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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Decoding Meaningful Use For Your EHR System 

Decoding Meaningful Use For Your EHR System  | EHR and Health IT Consulting |

During EHR implementation, it can become confusing to successfully navigate federal and locally-mandated requirements for regulations concerning HIPAA and Meaningful Use. For many healthcare practices, Meaningful Use attestation has become less of a collaboration in good patient care, and more of a headache – but it doesn’t have to be.

Decoding Meaningful Use and understanding its requirements will not only improve implementation and optimization of an electronic health records system, but it will also result in improved clinical processes, and ultimately, better patient outcomes.


What is Meaningful Use?

Back in 2009, Meaningful Use was developed by the federal government as a way to regulate electronic health records systems, and ensure that providers are on track to make the most out of those systems. Their incentive programs for Medicare & Medicaid generated incredible interest, and within just a few years, had captured most of the US industry. Last year, the ONC reported that of Critical Access and other eligible hospitals, 95 percent had demonstrated Meaningful Use. Meanwhile, according to CMS, over half a million providers had received over $25 billion in federal payments through the Medicare & Medicaid incentive programs as of this summer.

But this brings up an important question: just who benefits from Meaningful Use? The answer is encouraging. When employed properly, Meaningful Use benefits everybody. Providers and their staff benefit from improved clinical processes, billing and insurance parties benefit from standardization, and patients benefit from better care.


Understanding Meaningful Use Incentive Programs

The role of federal incentives is simply to encourage providers to adhere to Meaningful Use requirements through certified EHR systems. Finding vendors that provide certified EHR technology is critical to qualifying for these incentive programs, which have to-date paid tens of billions to providers who have successfully met the requirements of the incentive programs. Not only are these programs designed to improve health outcomes through compliance with important measures, but also encourage certified EHR adoption through effectively lowering the cost of EHR implementation for healthcare organizations.


The Future of Meaningful Use and EHRs

Each year, CMS and the ONC release new updates for Meaningful Use. Currently, the incentive programs have been widely successful, with over 500,000 medical practices having attested for Meaningful Use as of this year. And moving forward, there is still a great deal of opportunity for benefit to both providers and their patients.

There will still be significant pressure from the federal government to achieve even more universal adherence to Meaningful Use. Many of the most ambitious goals of the program can only be achieved through near-universal participation including those regarding information exchange. For Medicaid, 2016 represents the final year of beginning participation in the incentive program. And while CMS’ final rule published in 2015 extended through to 2017, the Center for Medicare & Medicaid Services has already begun constructing their 2017 requirements.

Successfully attesting for Meaningful Use isn’t always easy. That’s why it’s crucial to find an EHR vendor that is ready to support you and your practice every step of the way towards successful implementation.

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For Stage 2 Meaningful Use Attestation, Pick a Larger EHR Vendor

For Stage 2 Meaningful Use Attestation, Pick a Larger EHR Vendor | EHR and Health IT Consulting |

Larger EHR vendors tend to make better partners in achieving Stage 2 Meaningful Use, according to a recent study by Peer60. The study, which discusses insights and trends in EHR vendors, sought to identify the which vendors play a bigger and more supportive role in providers’ work to achieve meaningful use.

According to the report, users of notable vendors such as Epic, Cerner, and Allscripts stated that these technology partners delivered adequate support for their efforts to meet meaningful use. Among these vendors, many users also reported being in the midst of attesting to Stage 2. Epic also had several respondents report that it was not an adequate partner in Stage 2 attestation, but given the high volume of users Epic engages with, the positive reviews significantly outweigh the negative.

Other vendors did not receive such favorable reviews, according to Peer60. Among those is McKesson, who received nearly double the percentage of negative reviews as positive ones. McKesson also has a substantial number of users who report still being in the process of attesting Stage 2. A few smaller vendors also received negative meaningful use reporting reviews, including NextGen and Practice Partners (which is owned by McKesson).

Of the practices surveyed, nearly 90 percent of them have either achieved Stage 2 or are in the middle of attestation. Fifty-six percent of respondents had successfully completed Stage 2 attestation, and 34 percent were in the thick of attesting. Only 10 percent had not successfully attested, and Peer60 reports that about half of those who had not been successful “simply don’t have the proper model to receive enough benefits to bother attesting.”

This report comes out after CMS released data regarding meaningful use registration and participation. Given that data, it appeared as though the delay in the release of the meaningful use modificationrules was hindering program growth. According to CMS, meaningful use enrollment stayed stagnant between the months of May and August. Medicare eligible professional (EP) enrollment also remained relatively the same between May and July, and skyrocketed in August. Likewise, eligible hospital (EH) enrollment stayed consistent between May and July and made a notable jump in August.

Now that the Stage 2 Meaningful Use Modifications Rule has been released, the rate of EHR Incentive Program enrollment may increase. Because the modified rule eliminates unnecessary and cumbersome requirements, as well as shortens the initial reporting period to 90 days, it is expected that more providers will enroll in the program and will be able to achieve success.

However, success could potentially be better facilitated by an EHR vendor that is more supportive and provides a product that works better with meaningful use. As such, EHR vendors may need to adjust their practices in helping providers meet meaningful use guidelines in order to remain competitive in the EHR market.

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Senator Gives 5 Reasons to Delay Stage 3 Meaningful Use

Senator Gives 5 Reasons to Delay Stage 3 Meaningful Use | EHR and Health IT Consulting |

Joining the group of critics of Stage 3 Meaningful Use, Senate Chairman of the Committee on Health, Education, Labor, and Pensions (HELP) Lamar Alexander (R-TN) urged the administration not to move forward with the rule in a statement before administration officials, according to a press release.

Alexander advocated against implementing Stage 3 Meaningful Use rules, stating that doing so would be a detriment to the administration’s goals of providing better and more coordinated care for patients. Using that logic, Alexander stated that there was no downside to taking their time in developing an effective and manageable rule, while giving providers adequate time to achieve Stage 1 and Stage 2 Meaningful Use.

Alexander continued by underscoring the importance of the meaningful use programs in achieving broader goals within the healthcare industry, such as goals for precision medicine and transitioning Medicare payments to value-based payments. Because of the high-stakes surrounding meaningful use, Alexander argues that it needs to be developed carefully in order for it to be effective and successful.

In his testimony, Alexander listed five reasons why the administration should delay the Stage 3 rule:

Stage 2 Has Not Yet Been Successful

First, Alexander explained how Stage 2 Meaningful Use has not yet been successful, citing the statistics that a mere 12 percent of physicians and 40 percent of hospitals have managed to achieve Stage 2 success. It would make more sense, Alexander argues, to pause Stage 3 implementation and allow providers more time to comply to Stage 2.

Medicare Payment Issues Meaningful Use Penalties

In Medicare’s transition from fee-for-service payments to value-based payments, the program has put a priority on providers meeting meaningful use standards. Because of this, providers will face harsh penalties if standards are not met. To that end, Alexander explains, it is important that providers be given ample time to properly meet these standards.

Industry Leaders Also Recommend a Stage 3 Delay

Alexander states that the general consensus that he has gathered amongst prominent providers is an overall fear of Stage 3 rules.

“Physicians and hospitals have said to me that they are literally ‘terrified’ of stage 3, because of the complexity and because of the fines that will be levied,” he explains.

Stage 3 Requirements May Actually Hinder Interoperability

A leading goal for the administration includes the interoperability between EHR systems. However, a recent GAO report which Alexander commissioned stated that many industry stakeholders find thatmeaningful use rules hamper interoperability. This is because they concentrate on achieving program requirements rather than on effectively achieving interoperability.

The Final Rule Should Match the Legislation’s Primary Goals

When developing the meaningful use programs, the administration identified seven goals for the program. Alexander argues that meaningful use rules should match and enhance these goals. The seven goals include:

  1. Decreasing unnecessary physician documentation;

  2. Enabling patients to have easier access to their own health records;

  3. Making electronic health records more accessible to the entire health care team, such as nurses;

  4. Stopping information blocking

    1. This could be described as intentionally interfering with access to my personal health information;

  5. Ensuring the government’s certification of a records system means what it says it does;

  6. Improving standards; and

  7. Ensuring the security and privacy of patient records.

Alexander suggests a timeline that would begin with phasing in Stage 2 Meaningful Use modifications, aiding providers in achieving that step of the overall program. From there, Alexander suggests the administration phase in subsequent stages “at a rate that reflects how successfully the program is being implemented.”

Alexander has advocated for delaying Stage 3 Meaningful Use before. Recently, he and Senator John Thune cosigned a letter to HHS Secretary Sylvia Matthews Burwell. In the letter, the two request that the final rule for meaningful use not be implemented until January 1, 2017 at the earliest. This letter, along with Alexander’s testimony before the administration, are just two examples of congressional resistance to the final rule.

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CMS Chief to Address ICD-10 Implementation in National Call

CMS Chief to Address ICD-10 Implementation in National Call | EHR and Health IT Consulting |

The Centers for Medicare & Medicaid Services (CMS) continues gearing up for the October 1 ICD-10 compliance deadline with Acting Administrator Andy Slavitt scheduled to address the ICD-10 transition during a national provider call later this month.

On August 27, Slavitt will provide a national implementation update as the nation reaches the five-week countdown to October 1. Also scheduled to speak are American Health Information Management Association (AHIMA) Senior Director of Coding Policy and Compliance Sue Bowman and American Hospital Association (AHA) Director of Coding and Classification Nelly Leon-Chisen.

Two recent surveys show industry-wide progress toward a successful ICD-10 transition in October. In July, the 2015 ICD-10 Readiness reportpublished by AHIMA and the eHealth Initiative stated that half of respondents had completed test transactions with payers or claims clearinghouses.

Despite these positive findings, the report also revealed that ICD-10 preparation gaps still remain for many providers in the area of testing and revenue impact assessments. Only 17 percent indicated that they had completed all external testing. Similarly, only a minority of respondents (23%) have contingency plans related to ICD-10 go-live.

More recently, latest ICD-10 readiness survey from the Workgroup for Electronic Data Interchange (WEDI) showed physician practices to be lagging behind their counterparts.

As compared to seven-eighths of hospitals and health systems ready for October 1, less than a half of physician practices indicated they would be ready. This disparity was also evident in the area of provider impact assessments. Only one-sixth of physician practices had undertaken the assessment versus three-fifths of hospitals and health systems. "This lack of progress is cause for concern as it will leave little time for remediation and testing," WEDI reported.

In a letter to Department of Health & Human Services Secretary Sylvia Mathews Burwell, WEDI cautioned that without a concerted effort the ICD-10 transition could lead to negative consequences for the healthcare industry.

"We assert that if the industry, and in particular physician practices, do not make a dedicated and aggressive effort to complete their implementation activities in the time remaining, there is likely to be disruption to industry claims processing on Oct 1, 2015," the organization stated.

Around the same time, CMS provided clarification about ICD-10 flexibilities it make available to providers following a joint statement with the American Medical Association (AMA) in June. The major ICD-10 flexibility is the federal agency's decision not to reject claims coded incorrectly in ICD-10.

"Medicare claims with a date of service on or after October 1, 2015, will be rejected if they do not contain a valid ICD-10 code," the federal agency stated. "The Medicare claims processing systems do not have the capability to accept ICD-9 codes for dates of service after September 30, 2015 or accept claims that contain both ICD-9 and ICD-10 codes for any dates of service. Submitters should follow existing procedures for correcting and resubmitting rejected claims."

Here's a quick look at the agenda for the MLN Connects Call:

  • National implementation update, CMS Acting Administrator Andy Slavitt
  • Coding guidance, AHA and AHIMA
  • How to get answers to coding questions
  • Claims that span the implementation date
  • Results from acknowledgement and end-to-end testing weeks
  • Provider resources

As the entire healthcare industry counts down to October 1, CMS appears ready to ramp up its activities.

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CHIME and Fellow Industry Stakeholders Call on CMS to Expedite MU Modifications Rule

CHIME and Fellow Industry Stakeholders Call on CMS to Expedite MU Modifications Rule | EHR and Health IT Consulting |

The College of Healthcare Information Management Executives (CHIME) joined a diverse group 18 industry stakeholders urging the Centers for Medicare and Medicaid Services (CMS) to finalize the rule that sets meaningful use requirements for 2015 through 2017.

In May, the nation’s leading professional organization of chief information officers (CIOs) and senior IT executives in healthcare, submitted formal comments on the proposed changes to the EHR Incentive Program in which CHIME commended the agency for leading a series of changes to Meaningful Use, specifically the provision to shorten the EHR reporting period in 2015 from a full calendar year to 90 days.

“The additional time proposed by the modifications rule could help hundreds of thousands of providers meet meaningful use requirements in an effective and safe manner. However, we are just 61 days away from the end of the fiscal year, and the final quarter of 2015, yet hospitals and physicians are without the rules outlining the requirements for participation in the program this year,” said Leslie Krigstein, Interim Vice President of Public Policy for CHIME.

While, the efforts of CMS to simplify meaningful use in the 2015-2017 Modifications Rule are welcomed – and will be a key contributor to the ongoing success of the program – “providers and technology developers need to have the certainty now that comes with a Final Rule in order to be able to meet the reporting deadlines for 2015 and continue participation in the program,” stated the stakeholder group, which included provider and vendor representatives.

Unfortunately with the end of the fiscal year CIOs are finding themselves questioning their ability to successfully participate in the meaningful use program if the rules are not released quickly.

“CMS offered many beneficial changes in the proposed Modifications Rule, yet the delayed release may impede providers’ ability to not only take advantage of the proposed changes, but ultimately jeopardize their participation in the 2015 program year,” said Krigstein.

“Immediate clarity on the expectations for providers in 2015 is the best hope for enabling success in the meaningful use program this year.”

Citing the end of the fiscal year approaching, the letter states, “If providers do not receive the Final Rule shortly, it will be very difficult to make workflow adjustments in a timely manner to meet programmatic deadlines and facilitate Meaningful Use tracking and reporting.”

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Latest ICD-10 Developments and What Physicians Should Know

Latest ICD-10 Developments and What Physicians Should Know | EHR and Health IT Consulting |

With October less than three months away, physicians need to be prepared for the ICD-10 conversion.

By now, everyone in the healthcare industry knows that the effective date for ICD-10 implementation is Oct. 1, 2015. Moreover, because of the multiple delays of the effective date of the transition, there is no excuse for physicians not to be ready to change coding systems. Some larger institutions have already been utilizing the more specific standards of the U.S. version of ICD-10. Specifically, ICD-10 in the U.S. has two categories – ICD-CM and ICD-PCS.

ICD-10 CM is “[t]he International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM) is a system used by physicians and other healthcare providers to classify and code all diagnoses, symptoms and procedures recorded in conjunction with hospital care in the United States,”  according to Tech Target. Funded by the U.S. Centers for Medicare and Medicaid, ICD-10–PCS is specific to the United States and is utilized for procedural codes. The biggest obstacle for most physicians and coders is the increased specificity, which translates into a cash-gap increase. If the condition or procedure is not correctly coded, the claim will be denied and have to be re-filed utilizing one of approximately 69,000 ICD-10 CM codes compared to approximately 14,000 ICD-9 CM codes.

On July 6, 2015, the Centers for Medicare and Medicaid (CMS) and the American Medical Association (AMA) issued a joint statement. “ICD 10 implementation is set to begin on October 1, and it is imperative that physician practices take steps beforehand to be ready,” said AMA President Steven J. Stack, MD.  “We appreciate that CMS is adopting policies to ease the transition to ICD-10 in response to  physicians’ concerns that inadvertent coding errors or system glitches during the transition to ICD-10 may result in audits, claims denials, and penalties under various Medicare reporting programs.  The actions CMS is initiating today can help to mitigate potential problems.  We will continue to work with the administration in the weeks and months ahead to make sure the transition is as smooth as possible.”

Simultaneously, Representative Marsha Blackburn (R-TN), introduced H.R. 3018, Coding Flexibility in Healthcare Act of 2015. The purpose of the act was to provide a six-month safe harbor period for the transition to ICD-10 for submitted claims. The bill is still in Committee and has not been voted on by either the House or the Senate.

The takeaways for physicians include:

• Utilize the resources available through the AMA and CMS;

• Coordinate with all insurance companies to make sure that their systems are compatible and see if a “test run” can be done on submission claims;

• Review the contracts of EHR providers and see if there is a provision for a subscriber to recover for lost revenue in the event of a delay, glitch or system error in the claims submission process with ICD-10; and

• Be as specific as possible in medical documentation.

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CMS EHR Incentive Program Modifications to Meaningful Use – 2015 to 2017

CMS EHR Incentive Program Modifications to Meaningful Use – 2015 to 2017 | EHR and Health IT Consulting |

For those of you who spend time caring for patients, rather than keeping up to date on every proposed regulation that comes out of CMS, here are the highlights of one that directly affects you. On April 15, CMS published a proposed rule that makes dramatic changes in Stage 2 of Meaningful Use (MU). Essentially, Stage 2 as we knew it, no longer exists. The final rule, when it is published later this year, will define a new Stage 2 that will be in effect from 2015 through 2017, and possibly longer. The bad news is that everyone impacted by MU is in a holding pattern waiting for the final rule. Once it is published, we will all have to scramble to meet the new requirements before the end of 2015. The good news is that the proposed attestation period for 2015 will be any continuous 90-day period for all eligible professionals (EPs), as opposed to the full year. The proposed rule also addresses many of the concerns we have raised about the excessive reporting requirements contained in the old Stage 2 specification. If you were planning to skip the MU program this year due to the excessive burden of Stage 2, you may want to reconsider. While the final rule will have changes based on comments submitted on the proposed rule, we expect that, overall, it will be similar to the proposed rule.

Here are some of the Highlights:

EHR Reporting Period in 2015 and 2016

First, CMS proposes to align the definition of an EHR reporting period with the calendar year for all types of providers beginning in 2015 and continuing through 2016  and beyond. Specifically, beginning in 2015, this proposal would change the EHR reporting period for eligible hospitals (EHs) and critical access hospitals (CAHs) from a period based on the fiscal year to one based on the calendar year, and thus aligning it with the reporting period for individual EPs.

Second, for 2015 and 2016, CMS proposes to allow all new participants in the EHR Incentive Program (including new EPs, EHs, and CAHs) to attest to meaningful use for an EHR reporting period of any continuous 90-day period within the calendar year. In addition, for 2015 only, all EPs (regardless of their prior participation in the program) will be able to attest to an EHR reporting period of any continuous 90-day period within the calendar year.  So, if you have not begun reporting for this year, you still have time! However, starting in 2016, all returning participants will need to use an EHR reporting period of a full calendar year (i.e., from January 1, 2016 through December 31, 2016).

Finally, CMS proposes changes to many of the individual objectives and measures for Stage 2 of meaningful use, including the following:

  • Changing the threshold from the Stage 2 Objective for Patient Electronic Access measure number 2[1]  from “5 percent” to “equal to or greater than 1″. CMS acknowledges that external factors beyond EPs control can impact their ability to meet this measure. Practices have been reporting since the start of Stage 2 that convincing 5% of patients to perform the specified action is difficult or impossible.
  • Changing the threshold of the Stage 2 Objective Secure Electronic Messaging[2]  from being a percentage-based measure, to a yes-no measure stating the “functionality fully enabled”. As with the patient electronic access measure, practices report that convincing 5% of patients to perform the specified action is difficult or impossible.
  • Consolidating the four Stage 2 public health reporting objectives  into one objective with multiple measure options following the structure of the Stage 3 Public Health Reporting Objective. This provides EPs with much more flexibility in selecting public health reporting objectives that make sense for their practices and for which the reporting capabilities exist.

Essentially, Stage 2 has been completely re-worked to respond to complaints raised by many, and to align it with what is expected in Stage 3. Stay tuned for announcements regarding final CMS decisions on Stage 2 modifications and on Stage 3 requirements.

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EHR Replacement Market May See 7% Annual Growth Rate

EHR Replacement Market May See 7% Annual Growth Rate | EHR and Health IT Consulting |

As computer systems continue to evolve and stronger certified EHR technology is developed, the EHR replacement market will see significant growth over the coming years. Once more healthcare providers begin to implement strategies for Stage 3 Meaningful Use attestation, their respective medical facilities will begin to upgrade their EHR systems in order to improve the quality of patient care as well as population health outcomes.

Kalorama report called EMR 2015: The Market for Electronic Medical Records shows that there will continue to be an annual growth rate of 7 or 8 percent over the next five years for the EHR replacement market. This positions EHR vendors and developers in a strong spot for sector growth.

Whether it is EHR system upgrades or training and consulting, vendors will still see a steady increase in the EHR replacement market, according to a Kalorama Information press release.

"There might be a thought now that everyone has their EMR now so the market won't grow, but I'd argue against that," Bruce Carlson, Publisher of Kalorama Information, stated in the press release.  "There are upgrades, vendor switches, and still untapped physician markets for web-based products.  That being said, it's like any other software market now that the direct incentives are over and as such, vendors need to sell on value."    

As the requirements of the meaningful use stages continue to roll out over the coming years, more physicians and facilities are attempting to avoid the financial penalties under the Medicare and Medicaid EHR Incentive Programs. As such, more providers are switching over from paper records to certified EHR technology and others are upgrading their systems to reflect meaningful use attestation. All of this is stimulating the EHR replacement market to steadily rise.

Medical facilities that don’t implement certified EHR technology by 2015 will face a 1 percent reduction in their Medicare-based claims, which will rise to 2 percent in 2016 and 3 percent for years beyond. This cut in payment from the Centers for Medicare & Medicaid Services (CMS) could damage the financial future of certain hospitals and clinics.

Due to these potential meaningful use penalties, more providers are focused on upgrading and adopting certified EHR technology, which will continue to boost the EHR replacement market.

Vendor replacement contracts are also likely to affect the healthcare industry over the coming years, which will include new implementation of EHR systems, training and consulting fees.

Within the EHR replacement market, the reasoning behind many providers’ choice to upgrade their systems may be due to the need for an integrated EHR and practice management solution, according to

“Revenue Cycle management and integrated EHR vendor loyalty among small practice EHR physician practices is still on a significant upward trajectory,” Doug Brown, Black Book's Managing Partner, said in a public statement. “The EHR/practice billing vendor's abilities to meet the evolving demands of interoperability, networking, mobile devices, accountable care, patient accessibility, customization for specialty workflow, and reimbursement are the main factors that the replacement mentality and late adoption remain volatile especially among solo and small practices.”

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Meaningful Use Program: Why it failed and how to save it

Meaningful Use Program: Why it failed and how to save it | EHR and Health IT Consulting |

Given the "epidemic of waste [that] blights the U.S. health care delivery system," investment in health care information technology systems is a no-brainer. After all, doesn't the magic wand of IT improve the efficiency of every industry it touches? Congress thought so, and, as a result, in 2009, it allocated $20.6 billion as part of the American Recovery and Reinvestment Act to encourage doctors and hospitals to adopt and use IT systems and migrate from their old paper records to the new electronic health record systems. 

Meaningful Use program

To decide who qualifies for these generous incentives, the Department of Health and Human Services, through the Centers for Medicare & Medicaid Services, designed a set of criteria called meaningful use, a three-stage compliance program that requires providers show they're using electronic health records in measurable ways. To receive the financial incentives, doctors and hospitals must attest to reaching different stages of meaningful use.

The first stage of the program was designed to drive medical providers to adopt the records. As long as the government was willing to pick up the tab, doctors were willing to buy fancy electronic health record software and not worry about using it. Electronic health record vendors enjoyed an artificial market created by the billions of dollars of incentives included in the Recovery Act's Health Information Technology for Economic and Clinical Health Act. The majority of providers successfully attested to this first stage and as a result, record adoption rates skyrocketed.

Why the second stage failed

Now that everyone had electronic records, the next stage of the program had to logically focus on using this technology. Unsurprisingly, the second stage was not welcomed in the medical community. As of February 2015, roughly a quarter of physicians had complied with the requirements of this stage. Despite the lackluster results of the second stage of the program, HHS has already proposed the rules for the third stage, which is primarily focused on health information exchange among providers. While my own research documents huge benefits of exchanging health information, I believe that before implementing more complicated rules and regulations, we should have a clear understanding of the reasons for which the second stage of the program has failed. Without learning from the past, the future will not be brighter.

Although policymakers' hunch about the benefits of IT was correct, it failed to understand a nuanced condition under which this magic wand works: organic and voluntary adoption. Imposing these records on the medical community and forcing them to adopt and use this technology was destined to fail. Meaningful use is focused on adoption and use of electronic records as the final goal, which misses the whole point: that IT in health care, just like in any other industry, is a means to achieve the actual goal of efficiency. More importantly, meaningful use considers electronic health records as the only type of IT solution and ignores the fact that there are many other IT services that can help medical providers much more. The "one-size-fits-all approach," as American Medical Association President Steven Stack put it, of meaningful use ignores the differences between physicians and incorrectly assumes that medical care is mass-produced in the same way by all physicians and thus only one IT solution best addresses the unique needs of many different types of medical providers.

Policy recommendations

Meaningful use should have been integrated with the capitated payment models, in which the medical providers are paid a fixed amount per patient and are rather encouraged to provide the best care at the lowest cost. The need to cut costs and increase quality would have driven medical providers to adopt a wide variety of IT solutions that specifically address their unique needs. HHS should have set efficiency as a goal and let medical practices to find out the best way to achieve it through health care IT of their choosing. Instead of mandating physicians to record the smoking statuses and vital signs of all patients, send them reminders about their follow-up visits, and communicate with them through secure electronic messages, meaningful use incentives could have been allocated to fund a wide variety of different IT solutions suggested by medical providers.

Using a small part of the incentives now used for meaningful use compliance, we can run a pilot project and test this idea. HHS should call for proposals for IT projects that each provider, based on its own unique characteristics, deems the best way to cut costs and increase quality. Just like research grants, these proposals can then be evaluated by a panel of experts and funded only if approved. This approach will open up the market for meaningful and innovative IT solutions that actually help medical providers improve their efficiency.

Rather than being stuck with electronic health records as the only IT solution, we can have a national lab in which the performance of many different IT solutions will be tested. Medical providers will find their best way to be more efficient and will adopt the IT solutions that best fits their needs organically and voluntarily. Only then IT will work its magic in the health care sector.

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10 Reasons to Outsource Medical Billing

10 Reasons to Outsource Medical Billing | EHR and Health IT Consulting |

Several years ago, based upon a thorough review of the facts, I recommended a client outsource his practice's billing. It was a peculiar conversation:

Me: You could successfully address a number of issues by outsourcing your billing.

Client: I learned in medical school that it is important to keep billing in-house.

Me: That may have been true at the time. Your current situation is different. Let's talk about it.

Client: I learned in medical school that it is important to keep billing in-house.

That old advice, based on who knows what set of facts, was as universal and unchanging for that physician as "Do no harm" or "When you hear hoof beats, think horses not zebras." Unquestioning loyalty to that premise cost him a lot of money.

Here are some of the benefits that can be achieved with outsourcing billing:

1. Free up office space

If the billing is outsourced, the biller does not need a place to sit and the billing records are somewhere else.

2. Make some employee turnover irrelevant

Make employee turnover in the billing department someone else's problem. Unless your practice is big enough to justify a billing department, with a set of employees with varying skills and levels of sophistication, high turnover is almost inevitable. Some billing work can be mind-numbingly dull and some requires sophisticated skills in analysis, synthesis, and communication. Very few people capable of these higher-level requirements will be satisfied for long with dull routine work.

3. Cut down on incoming phone calls

Office staff is relieved of calls that go directly to the billing service. The biggest benefit, however, is the calls that are never made because billing and claims errors are more often avoided in the first place.

4. Turn a fixed expense into a variable one

Staff and office space are fixed expenses. They cannot go below a certain level no matter how low the volume of billing is. When they go up, they go up in stair steps. If the practice is paying a percentage of collections for the billing service, there is a perfect correlation between collections and cost.

Another benefit is that the interests of the practice and the billing service are aligned. If the billing service increases collections and their rate is anything less than 100 percent of collections, the practice is money ahead.

5. Know what is going on in the marketplace

Access a broader perspective of what's going on in the healthcare marketplace. This is one of the most valuable intangibles. An in-house biller cannot know what other practices in the same specialty are doing and what their outcomes are.

6. Anticipate payer rule changes

Avoid being caught flat-footed when payers' rules change. A good billing service is always aware of proposed and pending changes that can have an impact on the revenue cycle, especially technical changes that seldom hit the radar of a medical practice until reimbursements are impacted.

7. Access solid data analytics

A billing service can help your practice identify what the practice is doing well and poorly, in terms of maximizing legitimate reimbursements. The service will identify bottlenecks in the flow of billing documentation and be able to teach providers and staff how to avoid errors that negatively impact claims.  A really good billing service will also share information about alternative ways to code that result in more favorable reimbursements.

8. Know your accounts receivables

Enjoy the benefit of knowing exactly where you stand in terms of receivables. Any service worth its salt will be able to tell you, at least monthly, the percentage of claims that are paid from the initial submission, how many are 30 days, 60 days, and 90 days outstanding, and which payers are most important to the practice. It's valuable information that an internal billing person almost never has the time to provide.

9. Have a resource at payer offices

The biller in an individual practice deals with all the payers, and is essentially anonymous to all of them. A biller at a billing service typically deals with a subset of payers, and often with a single payer. That allows him to develop personal relationships that expedite problem resolution.

10. Be prepared for a payer audit

You will have an expert advocate in case of a payer's audit. A payer's audit is in the ordinary course of business for a billing service. They know the process and the vocabulary, and they have all the documentation at hand.

In general, it makes good business sense to outsource the billing for most medical practices. That said, the outsourcing must be done to a competent billing service and the relationship must still be managed by the medical practice.

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How Meaningful Use Requirements Support Population Health

How Meaningful Use Requirements Support Population Health | EHR and Health IT Consulting |

Industry stakeholders may debate the value and impact of meaningful use requirements new or modified, but a representative from Coastal Medicine of Rhode Island remain adamant that certified EHR technology and its use are crucial to the healthcare organization's approach to population health management.

"In 2006, we simply could not foresee the crucial role that the EMR would play in population health management. Today, the EMR plays a crucial role in functions," Coastal Medical Chief Operating Officer Meryl Moss, MPA, EMHA, told the Senate Committee on Health, Education, Labor & Pensionsin written testimony earlier this week.

Moss was one of three witnesses called to testify during a hearing on the EHR user experience, much of which focused on health data exchange and health IT interoperability.

"Our initial notion was that the EHR would function like a glorified word processor. In 2006, providers, office staff and leadership were thinking of the EHR only in terms of scheduling, billing, and documentation of care," she explained. "Over time, Coastal recognized the power of the EHR as a tool for mining data to guide proactive outreach and provision of care to patients."

A HIMSS Davis Award winner, Coastal Medical was an early participant in the EHR Incentive Programs as well as the Medicare Shared Savings Program (MSSP) and the Advanced Payment Model has met with success in reducing the total cost of care for Medicare beneficiaries by levering CEHRT.

"Today we view the electronic health record first and foremost as an essential tool for population health management," added Moss.

In her written testimony, Moss credited federal incentive programs and EHR certification standards with promoting EHR use among its providers:

1.  They focused on improving care for patients.

2. They provided a clear road map and guidelines for achieving program goals

3. They supplied dollars for infrastructure development and support; and

4. They created a financial incentive for physicians.

In particular, Moss praised the EHR Incentive Programs for taking some of pressure off of providers in choosing appropriate EHR technology. "Individual physicians and physician groups often do not have the expertise, sophistication or bandwidth to differentiate between individual electronic health records and ensure that the required functionality truly exists in an EHR product," she asserted.

According to Moss, similar incentives are essential to pushing EHR adoption forward and advancing the exchange of health information:

We would recommend that incentive programs continue to reward EHR adoption, interoperability, improved patient access, and improvement of performance on quality measures. This is still new work for many in our industry, and we are learning how to better care for populations of patients every day. These programs help us to focus on what is most important, and provide revenue for infrastructure support that is in short supply in many physician groups.

Alongside incentives should come EHR certification criteria focused on healthcare analytics, which Moss identified as one of her organization's "biggest challenges" and requiring increased attention.

"We would recommend that future iterations of EHR certification criteria include a requirement that data analytics capabilities be integrated into the electronic health record, so that both the financial and clinical data can be analyzed and presented in an efficient and effective manner," she maintained. "We will need such tools if we are to succeed in our mission to provide better care, better health, and lower cost of care for the populations we serve.

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The Dark Age of Meaningful Use

The Dark Age of Meaningful Use | EHR and Health IT Consulting |

A lesson from the future:

We look back at the years between 2010 and 2016  (The lifespan of Meaningful Use) as a dark age in healthcare software.

It was an era where software companies bound by government mandate to churn out horrible software tried to pretend their products increased productivity. “Eligible” providers were brow-beaten to click buttons and fill forms, print things and perform medical decision making without being paid.

Some software companies were successful, in a financial sense, as their armies of sales experts and market segmenters conquered their unassuming customers, brandishing the sabre of “ONC-ACB certified”. Those companies unwittingly managed to stamp out the potential of small physician offices, increasing consolidation to hospitals – and healthcare costs. Eventually, the ONC crest once emblazoned proudly on their chests, became a warning: “This software was designed for Meaningful Use, not Actual Use”.

Linguistically, the term “Meaningful Use” became entwined with “Electronic Health Record”. People forgot that medical software could improve patient care and not tout it’s Meaningful Use certification. An effort was made to ridicule those who believed that government regulations were legitimately harmful to the healthcare industry. The sky was lassoed and we were pulling it down.

A healthcare IT Renaissance:

The tides did turn, however. Visionaries and industry leaders came to realize how harmful Meaningful Use was to innovation.  Lawmakers were educated on how destructive constantly changing software and workflow requirements are to software development and medical workflow management.

The Meaningful Use tax on software companies and medical offices was lifted, allowing thousands of previously suppressed software providers to compete and distinguish themselves in a real market.  Some features that were expected materialized: Usability, Interoperability, support services and cost decreases. Even previously unimagined features appeared.

Those leaders went on to invent a SomethingNew(TM). Like the word processor, the spreadsheet or the iPad, this SomethingNew was created that physicians didn’t even know they needed. A new perspective on medical software was born. Indeed, the term “EHR” was retired as clinicians, politicians and developers realized how much more potential there is beyond “record keeping”.

And all that was required for this medical software revolution was a rollback of a law. No major changes, no reform. Just a realization that a heavy hand will not allow this industry to thrive.

Now, we have our many NewThings(TM). We have NewCardiologyThings, and NewOncologyThings, lots of NewThings. Hospital-employed docs have been shown that it is financially possible to go back to private practice. There is renewed respect for the difficult decisions we entrust our physicians and nurses to make. Medicine became distributed, diverse, healthier.

Now that we have gotten rid of Meaningful Use, it is a good time to be a doctor.  Let’s thank those that came before us for rolling back Meaningful Use. Now.

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Finalization of Stage 3 Meaningful Use May Need Postponement

Finalization of Stage 3 Meaningful Use May Need Postponement | EHR and Health IT Consulting |

With more providers, vendors, and stakeholders sending their comments to the Centers for Medicare & Medicaid Services (CMS) with regard to the proposed Stage 3 Meaningful Use rule, it becomes more apparent that the deadline for the last stage under the Medicare and Medicaid EHR Incentive Programs may need to be delayed in order for hospitals and healthcare professionals to be completely prepared.

The American Hospital Association (AHA) recently sent CMS their comments on the Stage 3 Meaningful Use proposed rule and explained that the federal agency may need to postpone the deadline set forth in order to better develop the “standards and infrastructure” necessary for advancinghealth information exchange. Essentially, AHA proposes that CMS wait until it has more experience with the challenges and achievements under Stage 2 Meaningful Use requirements before moving forward with finalizing the mandates for Stage 3 Meaningful Use.

The AHA Executive Vice President Rick Pollack does support that the Stage 3 Meaningful Use proposed rule expands on health information exchange and patient engagement, but reminds CMS that this year is the first time many providers across the country have implemented Stage 2 Meaningful Use requirements and preparing for a deadline in 2018 will prove difficult.

Currently, there are extensive challenges in attesting to Stage 2 Meaningful Use requirements, Pollack explains in the letter to CMS. Some of the issues to overcome include “lack of vendor readiness, mandates to use untested standards, insufficient infrastructure to meet requirements to share information and compressed timelines.”

Additionally, healthcare providers have found that EHR implementation and upgrades toward improvedinteroperability as well as ICD-10 coding proves to be extraordinarily expensive. AHA discovered that, between 2010 and 2013, US hospitals as a whole spent $47 billion annually to adopt health IT platforms. AHA also mentioned how helpful it is that CMS changed the EHR reporting period between 2015 to 2017 to better address some of these challenges.

Nonetheless, the proposed modifications to Stage 2 Meaningful Use requirements in the middle of its lifecycle only illustrate how various issues need to be addressed before a ruling is finalized and an approaching deadline passes only to find providers unprepared.

“Hospitals strongly support the long-term goal of the EHR incentive programs, and they have been working diligently to implement new health information technology to improve the quality and coordination of care for patients,” Pollack wrote in the letter to CMS. “While the Stage 3 proposals offer promising ideas that could further health information exchange and support greater patient engagement, we do not yet have sufficient experience at Stage 2 to be confident that the proposals for Stage 3 are feasible and appropriate. In addition, the standards and information exchange structures needed to support many of the Stage 3 requirements are not yet mature enough to be included in regulation. Furthermore, Stage 3 proposals such as relying on third-party applications to access sensitive patient data in EHRs may be a successful mechanism for the exchange of patient data information, but they raise important questions about patient privacy and information security that must be carefully considered.”

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Recapping Recommended Changes to Meaningful Use Requirements

Recapping Recommended Changes to Meaningful Use Requirements | EHR and Health IT Consulting |
The American Health Association (AHA) is the latest industry group to share its recommendations for changes to meaningful use requirements following the publishing of modifications to Stage 2 Meaningful Use and requirements for upcoming Stage 3 in October by the Centers for Medicare & Medicaid Services (CMS).

As a result, it's worthwhile in light of the AHA's most recent comments to recap the similar recommendations made by these industry groups representing large constituents of healthcare organizations and professionals.

Adopting 90-day reporting period

AHA joins the College of Healthcare Information Management Executives (CHIME) and Healthcare Information Management Systems Society (HIMSS) in calling for a 90-day reporting period for Stage 3. Echoing CHIME, the former contends that the first year of any stage requires considerable buildup and preparation.

"Experience to date indicates that the transition to new editions of certified EHRs is challenging due to lack of vendor readiness, the necessity to update other systems to support the new data requirements, the mandate to use immature standards, an insufficient information exchange infrastructure and a timeline that is too compressed to support successful change management," AHA Executive Vice President Thomas P. Nickels states.

Postponing the start of Stage 3

Neither AHA nor CHIME wants the next stage of the EHR Incentive Programs to begin prior to 2019. For its part, the former is seeking alignment between meaningful use requirements and those likely to come out of the Medicare Access and CHIP Reauthorization Act (MACRA).

Both organizations have pointed to provider struggles with previous stages of meaningful use as proof that the program's timeframe does not reflect experience-to-date of eligible hospitals and professionals whose success in Stage 1 did not carry over into Stage 2.

"All providers require sufficient time to implement and upgrade technology and optimize performance before moving to more complex requirements for use," adds Nickels.

Eliminating all-or-nothing approach

The American Medical Association (AMA) was likely the first industry group to advance this notion, but it now has company.

AHA, CHIME, and the aforementioned organization all seek the removal of the all-or-nothing thresholds required by the EHR Incentive Programs. AHA goes so far as to set the bar at 70 percent for EPs and EHs in successfully demonstrating meaningful use.

Reducing reporting burden on providers

Here AMA and CHIME are in agreement. The former was much more explicit in calling on CMS to allow providers to get the most out of the data they already have that can be used for the EHR Incentive Programs, Alternative Payment Models (APMs), and the Merit-based Incentive Payment System (MIPS).

Advancing interoperability

AHA, CHIME, and AMA all agree that Stage 3 needs to play a significant role in advancing interoperability and therefore must change significantly in order to do so.

For AHA, it's about use cases. "Prioritization of use cases that accelerate the exchange of the current meaningful use data set that is being captured to support care will build confidence and support for tackling the capture and exchange of additional data elements," writes Nickels.

Echoing AMA, the organization emphasized the need for more time for the healthcare and health IT community to address the issue. "The AHA urges CMS to allow the current market pressures for information exchange from consumers and from new care delivery models to accelerate demand for information exchange," added Nickels.

Many more recommendations comprise the letters from these industry groups to CMS, but a consensus is growing more steadily for some changes.

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AMA Urges CMS to Give Hardship Exemptions for Meaningful Use

AMA Urges CMS to Give Hardship Exemptions for Meaningful Use | EHR and Health IT Consulting |

As the waiting game for the Stage 3 Meaningful Use final rule and Stage 2 modification rule continues, the American Medical Association (AMA) is calling on the Centers for Medicare & Medicaid Services (CMS) to start taking actions to account for their delay. According to a recent press release, AMA is asking CMS to make an automatic hardship exemption due to the delay in the final rule’s release.

According to AMA President Steven J. Stack, MD, many physicians with the AMA are concerned that they will not be able to meet meaningful use standards because the details of the Stage 2 modification rule have not yet been released.

“The AMA has regularly stressed that CMS must finalize Meaningful Use modifications well ahead of Oct. 1 to provide the time that physicians need to plan for and accommodate these changes, yet CMS has continued to delay finalizing this rule,” says Stack. “As a result, many physicians who were counting on this flexibility will be subject to financial penalties under the rules currently in place.”

An automatic hardship exemption would exempt providers of financial penalties if they are not able to meet certain meaningful use standards. CMS developed hardship exemptions for providers who can demonstrate that adhering to meaningful use rules would cause a considerable hardship. AMA maintains that the considerable delay in the final rule is viable cause for an automatic hardship exemption.

The AMA is not the only organization expressing distress over the meaningful use final rule. Many entities, such as the Medical Group Management Association (MGMA) are calling on CMS to extend the meaningful use reporting period due to the delayed final rule.

The organization is concerned that medical groups will not have time to report for the final 2015 reporting period if not given adequate notice of the new EHR Incentive Program modifications.

MGMA stated that even if the modifications rule had been announced in early September, providers still would not have had adequate time to adjust workflows for the final reporting period beginning on October 3. Instead, MGMA suggested CMS extend the reporting period to either the first 90 days of 2016, or the final 90 days of 2015.

Other entities, such as the College of Healthcare Information Management Executives (CHIME), have simply urged CMS to release the modification final rule sooner. CHIME, in addition to several other co-signing industry stakeholders, states that CMS withholding the final rule is preventing providers from having adequate time to prepare to the program modifications.

CHIME reiterated that many industry stakeholders commend CMS’ efforts to refocus meaningful use standards, but feels as though inadequate time is being given to providers to make their own adjustments in time for the October 3 final reporting period.

As the final reporting period is mere days away, CMS will need to release the final rule for the meaningful use modifications soon, or many providers will be left unable to meet the final reporting deadline.

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Meaningful Use Audits: An Update

Meaningful Use Audits: An Update | EHR and Health IT Consulting |

The lion’s share of the CMS EHR incentives have been paid out, especially for those who participated on the Medicare side of the incentive program. The Meaningful Use (MU) incentives are winding down but it is prudent to keep an eye on the rear view mirror and make sure you are up to date on past MU documentation. One of the more common questions we are asked at Meaningful Use Audits has to do with how long after attestation can a CMS Meaningful Use audit take place. What is the look back period? How long does an Eligible Professional (EP) or Eligible Hospital (EH) need to keep their “book of evidence” in a handy place? When it is OK to breathe easy?

Our friends at CMS tell us: “Eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) should retain ALL relevant supporting documentation (in either paper or electronic format) used in the completion of the Attestation Module responses. Documentation to support attestation data for meaningful use objectives and clinical quality measures should be retained for six years post-attestation.”

So six years post-attestation is the period in which an incentive recipient needs to be prepared to respond to an audit. What are the chances you might be audited for an early attestation, say back in 2011 or 2012? I’m not a gambler and have never been too good at calculating odds but I was recently contacted by an EP who had received an audit engagement letter from the gang over at Figliozzi & Company. That EP had never been audited before and received the letter just a few week ago in early September 2015. The audit was for a 2011 attestation. That’s right, the audit was going all the way back to the 2011 attestation. There was scant guidance and clarification from CMS in those early days of MU and I imagine an EH or EPs “book of evidence” could be a bit on the slim side.

I don’t need to tell you what the lesson is here. An occasional glance in the rearview mirror to make sure documentation is intact would not be a bad thing to do.

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Groups Call for Final Changes to Meaningful Use Requirements

Groups Call for Final Changes to Meaningful Use Requirements | EHR and Health IT Consulting |

A group of eight hospital associations have joined voices to ask the Department of Health & Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) to move forward with finalizing proposed changes to meaningful use requirements made earlier this year.

"As organizations representing hospitals and health systems across the country, we are writing to urge the Department of Health and Human Services (HHS) to release, in the immediate future, a final rule making modifications to the meaningful use requirements under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs for fiscal years (FY) 2015 to 2017," they state in a letter to HHS Secretary Sylvia Mathews Burwell.

CMS first indicated that it was considering reducing meaningful use requirements between 2015 and 2017 earlier this year. In January, Deputy Administrator for Innovation & Quality and Chief Medical Officer Patrick Conway, MD, authored a blog post revealing that the federal agency "intended to be responsive to provider concerns about software implementation, information exchange readiness, and other related concerns in 2015."

CMS did not release the proposed rule in question until April and the proposal has made little progress since then which has drawn consideration from multiple industry associations. Just last week, the College of Healthcare Information Management Executives (CHIME)called on the HHS Secretary to finalize the rule.

Now it is the case that the following eight hospital associations have come together to make a similar request:

  • America’s Essential Hospitals
  • American Hospital Association
  • Association of American Medical Colleges
  • Catholic Health Association of the United States
  • Children’s Hospital Association
  • Federation of American Hospitals
  • Premier healthcare alliance
  • VHA Inc.

According to these organization, the finalized rule is long overdue:

The rule is past due, given that it will affect the current program year for meaningful use. Indeed, under current rules, meaningful use applies to fiscal year performance for hospitals. FY 2015 ends on Sept. 30 — fewer than 60 days from now. We recognize that the Centers for Medicare & Medicaid Services (CMS) also proposed to change meaningful use reporting for hospitals from a fiscal to a calendar year. Under that policy, the last possible reporting period would begin on Oct. 3. However, the proposed rule also allowed other reporting periods for earlier dates in FY 2015. Even if reporting is moved to a calendar year, hospitals need the certainty of a final rule now to determine the best reporting period to choose and begin the process of reviewing performance and ensuring they have met all of the revised requirements.

That is not to say that these hospital groups are content with the provisions of the proposed rule as is:

Other proposed changes, such as making e-prescribing of discharge medications mandatory or adding new public health reporting measures, however, would make meeting Stage 2 more difficult. And, given the delay in the release of a final rule, they would be virtually impossible for hospitals to accommodate. Hospitals simply will not have sufficient time to understand the new requirements, work with their vendors to purchase and implement new or revised technology that would accommodate them, and invest in the training and work flow changes necessary to meet the new requirements.

With the closing of the fiscal year coming for eligible hospitals at the end of September, the hospital groups are concerned that the delayed release of the final rule would impose burdens on these providers and have far-reaching consequences.

"Widespread failure to meet meaningful use due to unrealistic regulatory requirements and insufficient technology will undermine hospitals’ ability to use EHRs to improve care and involve patients in their care. It will also result in significant financial penalties for the hospital field. Therefore, we urge HHS to release a final rule as quickly as possible," they add.

No comment yet.!

Approaching an ICD-10 Implementation with Confidence

Approaching an ICD-10 Implementation with Confidence | EHR and Health IT Consulting |

The deadline for implementing ICD-10 is rapidly approaching.  Providers and practices should be preparing for the transition and approaching the implementation with confidence. They should be doing this even with therecent announcement from CMS on creating a one-year grace period, allowing for flexibility in the claims auditing and quality reporting process during the transition.  Addressing the following 11 steps will help assure your practice will be on track for a successful transition on Oct. 1, 2015 and going forward: 


Review the major differences between ICD-9 and ICD-10 and how those differences will affect a clinician’s specialty as well as your organization as a whole. Reviewing the “Official Guidelines for Coding and Reporting” for ICD-10 is a good starting point. 


Include staff from the administrative and clinical sides of your practice and divide up the work that needs to be accomplished. Make sure you communicate the changes required by ICD-10, both from a workflow standpoint as well as clinical documentation.


Consider all the different systems you use, the organizations you exchange data with, as well as what electronic and paper-based workflow processes you use that drive clinical encounters and the billing process.  Make sure all of these are updated and/or modified appropriately for ICD-10 compatibility.


Ask vendors about any needed upgrades to use ICD-10, what training (if any) will be needed, and cost estimates. Don’t forget to ask about the ability to concurrently use ICD-9 and ICD-10 and how long you’ll have the ability to do that.


Make sure you consider software and hardware upgrades, education and training costs, the cost of temporary staff during transition should it be needed, changes to printed materials, additional time for documentation review, and the cost of lost coder, clinical and/or revenue cycle staff productivity.


Ask if all their upgrades to accommodate ICD-10 have been completed and if they haven’t, when they will be. Also ask how they (the clearinghouse and health plans) will help your practice with the transition, when can you test claims and other transitions with ICD-10 codes, and whether they provide a list of any data content changes needed. Don’t forget to ask the health plans when they expect to announce their revised ICD-10-related coverage/payment changes. 


This may be one of the most challenging aspects of ICD-10.  Identify potential documentation issues by beginning to crosswalk ICD-9 codes to ICD-10 codes. The goal should be to identify any gaps in the documentation that prevent a coder from selecting the appropriate ICD-10 code.


Identify your education needs. While everyone will need to be trained, not everyone will need to be trained at the same level. Identify who should be trained on what.  You will also need to identify the best training mode for each group and the timeframe for providing that training. 


Testing is critical to success with implementation.  Plan for both internal and external testing.  This will need to be scheduled, so begin the planning now.


Every practice needs to plan for decreased staff productivity and prepare for the possibilities of other financial challenges during the initial implementation period. You should set aside some cash reserves for the practice. It may also be wise to consider establishing a line of credit. 

Preparing now for the transition to ICD-10 will help ease the burden of compliance on Oct. 1, 2015 and assure you will not have a major disruption in your practice revenue.


Make sure you familiarize yourself with the new grace period rules, including some key points below. CMS also announced the establishment of a communication center and an ICD-10 ombudsman to help receive and triage physician and provider issues. 

  • Medicare contractors will not deny claims based solely on the specificity of the ICD-10 diagnosis code as long as a valid code from the right family of ICD-10 codes is used. Moreover, physicians will not be subject to audits as a result of ICD-10 coding mistakes during this one-year period.
  • Physicians will not be penalized under the various CMS quality reporting programs for errors related to the additional specificity of the ICD-10 codes, again as long as a valid ICD-10 code from the right family of codes is used.
  • If Medicare contractors are unable to process claims within established time limits because of ICD-10 administrative problems, such as contractor system malfunction or implementation problems, CMS may in some cases authorize advance payments to physicians. 
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Frustration with Stage 3 Meaningful Use Continues to Build

The long wait for the publication of the final rule for Stage 3 Meaningful Use is allowing for frustration to build before these meaningful use requirements are ultimately enacted.

According to Brookings Institution Fellow Niam Yaraghi, the proposed objectives for this next phase of the EHR Incentive Programs will made success unachievable for eligible professionals and hospitals because the onus is not on these providers alone.

"That is, if other providers do not send electronic summaries, the medical provider who was supposed to receive them will fail to meet the second and third requirement," he writes.

"This scenario is very likely to happen," Yaraghi continues, "Roughly a quarter of physicians have attested to the second stage of the program. This tech-savvy minority is already sharing a large portion of their patients with other providers who were not able to meet the second stage of meaningful use, and thus are likely unable to send electronic care summaries."

Yaraghi contends that another significant problem is working against the EHR Incentive Programs, which is the lack of meaningful exchange of health information:

The main advantage of electronic exchange over paper exchange is that complete patient information will be available to medical providers whenever they need it. Completeness of records and timeliness of access are the two key advantages of the electronic exchange; the objectives defined in stage three of this program fail to address both of them. Instead, after implementing the proposed rules, the completeness of the records depends on patients' ability to recall their previous providers and the willingness of other providers to send care summaries. The timeliness of access to such records depends on other providers' availability and responsiveness.

Researchers are not the only individuals becoming frustrated with the direction and progress of meaningful use. The American Medical Association (AMA) in conjunction with the Medical Association of Georgia (MAH) held a town hall on Monday evening, calling on physicians to demand a reboot of the program.

"Government requirements have twisted EHR technology so it interferes with face-to-face discussions with patients, requires physicians to spend too much time performing clerical work and creates new costs that divert resources away from patient care improvements," the associations said in a joint statement prior to the event. "Meanwhile, the much anticipated benefits of being able to share important patient health care information electronically among providers in different settings have gone unfulfilled."

The town hall coincides with AMA's launch of a new campaign with the purpose of postponing the finalizing of Stage 3 Meaningful Use requirements, dubbed Break the Red Tape.

The campaign's website highlights physician EHR dissatisfaction a prime motivator behind championing for delaying Stage 3.

"Physicians are frequently trailblazers when it comes to using new medical technology," it reads. "Yet, there is one area of technology that many physicians do not love — their electronic health record (EHR). While most (80%) physicians have an EHR, the vast majority of physicians are extremely dissatisfied with their systems."

As part of the initiative, AMA is calling on physicians to share their experiences with AMA and its members as well as write to Congress in order to garner support for a delay.

"It appears that the federal government will finalize MU Stage 3 without realigning the other programs. The current direction of the MU program is bad for patients and physicians," the campaign's website also states. "If finalized this fall, MU Stage 3 regulations will determine what EHRs and the practice of medicine will look like in years to come."

Break the Red Tape also includes a question and answer component that provides further details about the AMA's views of EHR technology and meaningful use.

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Should Patient-Reported Outcomes Be Incorporated in EHRs?

Should Patient-Reported Outcomes Be Incorporated in EHRs? | EHR and Health IT Consulting |

Both Stage 2 and Stage 3 Meaningful Use requirements under the Medicare and Medicaid EHR Incentive Programs emphasize the need for patient engagement. With the widespread use of certified EHR technology, should patients have the ability to record or provide patient-reported outcomes within these systems?

Whether patients should have this ability or not depends upon healthcare service providers. According to a survey from Cutting Edge Information, 68 percent of clinical trials at top companies now utilize patient-reported outcomes while 90 percent of small pharmaceuticals developing clinical trials incorporate patient-reported data in their health IT systems.

“Although PROs (patient-reported outcomes) are increasingly embraced in the pharmaceutical industry, life science organizations must not rely solely on these measures to support regulatory approval,” Victoria Cavicchi, research analyst at Cutting Edge Information, said in a public statement. “Teams should play a balancing act and incorporate the right mix of traditional clinical evidence with patient responses to build the strongest case for emerging products.”

As the healthcare industry continues to push forward patient engagement and the inclusion of patient portals, clinical teams conducting drug trials may benefit from patient-reported outcomes when it comes to all effects of a drug including its overall success rates.

More life science companies have been including this type of data in their clinical trials to ensure all drug side effects are accounted for. However, one barrier standing in the way of patient-reported outcomes is the approval of the Food and Drug Administration (FDA).

Biomarkers and other biological endpoints are more likely to be approved for trial inclusion by the FDA than patient-reported outcomes. Nonetheless, the survey indicates that it is beneficial for pharmaceuticals to include both biological endpoints as well as patient-reported data within clinical studies.

There are several other barriers to incorporating patient-reported data in EHR and health IT systems. Acase report published in the Journal of the American Medical Informatics Association (JAMIA) shows a variety of different challenges that healthcare providers will need to overcome in order to incorporate patient-generated information within electronic medical systems.

The researchers of the case study considered clinical observations among staff, providers, and patients as well as written feedback from end-users and system development meetings. Some of the barriers uncovered include clinical benefit uncertainties and issues with time, workflow, and practice efforts.

However, there were several key aspects that facilitated patient-reported outcomes such as usable system interfaces, process automation, and collecting relevant patient-generated data at the right time.

When it comes to using EHR technology to gather patient-reported outcomes, it is vital to ensure there is clinical relevancy as well as to minimize provider and patient burdens. As the healthcare industry continues to push forward patient engagement and develop new uses for complex medical technologies, it is likely that patient-reported outcomes will gain more clinical benefits throughout the healthcare spectrum.

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ICD-10: CMS won't deny claims for first year

ICD-10: CMS won't deny claims for first year | EHR and Health IT Consulting |

In a surprise concession, the Centers for Medicare & Medicaid Services announced Monday that it would work with the American Medical Association on four steps designed to ease the transition to ICD-10.

Despite longtime disagreements on the topic, CMS will now adopt suggestions made by none other than the AMA with regard to the code set conversion. Those changes concern:

1. Claims denials. "While diagnosis coding to the correct level of specificity is the goal for all claims, for 12 months after ICD-10 implementation, Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family," CMS officials wrote in a guidance document.

2. Quality reporting and other penalties. "For all quality reporting completed for program year 2015 Medicare clinical quality data review contractors will not subject physicians or other Eligible Professionals (EP) to the Physician Quality Reporting System (PQRS), Value Based Modifier (VBM), or Meaningful Use 2 (MU) penalty during primary source verification or auditing related to the additional specificity of the ICD-10 diagnosis code, as long as the physician/EP used a code from the correct family of codes," CMS explained. "Furthermore, an EP will not be subjected to a penalty if CMS experiences difficulty calculating the quality scores for PQRS, VBM, or MU due to the transition to ICD-10 codes."

3. Payment disruptions. “If Medicare contractors are unable to process claims as a result of problems with ICD-10, CMS will authorize advance payments to physicians,” AMA president Steven Stack, MD, noted in a viewpoint piece on the group’s website.

4. Navigating transition problems. CMS intends to create a communication center of sorts, including an ICD-10 Ombudsman, "to help receive and triage physician and provider issues." The center will also "identify and initiate"resolution of issues caused by the new code sets, officials added. 

"These provisions are a culmination of vigorous efforts to convince the agency of the need for a transition period to avoid financial disruptions during this time of tremendous change," wrote Stack.

While AMA played a pivotal role in bringing about these CMS concessions, it was not the only party calling for a smoother conversion to the new code set.

Some members of the U.S. Congress have publicly suggested a dual-coding conversion period wherein CMS would accept and process claims in both ICD-9 and ICD-10. Instead of dual coding, CMS indicated that "a valid ICD-10 code will be required on all claims starting Oct. 1, 2015."

So as things stand today, providers have to use ICD-10 come October – but CMS will be more flexible about denials and payments than it has previously suggested it would be.

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Do Meaningful Use Requirements Need the 5% Objective Back?

Do Meaningful Use Requirements Need the 5% Objective Back? | EHR and Health IT Consulting |

Ever since the proposed modifications to Stage 2 Meaningful Use requirements were announced, a wide variety of opinions and objections surfaced throughout the healthcare industry. For instance, patient engagement advocates are calling for a Data Independence Day. Other medical societies are sending forward their comments about both the proposed Stage 3 Meaningful Use requirements as well as the potential modifications to Stage 2.

HIMSS is one organization that supports some aspects that the Centers for Medicare & Medicaid Services (CMS) is pushing forward in the latest proposals for Stage 3 Meaningful Use requirements. For instance, reducing redundant reporting is very beneficial for the healthcare industry, according to a letter HIMSS representatives sent forward to CMS.

For example, HIMSS is supportive of the new 2015 Stage 2 Meaningful Use change to a 90-day reporting period. However, HIMSS is also looking to encourage CMS to develop a phased-in approach to meeting the Patient Electronic Access objectives under meaningful use requirements.

“HIMSS recommends a balanced approach for meeting this objective that recognizes the challenges that some providers are encountering as they try to get their patient population more engaged on viewing, downloading, or transmitting their information to a third party,” the letter stated. “As a part of this approach, given the tight timeline between the publication of this Final Rule and the end of calendar year 2015, CMS could leave the proposed measures in place for 2015, and then phase-in increased threshold requirements for 2016 and 2017, increasing each 1%, 2% to 3% per year to propel the field forward... Overall, HIMSS believes a phased-in approach for the patient electronic access objective to be an appropriate and balanced step forward.”

The Consumer Partnership for eHealth (CPeH), the Consumer-Purchaser Alliance (C-P Alliance), and other organizations sent a letter to CMS expressing their concern over a specific modification on patient engagement objectives under Stage 2 Meaningful Use requirements. Now that CMS intends to only have one patient view, download, and transmit their information under Stage 2 Meaningful Use, many organizations are pushing for bringing back the prior 5 percent requirement.

“CPeH, C-P Alliance, and the undersigned organizations and individuals are dismayed that CMS intends no longer to require that five percent of patients1 view, download or transmit their health information or send a secure message to their providers,” The letter from the Consumer Partnership for eHealth states. “Instead, CMS proposes that doctors and hospitals merely show that just one patient used online access to their health information, and that secure messaging was merely turned on, not whether any patient has actually used it. We are deeply disappointed in CMS’s reversal of these essential commitments to patient and family engagement.”

Healthcare providers should be able to meet the 5 percent requirement and better engage patients with their medical information, according to the letter. Additionally, prior analysis shows that this should be achievable, which is why the new CMS modification is causing such an uproar in the medical community. Research shows that more than half of patients want to be able to email their healthcare provider, which is why the secure messaging aspect of a patient portal should increase patient engagement if properly leveraged. CMS would be wise to take these comments under advisement as they continue to develop meaningful use requirements.

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Health Information Exchange Should Extend Past Meaningful Use

Health Information Exchange Should Extend Past Meaningful Use | EHR and Health IT Consulting |

The efficient sharing of medical data is key to improving patient care across the country, which is why the federal government has pushed forward the development of the state health information exchange (HIE). Ever since the Health Information Technology for Economic and Clinical Health (HITECH) Act was passed in 2009, the healthcare industry has been adopting certified EHR technology and attempting to improve connectivity among healthcare IT systems as well as develop effective medical data exchange.

To learn more about the progress of health information exchange developments, the Office of the National Coordinator for Health IT (ONC) has worked with NORC at the University of Chicago to evaluate the program over a handful of years.

In a finalized report called “Provider Experiences with HIE: Key Findings from a Six-State Review,” a summary of healthcare provider interviews detail the priorities and needs of the medical industry, case studies of health information exchange systems, and the challenges overcome during HIE program development.

Between March and May of 2014, the organization conducted site visits as well as general provider interviews and discussions throughout six states, which included Iowa, Mississippi, New Hampshire, Utah, Vermont, and Wyoming. The discussions revolved around viewpoints on state health information exchange programs as well as general attitudes toward medical data exchange.

A wide variety of medical facilities were visited such as long-term care centers, hospital associations, critical access hospitals, and physician organizations. Several key findings were uncovered. For example, HIE needs go beyond meeting meaningful use regulations or system connectivity. Providers now needs HIE systems to proffer important clinical data at the point of care to enhance the delivery of medical services along with care coordination.

“Meaningful use and payment reform are creating new requirements for health IT-enabled information sharing related to care coordination and management as well as new models for patient care,” the report stated. “Providers anticipate a growing need for vendor provided HIE services and infrastructure as expectations for electronic exchange of health information increase under this shift.”

The provider interviews also found that healthcare professionals encountered a variety of obstacles when it comes to advancing health information exchange at their facility. These challenges include competing priorities, difficulty managing the revenue cycle, lack of training or experienced staff, and insufficient support from their EHR or HIE vendors.

Some positive findings from the discussions revolve around the bringing of awareness for state health information exchange programs and the benefits of data sharing. Essentially, providers see the need for health information exchange. While the EHR Incentive Programs may not have targeted long-term care and behavioral health facilities, state HIE programs did further involve the participation of these providers.

“Awareness of and demand for HIE has been steadily increasing throughout the life of the program,” the report concluded. “Providers we spoke with in previous and current activities reported an appreciation for the State HIE Program’s role in communicating with providers of all types, bringing together stakeholders, and communicating the value of HIE. Now that HIE is better established—both in terms of visibility and available services—providers have identified new priorities and challenges. These have evolved from early issues surrounding basic implementation and awareness of the benefits of HIE into a search for solutions to meet greater demand for information, while balancing cost and multiple information exchange priorities.”

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Debating Meaningful Use Requirements for Patient Engagement

Debating Meaningful Use Requirements for Patient Engagement | EHR and Health IT Consulting |

The proposed reduction of patient engagement meaningful use requirements between 2015 and 2017 has received a mixture of support and criticism from industry stakeholders.

Both the Medical Group Management Association (MGMA) and Healthcare Information and Management System Society (HIMSS) support reducing the threshold for view, download, and transmit and secure messaging as well as many other components of the proposed modificaitons to meaningful use in 2015 to 2017.

Conversely, the Consumer Partnership for eHealth (CPeH) and Consumer-Purchaser Alliance (CP-Alliance) contend that the modifications to patient engagement meaningful use requirements constitute a "dramatic retreat."

"CPeH, C-P Alliance, and the undersigned organizations and individuals are dismayed that CMS intends no longer to require that five percent of patients view, download or transmit their health information or send a secure message to their providers," the organizations state in a letter to the Centers for Medicare & Medicaid Services (CMS) Acting Administrator Any Slavitt.

The two organizations and their cosigners argue that the proposed modifications have serious ramifications for patients and their caregivers, such as undermining national initiatives for healthcare reform.

"A minimum standard of 5 percent signals a genuine expectation by CMS that organizations make the process changes necessary to support online access; it is meaningful enough to drive real progress in patient and family engagement and real change in clinical culture," they continue. "Dropping to just one patient, and merely turning secure messaging on, signals a drastic reversal in CMS's expectations of providers and patient engagement."

In contrast to these comments from the patient perspective, MGMA and HIMSS have issued comments from the point-of-view of providers struggling to meet these meaningful use requirements.

"While we may agree that as technology improves patients may become more engaged in their healthcare, the industry is clearly not at the stage to support arbitrary thresholds for patient engagement measures," writes MGMA President and CEO Halee Fischer-Wright, MD, MMM.

MGMA claims that many specialty physicians do not have the ongoing patient relationships necessary for meeting the five-percent VDT requirements. What's more, the organization debates whether the patient engagement requirements put forth by CMS address the needs and wants of patients.

"It is true that more and more patients want to leverage online functionalities when interacting with the healthcare system," the MGMA letter states. "However, our members report that patients are far more interested in utilizing online administrative tools such as appointment scheduling, prescription refill requests, reviewing and paying outstanding balances, and completion of registration, HIPAA, and other forms."

According to MGMA, getting patients to use these administrative services should lead them to leverage VDT of their records.

For its part, HIMSS is calling on CMS to take a phased approach to patient engagement requirements for the EHR Incentive Programs going forward:

"As a part of this approach, given the tight timeline between the publication of this Final Rule and the end of calendar year 2015, CMS could leave the proposed measures in place for 2015, and then phase-in increased threshold requirements for 2016 and 2017, increasing each 1%, 2% to 3% per year to propel the field forward.  We propose that this approach continue for Meaningful Use Stage 3 in 2018 and beyond; we emphasize that incremental increases avoid substantial jumps from year to year, or between stages."

The organization maintains that a phased approach will allow technology to evolve and become more user-friendly, making it a highly valuable tool for patients.

The comment period for these proposed meaningful use modifications closed on June 15.

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Are Meaningful Use Requirements Enough for Patient Engagement?

Are Meaningful Use Requirements Enough for Patient Engagement? | EHR and Health IT Consulting |

As Stage 2 Meaningful Use requirements have pushed forward the need for healthcare providers to offer patients a means to download, view, and transmit their electronic medical information, more healthcare facilities have implemented patient portals and encouraged their consumers to utilize these tools.

The Office of the National Coordinator for Health IT (ONC) discusses in an article how meaningful use requirements under the Medicare and Medicaid EHR Incentive Programs, the Blue Button Initiative, and the Health Insurance Portability and Accountability Act (HIPAA) have all brought more focus on patient engagement throughout the healthcare industry.

While there has been a greater aim toward patient engagement through meaningful use requirements within the sector, are patients actually interested in seeing their records through web-based or electronic means? Are there enough consumers who demand to see their medical information online through a patient portal? The HealthITBuzz article attempts to answer these questions.

The most important question to answer is, out of all patients who are offered electronic access to their data and a secure messaging platform to communicate with their physicians, how many have actually utilized these tools. A data brief called Individuals’ Access and Use of Their Online Medical Record Nationwide shows the general use of online health tools and patient access to their records.

The results show that approximately one-third of American patients experience some type of gap with regard to health information exchange. The most common issue that 18 percent of patients experience is the need to tell a healthcare provider about one’s medical history due to the lack of patient records from a prior provider. Additionally, 18 percent of patients had to bring in an MRI, X-ray, or other test result to a doctor’s appointment due to lack of sharing pertinent medical data among different facilities.

Based on results from a consumer survey taken in 2013, a total of 28 percent of patients were offered electronic access to their web-based health record due to the stipulations within meaningful use requirements. The results also show that only 46 percent of those offered access actually viewed their medical information one or more times. Only 10 percent of those given access to their data viewed their patient record six or more times.

However, a total of 60 percent of those who accessed their data found it “very useful” while another 28 percent regarded it as “somewhat useful.” These statistics show promise that, over time, patients will see the benefits of utilizing portals to view their health records and patient engagement with their wellness can grow steadily.

“A majority of those that accessed their online record considered the information very useful. Even among the survey respondents who did not access their medical records online, a majority viewed secure online access to those records as very or somewhat important, and this was nearly universal among those who did access their online record,” stated ONC representatives in the HealthITBuzz article.

As new technologies evolve and healthcare providers continue to implement patient portals and other secure messaging platforms, patient engagement should steadily increase throughout the country.

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