that came out this year. The reimbursement is about $42 per patient and can be billed once a month. The requirement is that the patient has two or more chronic conditions that are expected to last at least 12 months or until the patient’s death. Clinical staff must spend at least 20 minutes performing CCM services for the patient each month that the code it billed. The services are non-face-to-face and direct supervision is not required, which means that nursing staff or non-physician practitioners can render CCM even if the physician is not in the office. Again, if your practice sees a lot of patients with chronic health problems, this can be a great way to add revenue by using nursing or mid-level staff.


Affordable Care Act Opportunities


By now I hope everyone knows that preventive care services are covered with no copays or deductibles. What many providers still aren’t very aware of are the other types of programs that are now covered by insurance that can be great revenue generators. While they don’t require an EHR, this is another area where using an EHR makes running these programs much easier. The two programs that make a lot of sense for primary care providers and specialists who see patients with certain types of qualifying conditions are group visits and weight loss programs.


With group visits, the practice identifies a group of patients who have a similar, chronic condition that requires frequent visits. You can do this using your EHR (it would be tough using paper charts). Some examples include HIV, chronic pain, COPD, and hypertension. Vitals are done individually as patients arrive and then the whole group spends the rest of the 1.5 – 2 hour visit together with the provider. Once a group visit is completed, each patient’s insurance is billed for the appropriate E&M code for their individual situation. The ability to use templates and copy note features in the EHR can make documenting after the group visit much faster and easier than it would be if done by hand.


For patients with certain conditions, a weight loss program may be mostly or fully covered by insurance like preventive care. The great thing about this is that it can be as simple or complex as you are willing to manage. You can do simple nutritional counseling and weigh-ins or go for a fully formed program through a third party that includes food and supplements. Again, using an EHR makes it much easier and faster to manage and track multiple follow up appointments, set reminders, and copy notes and simply update them each time. You can even have a group visit component!


The key to all of these opportunities is that an EHR helps reduce the complexity of managing the requirements and helps insure that you can quickly and easily show accurate, thorough documentation to payers. Without an EHR, these revenue generating programs would simply seem too difficult to manage. In a time when every penny counts, you can’t ignore opportunities like these.


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Stage 2 'flexibility' rings hollow for many | Healthcare IT News

Stage 2 'flexibility' rings hollow for many | Healthcare IT News | EHR and Health IT Consulting | Scoop.it

When the Centers for Medicare & Medicaid Services published its final rule for Stage 2 meaningful use on Aug. 29, it trumpeted the "flexibility" it offered for how providers can use certified electronic health records.

Specifically, the rule allowed providers to use the 2011 Edition certified EHRs, or a combination of 2011 and 2014 Edition technology for the reporting period in 2014. By 2015, all eligible professionals, eligible hospitals, and critical access hospitals are required to use the 2014 Edition certified IT.

“We listened to stakeholder feedback and provided CEHRT flexibility for 2014 to help ensure providers can continue to participate in the EHR Incentive Programs forward,” said CMS Administrator Marilyn Tavenner, in a press statement.

But industry groups did not feel listened-to. And they definitely did not see much in the way of flexibility – at least when it came to reporting periods – a topic on which they'd lobbied particularly hard.

"CHIME is deeply disappointed in the decision made by CMS and ONC to require 365-days of EHR reporting in 2015," said Russell P. Branzell, chief executive officer of the College of Healthcare Information Management Executives, in a press statement responding to the new rule.

"This means that penalties avoided in 2014 will come in 2015, and millions of dollars will be lost due to misguided government timelines," he added. "Now, the very future of meaningful use is in question."

Other stakeholders were similarly wary of CMS' next steps. Even the day before that final rule, MGMA Policy Advisor Robert Tennant (perhaps intuitively sensing what it would contain), told Healthcare IT News that, "We've raised numerous concerns about where meaningful use is going. If significant changes are not coming in the program, I think the program risks a lot. We could see, frankly, failure of the program."

In mid-September, CHIME, MGMA and more than a dozen other stakeholders joined forces to write a pointed letter to HHS Secretary Sylvia Mathews Burwell – Tavenner and National Coordinator for Health IT Karen DeSalvo, MD, were CC'd – to reiterate their serious concern that the success of meaningful use "hinges on addressing the 2015 reporting period requirements.

While the groups – which included HIMSS, the American Medical Association, the American Hospital Association and more – thought their concerns had been heard and would be acknowledged in the Aug. 29 rule, they "were surprised to learn that flexibilities meant to mitigate 2014 challenges did not also address program misalignment in 2015 and beyond."

The numbers speak for themselves, the groups argued. As of September, just 143 hospitals and 3,152 providers have been able to meet Stage 2 with 2014 Edition EHRs.

"This represents less than 4 percent of the hospitals required to be Stage 2-ready within the next 15 days," according to the letter. "And while eligible professionals have more time, they are in comparatively worse shape, with only 1.3 percent of their cohort having met the Stage 2 bar thus far."

While the stakeholders reiterated their commitment to meaningful use, they urged Secretary Burwell to "take immediate action by shortening the 2015 EHR reporting period to 90 days" – and also by adding more wiggle room with regard to Stage 2's notoriously troublesome transitions of care and view/download/transmit measures.

The very next day, a new bi-partisan bill seeking to offer providers meaningful relief was drafter on Capitol Hill. Republican North Carolina Congresswoman Renee Ellmers introduced H.R. 5481, The Flexibility in Health IT Reporting (Flex-IT) Act of 2014, on Sept. 16.

Co-sponsored with Democratic Utah Rep. Jim Matheson, the new legislation is crafted to offer providers more flexibility in showing meaningful use compliance. Specifically, according to Ellmers' office, it would remedy HHS' "short-sighted final rule" requiring 365 days of EHR reporting in 2015.

The Flex-IT Act would allow providers to report their technology upgrades in 2015 through a 90-day reporting period as opposed to a full year. It would be welcome relief for legions of providers, who say the shortened reporting window would help them better manage meaningful use's many onerous mandates.

"The meaningful use program has many important provisions that seek to usher our health care providers into the digital age," said Ellmers in a press statement. "But instead of working with doctors and hospitals, HHS is imposing rigid mandates that will cause unbearable financial burdens on the men and women who provide care to millions of Americans. Dealing with these inflexible mandates is causing doctors, nurses, and their staff to focus more on avoiding financial penalties and less on their patients."

By giving providers the option to choose any three-month quarter for the EHR reporting period in 2015 to qualify for MU, "hundreds of thousands of providers" would have a better shot of meeting Stage 2 requirements safely and effectively, she said.

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