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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Stage 3 Meaningful Use proposals at White House for final review

Stage 3 Meaningful Use proposals at White House for final review | EHR and Health IT Consulting | Scoop.it

Why do these things always seem to happen late on Friday afternoons? At least this time it’s not right before a holiday. Actually, with a bit more inspection, I see that it did happen right before a holiday.

HIMSS is reporting today that the White House’s Office of Management and Budget is “in its final stages of review” of the proposed rules for Stage 3 of the Meaningful Use EHR incentive program. OMB always goes over proposed and final regulations to measure the fiscal — and, presumably, political — impact before allowing executive-branch agencies to make public releases.

A peek at OMB’s reginfo.gov site indicates that the MU Stage 3 proposal from CMS and related ONC plan for certification of EHRs are indeed at OMB for final review.

“We are proposing the Stage 3 criteria that [eligible professionals], eligible hospitals, and [Critical Access Hospitals] must meet in order to successfully demonstrate meaningful use under the Medicare and Medicaid EHR Incentive Programs, focusing on advanced use of EHR technology to promote improved outcomes for patients. Stage 3 will also propose changes to the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements,” CMS states in a rule summary on the OMB site.

A placeholder date (“02/00/2015 “) on the same page suggests that the proposal will be published in February. However, a placeholder date on the page for the forthcoming ONC certification standards indicates that the plan was supposed to come out in November.

And the date the two notices appeared on the reginfo.gov? Dec. 31, when pretty much everyone was already checked out for the extended New Year’s weekend.

Stage 3 is scheduled to start no earlier than Oct. 1, 2016, for hospitals and Jan. 1, 2017, for individual providers.


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AMA Lists EHRs, Meaningful Use, ICD-10 as Top 2015 Challenges

AMA Lists EHRs, Meaningful Use, ICD-10 as Top 2015 Challenges | EHR and Health IT Consulting | Scoop.it

The New Year’s celebrations may be dying down this week as the healthcare industry gets back to work, but the American Medical Association (AMA) wants providers to keep a watchful eye on ten major challenges that they will face during the year ahead.  From ICD-10 to meaningful use to improving population health management and chronic disease care, the AMA list highlights some common complaints.

At the top of the list is a familiar refrain: the ongoing burden of regulatory initiatives such as meaningful use that have frustrated physicians for years.  The AMA has long advocated for changes to the program, and plans to “intensify” its efforts to push CMS towards greater flexibility for the program, especially after more than 50% of providers were notified that they will be receiving Medicare payment adjustments in 2015.

The overly-strict requirements of the EHR Incentive Programs “are hindering participation in the program, forcing physicians to purchase expensive electronic health records with poor usability that disrupts workflow, creates significant frustrations and interferes with patient care, and imposes an administrative burden,” AMA President Elect Steven J. Stack, MD said in a statement.

Coupled with meaningful use is the AMA’s other nemesis – ICD-10.   While the organization has tried everything from a Twitter rally to Congressional letters to industry appeals in order to continue delaying the code set indefinitely, the new list of challenges takes a bit of a different tack.  Instead of reiterating the AMA’s opposition to the codes, the list simply says that the AMA “has advocated for end-to-end testing, which will take place between January and March and should provide insight on potential disruptions from ICD-10 implementation, currently scheduled for Oct. 1.”

“Given the potential that policymakers may not approve further delays, ICD-10 resources can help physician practices ensure they are prepared for implementation of the new code set,” the section continues, which is some of the mildest language the AMA has used about the ICD-10 transition for some time.

Is there a little hint of resignation to defeat now that Congress itself has backed the 2015 implementation date, or will the AMA continue its lengthy fight until the very end?  The degree to which the AMA pushes resistance instead of readiness over the next few months may impact how many providers are prepared for the deadline and how many continue to pin their hopes on a postponement.

Other items on the list that will impact physicians in 2015 include the rampant abuse of prescription medications, the spread of diabetes and heart disease, and the need to adequately modernize medical education and the AMA’s Code of Medical Ethics.

The list also highlights the need to continue medical research and the sharing of clinical knowledge, to which end the AMA is launching JAMA Oncology, a new journal in its network of publications.  Physician satisfaction and the financial sustainability of medical practices is also on the AMA’s mind as it beta tests professional tools to help physicians chart a profitable course for the future.

To round out the top ten issues for the healthcare industry in the coming year, the AMA includes the need for reform to the Medicare physician payment system after the latest temporary Congressional SGR fix in April, the need to ensure adequate provider networks for patient care, and upcoming judicial rulings on healthcare-related issues such as liability, patient privacy, and the regulation of practices by state licensure boards.


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2015 Hospital Healthcare IT Predictions | Hospital EMR and EHR

2015 Hospital Healthcare IT Predictions | Hospital EMR and EHR | EHR and Health IT Consulting | Scoop.it

At the start of 2015, I thought I’d put down some predictions on what will happen in the world of healthcare IT and EHR. These won’t be crazy predictions, since I don’t think anything crazy is going to happen in healthcare in 2015. We’ll see some clarity with a few programs and we’ll some some incremental change in things that matter to hospitals.

ICD-10 – I predict that ICD-10 will again be delayed with the next SGR fix. I don’t have any inside information on this. I just still believe that nothing’s different in 2015 that wasn’t true in 2014 (maybe AHIMA’s lobbying harder for no delay). I think another delay will put all of ICD-10 in question. Let’s hope whatever the decision is on ICD-10, it happens sooner than later. The ICD-10 uncertainty is worse than either outcome.

Meaningful Use – MU stage 2 will change from 365 days to 90 days. It will probably take until summer for it to actually happen which will put more people in a lurch since they’ll have even less time to plan for the 90 days than if they just made the change now. MU stage 2 numbers will be seen as great by those who love meaningful use and terrible by those who think it’s far reaching. The switch to 90 days means enough hospitals will hop on board that meaningful use will continue forward until it runs out of money.

EHR Penalties – Doctors will be blind sided by all the penalties that are coming with meaningful use, PQRS, and value based reimnbursement, even though it’s been very clear that these penalties are coming. Doctors will pan it off on “I can’t keep up with all the complex legislation.” and “I knew the penalties were coming, but I din’t think they’d be that big.” Watch for some movement to try and get some relief from these penalties for doctors. However, it won’t be enough for the doctors who want to start a perpetual SGR fix like delay of the EHR penalties. Many practices will have to shut down because of poor business management.

Direct to Consumer Medicine – Doctors will start to move towards a number of direct to consumer medicine options such as telemedicine and concierge medicine. These doctors will love their new found freedom from insurance reimbursement and the ongoing hamster on a treadmill churn of patients through their office. How far this will go, I’m not sure, but it will create a gap between these doctors who love this “new” form of medicine and those who feel their stuck on the treadmill.

Interoperability – 2015 still won’t see widespread healthcare interoperability, but it will help to lay a clear framework of where healthcare interoperability needs to go. A couple large EHR vendors will embrace this framework as an attempt to differentiate themselves from their competitors.

There you go. A few 2015 predictions. What do you think of these predictions? Any others you’d like to make? I feel like my predictions feel a little bit dire. A few show signs of promise, but I think that 2015 will largely be a transitory period as we try to figure out how to get the most value out of EHR.

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EHR Incentive Program Status Report October 2014 - HITECH AnswersHITECH Answers

EHR Incentive Program Status Report October 2014 - HITECH AnswersHITECH Answers | EHR and Health IT Consulting | Scoop.it

As of October 2014, more than 418,000 health care providers received payment for participating in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.  In May 2013, CMS announced that more than half of all eligible health care providers had been paid under the Medicare and Medicaid EHR Incentive Programs. In August of 2014, HHS reported more physicians and hospitals are using EHRs than before. And in December of 2014, an ONC data brief released stated financial incentives and ability to exchange clinical information found to be top reasons for EHR adoption.

The Centers for Medicare & Medicaid Services (CMS) has released the most recent numbers for the EHR Incentive programs. Here are some Program-to-date highlights from this latest CMS report – October.

  • Active registrations of those completed totaled 505,641 breaking down with 335,964 Medicare EPs, 164,912 Medicaid EPs, and 4,765 hospitals.
  • 50 States and 5 territories have open Medicaid registration. For links to states’ Medicaid EHR Incentive Program websites, see your State EHR Incentive Program Milestones and Web Resources guide.
  • A total of 418,752 unique providers have been paid with breakdown of 268,010 Medicare EPs, 132,412 Medicaid EPs, 4,695 eligible hospitals, and 13,635 Medicare Advantage Organizations for EPs.
  • 39,271 EPs have received a HPSA bonus payment for program years 2011 and 2012.
  • 3,514 hospitals have received payments under both Medicare and Medicaid (of those, 727 were CAHs).
  • A total of $25,774,554,152 has been paid out in the program to date.
  • Medicare EPs have been paid $6,525,991,926 with the majority of those, Doctors of Medicine or Osteopathy receiving $5,880,245,369.
  • Medicaid EPs have been paid $3,360,689,785 with the majority of those, Physicians receiving $2,358,438,340.
  • Eligible hospitals have been paid $15,481,118,733 with Medicare only $597,234,756, Medicaid only $366,549,394, and Medicare/Medicaid $14,517,334,584.
  • Medicare Advantage Organizations For Eligible Professionals have been paid $406,753,707.
  • Medicaid EHR Incentive payments began in January 2011 and Medicare EHR Incentive payments began in May 2011.
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Meaningful use numbers show signs of life, groups still lobby for relief | Healthcare IT News

Meaningful use numbers show signs of life, groups still lobby for relief | Healthcare IT News | EHR and Health IT Consulting | Scoop.it
Stage 2 meaningful use attestations have shown big improvements recently, but many providers are still struggling. With her Flex-IT Act gaining traction in the House, Rep. Renee Ellmers, R-N.C., along with 28 fellow members of Congress, have called on HHS Secretary Sylvia Burwell to offer relief in the form of a shorter 90-day reporting period.

[See also: Poor MU showing renews calls for change]

The American Medical Association, meanwhile, is "appalled" that more than half of eligible providers will face penalties in 2015.

Speaking before the ONC's Health IT Policy Committee this past week, Elisabeth Myers, policy and outreach lead at CMS's Office of eHealth Standards and Services reported some drastic Stage 2 improvements.

[See also: New bill aims to ease MU reporting rules]

Hospitals, which had managed to log just 840 attestations through October, doubled that number between Nov. 1 and Dec. 1 – with 1,681 success stories as of the beginning of the month.

Eligible providers, meanwhile, managed another 5,000 successful attestations over the month – from 11,478 through Nov. 1 to 16,455 by Dec. 1.

For a program that seemed on such shaky ground as recently as this fall, those numbers are heartening. Still legislators and industry groups would like to see more. And a three-month reporting period in 2015, rather than a full year, would be one way to see even more success, argues Ellmers, along with more than two dozen, mostly-Republican colleagues, in a Dec. 16 letter sent to HHS.

"We remain convinced that program success hinges on addressing the 2015 reporting period requirements," Ellmers wrote, asking that HHS "immediately provide" a shortened, 90-day reporting period in 2015, "which would give providers much-needed time to safely and effectively implement certified technology and continue their 'meaningful use' journey."

Full-year reporting will "complicate the forward trajectory" of the program and "jeopardize the $25 billion in federal investment made to date," she wrote.

"Our constituents remain concerned that the pace and scope of change have outstripped the capacity of our nation’s hospitals and doctors to comply with program requirements," wrote Ellmers, who co-sponsored the Flex-IT Act this past September, in answer to outcry over CMS holding fast on its 365-day reporting period – a move that "disregarded recommendations made by the vast majority of healthcare stakeholders."

On Wednesday, CHIME President and CEO Russell P. Branzell issued a statement in support of the letter.

CHIME, he said, "applauds the leadership" Ellmers and her colleague, Rep. Jim Matheson, D-Utah, "have shown on this important, bipartisan issue and are pleased their colleagues recognize how essential meaningful use is in the modernization of the nation’s healthcare delivery system."

He added that December data from CMS showing that about half of the nation's physicians will receive penalties in 2015, "only validate our calls for increased program flexibility."

Indeed, that penalty data had the AMA hopping mad on Wednesday.

The AMA, said President-Elect Steven J. Stack, MD, is "appalled" by the news that more than 50 percent of eligible professionals will face penalties under the meaningful use in 2015.

That's "a number that is even worse than we anticipated," he said.

"The AMA supported the original HITECH legislation and we have provided extensive and constructive feedback to the administration to help fix the meaningful use program, but few changes have been made," wrote Stack.

The penalties faced by docs under meaningful use "are part of a regulatory tsunami facing physicians, apart from the flawed Sustainable Growth Rate formula, that could include cuts from the Physician Quality Reporting System, the Value-based Modifier Program and the sequester, further destabilizing physician practices and creating a disincentive to see Medicare patients," he added.
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Meaningful Use Problems Go Beyond Just Software, Say “Stage 2 Flexibility” Critics

Meaningful Use Problems Go Beyond Just Software, Say “Stage 2 Flexibility” Critics | EHR and Health IT Consulting | Scoop.it

The final rule for meaningful use Stage 2 flexibility, released late on Friday by the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC), is not as popular as the government probably would have liked.

The rule does allow eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) to use 2011 Edition certified electronic health record (EHR) technology (CEHRT)  or a combination of 2011 and 2014 Edition CEHRT for an EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs. However, the government has received sharp criticism from industry associations that the flexibility offered in these modifications was not enough to save hospitals and providers from receiving penalties down the line.

Robert Tennant, senior policy advisor of the Medical Group Management Association (MGMA), says while his organization is grateful for the focus on the CEHRT software, most of MGMA’s recommendations, as well as the other comments CMS and ONC received, and many of the overall problems with meaningful use were ignored.

“They’ve decided to focus exclusively on the issue of the software not being ready. We believe the problems with Stage 2 go beyond the CEHRT. That’s certainly an issue and we’re pleased they’ve given EPs flexibility for 2014 but that doesn’t solve the many other issues with Stage 2, not least of all, some of the new requirements have proven to be extremely onerous and forced EPs to rely on the actions of third parties,” says Tennant, speaking exclusively to Healthcare Informatics.

“The software issues are a problem, this definitely helps. But they made it adamant in the final rule that any criticism to the measures themselves were out of scope. They dismissed all of the industry recommendations.”

Tennant is frustrated that CMS and ONC continue with an “all or nothing” approach. He says the fact that an EP or EH can be 99.9 percent of the way there and fail sends the wrong message to the industry. Specifically, he mentioned the challenging transitions of care measures, which recent research showed that only a small number of EPs and EHs were able to meet.

The MGMA’s policy head mentioned the reporting requirements, and the lack of flexibility offered by CMS and ONC, as another reason the modifications weren’t enough for providers and hospitals. CMS and ONC are still requiring hospitals to engage in a 365-day reporting period in second-year Stage 2 reporting in 2015, rather than an industry-proposed 90-day reporting period. This means they have less than one month to get certified electronic health record (EHR) software in place in time to begin the mandatory reporting, since the fiscal year begins on Oct. 1, 2014.  

Speaking on this matter to HCI, Russell P. Branzell, president and CEO of the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME), was none too pleased with ONC and CMS’ efforts. “For a program that we still believe is absolutely essential and absolutely important to gain momentum, we are absolutely shocked that no flexibility was given in this case, with regard to 2015. Their rationale was that they wanted to create more momentum. But this does the opposite,” Branzell said.

This sentiment was echoed by Chantal Worzala, director of policy at the American Hospital Association. In a statement, she said: "The American Hospital Association appreciates the flexibility offered by CMS. Unfortunately, this rule offers little relief because CMS did not grant a shorter reporting period for FY 2015, which begins on Oct. 1."



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Pressure is on for meaningful use rebuild | Healthcare IT News

Pressure is on for meaningful use rebuild | Healthcare IT News | EHR and Health IT Consulting | Scoop.it

A coalition of healthcare associations today called on HHS Secretary to revamp the meaningful use program.

"Without changes to the MU program and a new emphasis for interoperable EHRs/EMRs systems and HIT infrastructure, we believe that the opportunity to leverage these technologies will not be realized," the organizations wrote.

The letter is signed by the American Academy of Family Physicians, American Medical Association, Medical Group Management Association, National Rural Health Association, Memorial Healthcare System, Mountain States Health Alliance, Premier healthcare alliance and Summa Health System.

The AMA also wrote a separate letter to CMS and ONC, pushing a similar agenda and offering a detailed "blueprint."

The coalition letter to Burwell references the recent final rule that provided some flexibility in cases where certified EHRs were not available.

"Unfortunately, the recently released final rule that provided relief for unavailable technology did not address or improve the challenges of interoperability and usability," the letter stated. "It also only limited its impact to 2014, despite the growing concern with future stages of the MU program. Our organizations remain concerned that without changes the forward trajectory of the MU program will be in jeopardy."

The coalition recommended the following:

• Streamline and focus the ONC certification requirements on interoperability, quality measure reporting and privacy/security. Removing a heavy handed set of certification mandates and allowing instead for a flexible and scalable standard based on open system architectural features like application program interfaces will promote the delivery of more innovative and usable solutions. This in turn will allow data to move more freely across the healthcare system, reducing data lock-in and promoting more usable systems;


• Foster collaboration among stakeholders to promote the development of new HIT that is focused on meeting clinical care needs;

• Remove restrictive MU policies that stifle HIT innovation;

• Recognize vendors and providers need adequate time to develop, implement and use newly deployed technology and systems before continuing on with subsequent stages of the MU program. Testing and achievement of specific performance benchmarks should occur before providers are held accountable for any new MU requirements.

Among the AMA recommendations in the letter it sent CMS and ONC were:

Adopting a more flexible approach for meeting meaningful use to allow more physicians to successfully participate;

•Better aligning quality measure requirements including reducing the reporting burden on physicians and helping relieve them from overlapping penalties;

• Ensuring quality measures and clinical decision support within the program are current to improve care for patients and ensure physicians are following the latest evidence; and

• Restructuring EHR certification to focus on key areas like interoperability.

"Physicians will always embrace technology that can help them provide better care for their patients and foster innovation, but improvements must be made to the meaningful use program in order for those goals to be achieved," said AMA President Robert M. Wah, MD, in a news release. "We can no longer just delay the program from taking full effect. We must make the necessary changes to ensure that the meaningful use program requirements are in fact meaningful and deliver – not hinder – the intended improvements in patient care and practice efficiencies."

The blueprint outlines several ways CMS and ONC could improve meaningful use immediately and in the future.

As part of its recommendations to improve the program, the AMA is asking the administration to make optional the objectives physicians are finding most challenging. These objectives include view, download and transmit, transitions of care and secure messaging.

In addition, the AMA recommends that CMS and ONC take the opportunity with Stage 3 to make the meaningful use program less primary care centric by expanding options within the health IT objectives to meet the needs of specialists and requiring physicians to meet no more than 10 requirements.

The letter also reiterates AMA concerns with Stages 1 and 2 of the program, and offers recommendations for addressing the programs.

"The whole point of the EHR incentive program was to build an interoperable health information technology infrastructure that would allow for the routine exchange of important medical information across settings and providers and put medical decision-making tools in the hands of physicians and patients, yet that vision is not being realized and the lack of interoperability is stifling quality improvement," said Wah. "While more than 78 percent of physicians are using an EHR, thousands have not participated in the meaningful use program or attested to Stage 2, in large part because of the program's all-or-nothing approach. Physicians should not be required to meet measures that are not improving patient care or use systems that are decreasing practice efficiencies. Levying penalties unnecessarily will hinder physicians' ability to purchase and use new technologies and will hurt their ability to participate in innovative payment and delivery models that could improve the quality of care."

The coalition seems to be in agreement. In its letter to Burwell, it wrote:

"In addition to HIT interoperability challenges, existing systems also lack usability, complicating physician and provider workflows, and diverting resources away from patient care. For instance, many of the physicians have vocalized concerns that these challenges and greater administrative burdens are creating significant dissatisfaction with EHR/EMR usability; yet, their vendors are limited from addressing these concerns as they focus on meeting increasingly complex certification requirements."



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Providers Seek Consulting Firms For Smaller EHR Projects

Providers Seek Consulting Firms For Smaller EHR Projects | EHR and Health IT Consulting | Scoop.it
With EHR installation a done deal, many health providers look to consulting firms for smaller Meaningful Use projects, KLAS study shows.

 

Healthcare organizations seeking to meet Meaningful Use Stage 1 requirements are much less inclined to hire consulting firms to fully install an electronic health record (EHR) and more likely to turn to these firms to help with smaller projects that enhance the features and functionality of their EHRs, a new KLAS report reveals.

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What Gets Measured Gets Managed - HITECH AnswersHITECH Answers

What Gets Measured Gets Managed - HITECH AnswersHITECH Answers | EHR and Health IT Consulting | Scoop.it

Say what you will about the pains of implementing an EHR or meeting the requirements for Meaningful Use. I’ll grant you that there are hiccups, roadblocks, stumbling points on the path to going digital. No doubt. But, you can’t deny that data doesn’t lie and when we measure data, we can manage it.

Case in point: an 11-doctor pulmonary group was scheduled to attest to Stage 2 Meaningful Use in 2014. The group’s practice manager was new to the organization and tasked with the responsibility of managing the eligible providers’ progress. She was overwhelmed and understandably nervous that the responsibility for earning $92,000 of incentive funds and avoiding a 2% penalty in 2016 was on her shoulders.

The Stage 2 requirements were a worry. The practice had just recently updated to the 2014 Edition EHR software and the patient portal had only been implemented for a month. She wasn’t sure if they could meet the patient engagement requirements and she didn’t know where they stood with the newly introduced objectives.

She asked for support through her network and found me.

Data > Information > Knowledge

I started by getting access to her EHR and venturing to the reporting module. I found out how each provider was performing on each of the Stage 2 Meaningful Use criteria and compiled the data. In fact, you can see their starting point for yourself by looking at the left side of the below chart. (Hint: click image for better viewing)

 

I could see right away why the practice manager was concerned. You can see on the left side that as of October 5, none of the providers were meeting the criteria for Core 7 (VDT), Core 12 (Patient Reminders), Core 17 (Secure Messaging), or Menu 4 (Family Health History). Only half of the providers were capturing enough vitals information (Core 4) and clearly workflows needed to be reinforced for several others, including Core 1 (CPOE for medication orders), Core 5 (Smoking Status), Menu 2 (Electronic Notes).

They were able to exclude Core 15 (Transition of Care), which is why those rows are blank.

We had 90 days to turn this around.

Team Work

Armed with information, we came up with a plan. The practice manager would work with each doctor and their support staff to communicate the goals, state their status, and ensure that each person was enrolled in doing their part.

Meaningful Use is a team sport, after all.

The nurses were charged with increasing their vitals stats. The administrators made sure that reminders were sent out to patients with a specific diagnosis for preventive or follow-up care. The doctors were instructed to collect smoking statuses for more patients.

We found out that there were new features within the EHR to accommodate Stage 2, so with help from the EHR vendor, we found out how to trigger the numerators for electronic notes and for family health history. It took a couple tweaks in customization and then training on the new workflows.

With each week’s reports, we saw steady improvement. But it was important to keep the pressure on to strengthen the areas of weakness.

Getting Creative with the Portal

In November, we focused diligently on the portal. The practice has several locations, so they started a contest among them to see which office could sign up the most patients to the portal. Some locations struggled more than others, complaining of elderly patients not having access to the internet.

Ultimately, what worked best was incentivizing the patients. They purchased a bunch of $5 gift cards to Amazon and  gave them out to patients AFTER they had both logged in to the portal to view, download, or transmit their health record AND sent a secure message to the doctor.

They even told patients what to say:

Dear [Provider], I was able to see my health record through the portal. Now I know where I can send you messages directly if I have questions. Thanks, [Patient]

This step alone addressed the tougher patient engagement objectives and by mid-November, we started seeing drastic improvements in the VDT and Secure Messaging stats.

The First Big Win

Around the same time, we got the first provider to meet ALL of the percentage-based requirements. It took some targeted attention to improve specific workflows, but once the first doctor demonstrated that it could be done, the others followed right behind him. By the end of November, more than half the providers were hitting the marks; and by the second week of December, all of them were.

Their main focus on closing out the year was to keep up the good work.

Non-Percentage Based Objectives

Some Meaningful Use requirements are not numerator/denominator based and require a Yes/No response. For example, were clinical decision support rules in place and did at least 5 of them related to the chosen Clinical Quality measures? Did each provider generate a patient list for a specific diagnosis for the purpose of sending reminders, outreach, or research? Was a Security Risk Analysis performed and security updates implemented to correct any identified deficiencies? Yes, yes, and yes.

Lessons Learned

1. It sure helps to have engaged team members. The practice manager served as the messenger – communicating where improvements were needed. The doctors were responsive to looking at their data, comparing it with their peers, and then making concerted efforts to improve. The office staff were all willing to step up their game when they understood the mission of engaging patients. The EHR vendor was helpful with setting up the appropriate settings and customizing the EHR when needed.

2. What gets measured gets managed. Sticking our heads in the sand and hoping Meaningful Use would take care of itself simply would not have worked. We needed to know where improvements could be made and the only way to do that was to look at the data often and respond to it.


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OMB Reviewing Proposed Stage 3 Meaningful Use Requirements | EHRintelligence.com

OMB Reviewing Proposed Stage 3 Meaningful Use Requirements | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it

The Centers for Medicare & Medicaid Services is one step closer to issuing a notice of proposed rulemaking (NRPM) for the next stage of meaningful use requirements for the Medicare EHR Incentive Program.

The Office of Management and Budget (OMB) is currently reviewing the proposed rule for Stage 3 Meaningful Use that is expected to be published in February.

Few details about the requirements for Stage 3 appear in the rule submitted to the OMB by the Department of Health & Human Services as part of the Unified Agenda — that is, with the exception of the following:

In this proposed rule, CMS will implement Stage 3, another stage of the Medicare and Medicaid EHR Incentive Program as required by ARRA. We are proposing the Stage 3 criteria that EP’s, eligible hospitals, and CAHs must meet in order to successfully demonstrate meaningful use under the Medicare and Medicaid EHR Incentive Programs, focusing on advanced use of EHR technology to promote improved outcomes for patients.  Stage 3 will also propose changes to the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements.

The rule before the OMG also indicates that CMS will coordinate with the Office of the National Coordinator for Health Information Technology to ensure that EHR certification criteria and certified EHR technology will be in place when Stage 3 goes into effect no earlier than 2017.

During a Health IT Policy Committee meeting in March, the group voted to approve 19 objectives recommended by the Meaningful Use Workgroup. Those recommendations fall into four categories of care improvements:

Improving Quality of Care and Safety
1. Clinical decision support
2. Order tracking
3. Demographics/patient information
4. Care planning — advance directive
5. Electronic notes
6. Hospital labs
7. Unique device identifiers

Engaging Patients and Families in their Care
8. View, download, transmit
9. Patient generated health data
10. Secure messaging
11. Visit Summary/clinical summary
12. Patient education

Improving Care Coordination
13. Summary of care at transitions
14. Notifications
15. Medication reconciliation

Improving Population and Public Health
16. Immunization history
17. Registries
18. Electronic lab reporting
19. Syndromic surveillance

Before any of the proposed rule’s requirements for Stage 3 Meaningful Use are enacted, the NPRM must made available for public comment which has the potential to influence the requirements of the final rule. Given the resistance CMS has faced as a result of Stage 2 Meaningful Use, the federal agency is likely to receive requests for greater flexibility and timing from healthcare organizations and industry groups.


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Physicians Still Sour on Meaningful Use Attestation Changes | EHRintelligence.com

Physicians Still Sour on Meaningful Use Attestation Changes | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it
The adjustments involved in successful meaningful use attestation still get a thumbs-down from pessimistic physicians.

Physicians are still not sold on the idea of changing their daily workflows to meet the requirements of meaningful use, finds a new study in BMC Medical Informatics and Decision Making.  In a survey of 400 providers at 47 ambulatory practices, the researchers found a general unwillingness among all types of physicians to adapt to the needs of Stage 1 meaningful use (MU), and a general lack of confidence in their organization’s ability to rise to the challenges presented by EHR implementation.

The study cites the importance of effective change management strategies as a foundation for preparing healthcare providers for the impact of EHR implementation and meaningful use attestation.  “In busy practice settings, such change efforts are often difficult to implement effectively. In fact, experts have suggested that without sufficient readiness for change, change efforts are more likely to lead to unrealized benefits or fail altogether,” the authors write.  “With billions of dollars invested in MU and the countless hours spent by providers and clinical staff on MU implementation nationally, unrealized benefits from the program would carry significant financial and opportunity costs for health care systems.”

Resistance to the changes involved in meaningful use is nothing new in the healthcare industry.  The study adds to the anecdotal notion that physicians are particularly unwilling to embrace workflow changes due to new technologies and requirements.  While approximately 83% of nurses and advanced practice providers (APPs) indicated a willingness to change their workflow in response to meaningful use, just 57.9% of physicians reported the same.  Nearly 45% of nurses and APPs believed their organization would be able to address any problems that arose during meaningful use attestation, but only 28.4% of physicians were optimistic about overcoming issues.

Specialists were nearly three times more likely than primary care providers to believe that meaningful use would divert significant attention away from the practice of patient care.  Twelve percent of specialists thought their interactions will patients would suffer, compared to 4.4% of other providers.  However, specialists were no more likely than other providers to believe their organizations were unready to tackle meaningful use.

“These results suggest that leaders of health care organizations should pay attention to the perceptions that providers and clinical staff have about MU appropriateness and management support for MU,” the study concludes. “Change management efforts could focus on improving these perceptions if need be as it is feasible that doing so could improve willingness to change practices for MU.”

The authors suggest that organizational leaders invest in education for their staff about the benefits and opportunities involved in meaningful use.  Creating opportunities to provide guidance, demonstrations, and training for EHR proficiency and documentation measures required for attestation may help to ease trepidation among providers, while indicating a strong sense of support along with a clear implementation framework may help to make meaningful use attestation a more successful prospect.


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CMS Extends Hospital 2014 Meaningful Use Reporting Deadline | EHRintelligence.com

CMS Extends Hospital 2014 Meaningful Use Reporting Deadline | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it

While this week marks the end of one and beginning of another year, those in the healthcare industry should take note of all that transpired in the previous year to avoid similar setbacks in 2015. This is especially true for matters scheduled to have been addressed over the last 12 months.

ICD-10 delays, meaningful use changes, health IT vendor competition, and EHR implementation gaffes. Based on the interest of our readers, those were the most popular topics of 2014 on EHRIntelligence.com.

ICD-10 transition delay one more year

More than any other topic on our news site, ICD-10 garners the greatest amount of our readership’s attention and given its high stakes, it makes sense. This past October was supposed to usher in a new era of clinical coding — the move from ICD-9 to ICD-10 — and put the United States on par with other leading nations in terms of healthcare documentation.

The Congressional debate over the sustainable growth rate (SGR), however, swiftly dashed those visions. Close to one week after expectations began to build that Congress would vote on an SGR patch that included a one-year ICD-10 compliance delay, the Senate voted in favor of the bill. While the rest of the nation took this as business as usual on the Hill, the healthcare industry scrambled to put new plans together for postponing their 2014 ICD-10 implementation activities.

What the delay meant to providers depended on where they practices. Larger healthcare organizations reported high levels of ICD-10 readiness while some smaller physician groups and practices were completely unsure where they stood. No matter their view of the most recent ICD-10 delay, most are committed to removing ICD-10 implementation pain points to be ICD-10 ready by Oct. 1, 2015.

The bending but not breaking of meaningful use

This past year began with eligible professionals and hospitals working to achieve Stage 2 Meaningful Use, but that is hard to do when certified EHR technology is unavailable.

Early hints of changes to meaningful use reporting in 2014 emerged as early as February when the Centers for Medicare & Medicaid Services (CMS) introduce a new meaningful use hardship exception dealing with a lack of available CEHRT.

In September, the federal agency finalized a rule intended to give providers greater flexibility in meeting meaningful use requirements in 2014 — known as the flexibility rule. However, this did not turn out to be CMS’s final move.

The flexibility rule was followed by the reopening of the meaningful use hardship exception application submission period for both EPs and EHs and the extension of the 2014 meaningful use attestation period for EHs and critical access hospitals through the end of the year.

Despite their intentions, neither has put to rest repeated calls for 2015 meaningful use reporting requirement changes by industry stakeholders.

Heading to a showdown

Prognosticators in health information technology (IT) have foreseen consolidation in the marketplace over the next few years. But it is unlikely that they saw things playing out as they did in 2014.

Cerner’s acquisition of Siemens Health Siemens over the summer is an example of how quickly and dramatically the market can change. Most viewed the maneuver as a power play by the Kansas City-based health IT company to contend with Epic Systems and its market share among health systems and hospitals.

While the growth of both Cerner and Epic continues to loom large over the industry, they still have to contend with numerous other players in the ambulatory care space, especially given Epic’s recent loss to athenahealth as the top overall software vendor over the past year.

Expect more to come.

Squeaky wheel gets the grease

When EHR implementations go well, those involved in the process are more than willing to share details of their experiences. When they don’t, it is like pulling teeth.

Poorly managed EHR implementations can prove costly. The University of Arizona Health Network saw red of a different variety as a result of its Epic EHR adoption. Whidbey General Hospital felt the financial effects of a software glitch in its MEDITECH EHR that crippled its billing system and left it short on cash. Meanwhile, a Cerner EHR implementation gone awry led to the dismissal of Athens Regional Medical Center’s CEO.

If 2014 was a busy year, then 2015 is only likely to be busier. Stay with us as we continue our coverage of meaningful use, EHR and ICD-10 implementation, and anything else health IT-related that comes our way.



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Role of Integrated EHR Technology in Solving Fragmented Care | EHRintelligence.com

Role of Integrated EHR Technology in Solving Fragmented Care | EHRintelligence.com | EHR and Health IT Consulting | Scoop.it
Authors of a recent Harvard Business Review article claim that integrated care hold the key to resolving fragmented healthcare in the United States.

Pioneering healthcare organizations demonstrate that it is now possible “the integrated-care model and accelerate its adoption more broadly and deeply across the American health care system.” This according to the Institute for Healthcare Improvement and Weill Cornell Medical College’s Kedar S. Mate, MD, and the Permanente Federation’s Amy L. Compton-Phillips, MD. Kaiser Permanente just so happens to be one of them.

Along with aligning payment with integrated care and other measures, the authors of “The Antidote to Fragmented Health Care” identify the creation of universal EHRs a means of achieving an end to fragmented care:

The lack of a single health record for each patient that clinicians from all specialties can access in both inpatient and outpatient settings is an obstacle to integrating care. In addition, patient privacy protections inhibit the sharing of health information, creating both perceived and real hurdles. Back in the 1990s, the U.S. Veterans Administration developed an electronic health record (EHR) that linked information across venues of care and provider specialties. This early work showed that linking clinicians electronically was transformational.

In addition to the example of the VA and its Veterans Health Information Systems and Technology Architecture (VistA) EHR, the authors highlight the positive experiences of EHR end-users at Kaiser Permanente:

Kaiser Permanente has an EHR that is shared by primary care doctors and specialists who work in hospitals and offices and is also used by nurses, pharmacists, physical therapists, and nutritionists. Their ability to collaborate electronically with patients in their homes and with each other using tools such as electronic consultation has fundamentally changed the way medicine is practiced at KP.

While these examples do make a case for integrated EHR technology, they are short on details about the two EHR technologies being used by providers at the VA and Kaiser Permanente.

Kaiser Permanente is using an Epic EHR although it is one that bears the marks of its own optimizations and enhancements. As noted in a report earlier today, the costs of implementing and maintaining an Epic EHR “are significantly higher than comparable competitor products, and, in at least one study, did not produce savings for payers” based on research published in the Journal of the American Medical Informatics Association. Not all healthcare organizations have these kinds of financial resources at their disposal or the expertise necessary for running this EHR technology effectively.

The example of the VA should raise additional doubts about the concept of a universal EHR. Without taking the Phoenix scheduling fiasco into account, the VA is facing significant pressure from Congress to modernize its EHR platform and achieve interoperability with the Department of Defense’s platform, when one is finally chosen.

The longstanding lack of interoperability between the two departments continues to be an obstacle preventing the records of DoD patients moving seamlessly into the VA’s EHR platform. And even with billions of dollars in funding from the federal government, no solution is in sight.

The EHR marketplace is full of players with products capable of supporting a provider’s pursuit of meaningful use and other financial incentives and still health information exchange varies by region and interoperability remains elusive. Technology is only one component of the authors’ vision of integrated care, but it is much more complicated than they demonstrate.



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Protect Electronic Health Information Core Objective -

Protect Electronic Health Information Core Objective - | EHR and Health IT Consulting | Scoop.it
If you are a provider participating in the EHR Incentive Programs, conducting or reviewing a security risk analysis is required to meet Stage 1 and Stage 2 of meaningful use. This meaningful use objective complements, but does not impose new or expanded requirements on the HIPAA Security Rule.

How This Objective Improves Care
Security risk analysis doesn’t just help your organization ensure it is compliant with HIPAA’s administrative, physical, and technical safeguards; this ongoing process also helps reveal areas where your organization’s electronic protected health information (e-PHI) could be at risk. Meeting this objective can help you avoid and address common security gaps that lead to cyber-attack or data loss, which helps protect your practice, information, technology, and the people you serve.

New CMS Guidance for When to Complete a Security Risk Analysis
A security risk analysis needs to be conducted or reviewed during each program year for Stage 1 and Stage 2. These steps may be completed outside OR during the EHR reporting period timeframe, but must take place no earlier than the start of the EHR reporting year and no later than the date the provider submits their attestation for that EHR reporting period.

For example, an eligible professional who is reporting for a 90-day EHR reporting period in 2014 may complete the appropriate security risk analysis requirements outside of this 90-day period as long as it is completed between January 1st of the EHR reporting year and no later than the date the eligible professional submits the attestation for that EHR reporting period. For more information, read the updated FAQ.

Please note:

Conducting a security risk analysis is required when certified EHR technology is adopted in the first reporting year.
In subsequent reporting years, or when changes to the practice or electronic systems occur, a review must be conducted.

Resources for Security Risk Analysis
To help providers understand what’s required to meet this core objective, CMS has a Security Risk Analysis Tipsheet available on the Educational Resources page that includes:

Steps for conducting a security risk analysis
How to create an action plan
Security areas to consider and potential courses of action
Myths and facts about conducting or reviewing a security risk analysis

This information is also available as an intermediate level resource on eHealth University.

Providers in small-to-medium sized offices may also use ONC’s Security Risk Assessment (SRA) tool to conduct risk assessments of their organizations. The tool also produces a report that can be provided to auditors. A User Guide and Tutorial video are available to help providers use the tool.
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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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