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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How Stage 3 MU Concerns Impact EHR Incentive Programs

How Stage 3 MU Concerns Impact EHR Incentive Programs | EHR and Health IT Consulting |

The Medicare and Medicaid EHR Incentive Programs will be impacted by the latest Stage 3 Meaningful Use proposed rule. The proposed ruling calls for stricter security measures for protecting patient health information, increasing the amount of electronic prescribing and computerized order entry conducted in hospitals and physician practices, and pushing forth patient engagement efforts.

“Transmitting the prescription electronically promotes efficiency and patient safety through reduced communication errors,” the Stage 3 Meaningful Use proposed ruling states. “It also allows the pharmacy or a third party to automatically compare the medication order to others they have received for the patient that works in conjunction with clinical decision support interventions enabled at the generation of the prescription.”

Currently, there is a comment period in which providers, vendors, and other stakeholders can offer their perspective on some of these meaningful use requirements and state which objectives are not achievable.

Once the final ruling for Stage 3 Meaningful Use requirements is established, however, providers who are unable to meet the objectives will need to file a hardship exemption and ensure there is evidence of their burden. Otherwise, these healthcare providers will receive a payment penalty from the Centers for Medicare & Medicaid Services (CMS).

The healthcare providers who do meet Stage 3 Meaningful Use objectives, on the other hand, will receive payment incentives from CMS. While some hospitals and practices have seen financial incentives from the Medicare and Medicaid EHR Incentive Programs, others have been burdened with payment penalties as well as the major financial investment from implementing EHR systems, according to the JD Supra publication.

With around half of healthcare providers not meeting Stage 2 Meaningful Use requirements, it remains to be seen whether the federal government will ease its restrictions and allow more time for struggling healthcare professionals to catch up.

Some are concerned over the set objectives in the Stage 3 Meaningful Use proposed ruling such as the goal of ensuring 25 percent of patients view and download their health information through portals.

Another major complication that CMS set forth is the requirement of all eligible hospitals and providers to attest to Stage 3 Meaningful Use by 2018 regardless of prior attainments. There will also be an optional period in 2017 to attest to Stage 3 Meaningful Use requirements. Those who feel incapable of meeting Stage 3 within the next three years should send comments to CMS and the Office of the National Coordinator for Health IT (ONC) before the May 29 deadline.

Others are concerned with the EHR reporting period beginning in 2017, which will require providers to report on a full calendar year. However, this system is meant to align the Medicare and Medicaid EHR Incentive Programs with other CMS initiatives such as the Physician Quality Reporting System.

Even with the many issues surrounding reaching Stage 3 Meaningful Use requirements, the proposed ruling aims to improve quality of care by expanding health information exchange, EHR interoperability, and patient engagement efforts.

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Healthcare Industry Reacts to Stage 3 MU Proposed Rule

Healthcare Industry Reacts to Stage 3 MU Proposed Rule | EHR and Health IT Consulting |
On March 20, the Centers for Medicare & Medicaid Services (CMS), the Office of the National Coordinator for Health IT (ONC), and the U.S. Department of Health and Human Services (HHS) announced that the latest proposed ruling on Stage 3 Meaningful Use requirements have been released for public comment.

The announcement emphasizes how the proposed rules will give providers more flexibility under the EHR Incentive Programs and increase EHR interoperability to improve the access and sharing of patient health information.2015-01-12-chime-small

The healthcare industry as a whole is currently processing the proposed ruling and preparing to contribute during the comment period. Some public statements about the Stage 3 Meaningful Use proposed ruling from leading organizations have been released.

A statement from the College of Healthcare Information Management Executives (CHIME) said: “CHIME is closely evaluating both the CMS Meaningful Use rule and the ONC certification rule. Based on our initial review, we are pleased to see flexibility built into the Stage 3 proposed objectives. We are still trying to understand the implications of moving all Medicare providers to a single definition of MU by 2018, but are encouraged by the potential for this policy to simplify and streamline the long-term viability of Meaningful Use. While we and other stakeholders have been critical of the program over the last two years, we have always underscored how vital Meaningful Use is to modernizing our nation’s healthcare system. We look forward to digging further into the rule, looking for elements that will allow providers to build on their IT investments, specifically in the areas of care coordination, patient engagement and interoperability.”

“We do, however, urge CMS to quickly publish the proposed rule alluded to in Dr. Conway’s January 29 announcement. We were encouraged by the signals to shorten the 2015 EHR reporting period from 365 to 90 days and make other program improvements through a follow-on rule. We call on CMS to propose policy changes to the ‘all-or-nothing’ construct, lengthen timing between required Stage upgrades, and consider much-needed revisions to the hardship exception categories. These changes will enable far better participation among providers, which will in turn, keep them on a path towards improved care through health IT.”

With the inclusion of some more policy changes, CHIME recognizes that Stage 3 Meaningful Use regulations will play a pivotal role in expanding health IT adoption across the country and thereby improving the quality of care. Another statement comes from the American College of Cardiology President Kim Allan Williams Sr., M.D., on the organization’s reaction to the proposed ruling.

“The American College of Cardiology has long supported the adoption of electronic health records (EHRs) as a mechanism for improving patient outcomes,” Williams said. “The EHR Incentive Program as currently structured has been focused more on ‘checking the box’ than changing care delivery to achieve the goal of improved patient care.”

“Although the ACC is still reviewing the proposed regulations, the College is concerned by the proposal to require all providers, even first-time participants, to report for a full calendar year,” the American College of Cardiology President continued. “Implementing an EHR system in a physician practice or a hospital is not as simple as flipping a switch; it takes time, financial investment, careful consideration and planning, as well as education for all staff. The program must take this learning curve into consideration.”

Some players within the healthcare industry find the EHR reporting period of a full calendar year problematic and are urging CMS to transition to a 90-day reporting period instead.

Additionally, there may be too many regulations that are being put forth to advance the meaningful use of health IT systems instead of addressing the various problems in the medical industry today. A statement from the American Hospital Association (AHA) underscores this point.

“Hospitals are implementing electronic health records at a brisk pace in order to improve patient health and health care, but they must do so under the crushing weight of government regulations,” Linda E. Fishman, Senior Vice President of Public Policy Analysis and Development at AHA, said in a public statement. “The release of today’s rule demonstrates that the agency continues to create policies for the future without fixing the problems the program faces today. In January, CMS promised to provide much-needed flexibility for the 2015 reporting year, which is almost half over. Instead, CMS released Stage 3 rules that pile additional requirements onto providers. It is difficult to understand the rush to raise the bar yet again, when only 35 percent of hospitals and a small fraction of physicians have met the Stage 2 requirements.”

“We urge CMS to release the 2015 flexibility rules immediately. Information technology holds the promise of enhancing care for patients and communities,” Fishman continued. “America’s hospitals are committed to adopting technology but need today’s problems to be addressed to make progress for patients and communities.”
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Breaking Down the Health IT Impacts of Stage 3 Meaningful Use

Breaking Down the Health IT Impacts of Stage 3 Meaningful Use | EHR and Health IT Consulting |

The Centers for Medicare and Medicaid Services (CMS) released its proposed rule for Stage 3 meaningful use on March 20, revealing the hotly anticipated provisions for the final phase of the EHR Incentive Programs.

Raising the bar on some of the toughest aspects of Stage 2 while requiring healthcare providers to make some significant leaps in EHR adoption and care delivery by 2018, the Stage 3 meaningful use framework poses some difficult questions for eligible providers and hospitals struggling with interoperability and the burdens of leveraging EHRs for patient care.

From health IT interoperability to privacy and security to big data analytics, the impacts of Stage 3 will touch nearly every aspect of the healthcare industry in the next few years.

What are some of the key issues providers must keep in mind as 2018 approaches and the EHR Incentive Programs eventually come to an end?

Top 8 goals of the Stage 3 meaningful use proposed rule

The objectives and thresholds in Stage 3 urge providers to new heights in patient care by encouraging more extensive use of health information exchange, e-prescribing, clinical decision support, and computerized provider order entry (CPOE).  CMS also hopes to increase patient engagement substantially over Stage 2 levels and promote the coordination of care through expanding access to personal health information.  Read a summary of the eight major objectives included in CMS’ plan for the industry.

Interoperability key to Stage 3 meaningful use requirements

Industry-wide EHR interoperability is the ultimate goal of the EHR Incentive Programs, and Stage 3 hopes to bring providers closer to widespread health information exchange than ever before.  “The flow of information is fundamental” to better care, healthier patients, and reduced costs, says HHS Secretary Sylvia Burwell, but the path towards meaningful interoperability has been a difficult one.  Stage 3 intends to address some of the major barriers to interoperability by raising thresholds and benchmarks for health information exchange.

Can Stage 3 meaningful use CEHRT bring on big data analytics?

Stage 3 brings some major changes to the way EHR technology is certified and designed in accordance with the EHR Incentive Programs’ growing emphasis on healthcare analytics and population health management.  With the newly-named “health IT modules” presenting opportunities and challenges for providers seeking to gear up for the optional 2015 Edition Certified EHR Technology (CEHRT) criteria, how will the new provisions for EHR development allow the technology evolve into meaningful tools for big data analytics and effective care coordination?

How does Stage 3 meaningful use affect health data privacy?

As CMS turns its attention to interoperability and increased data exchange, patient privacy and security measures will become ever more important to the industry.  Continued confusion over meaningful use and the HIPAA Security Rule has left many providers asking questions about how they can protect their patients’ electronic personal health information (ePHI) in the face of data breach after data breach.  Learn how Stage 3 hopes to simplify patient data privacy and security measures for providers in this breakdown of the Stage 3 proposal from

What does the Stage 3 meaningful use rule mean for analytics?

How will Stage 3 build on existing infrastructure to encourage healthcare analytics to thrive?  By leveling the playing field and requiring providers to meet all the same measures in 2018.  This controversial proposal may leave some lagging organizations in the lurch, but with the help of the ONC’s Common Clinical Data Set, it would create rich opportunities for informaticist and population health managers.  Will Stage 3 be the push the industry needs to expand its budding analytics capabilities?

ONC proposes 2015 health IT certification criteria rules

The 2015 CEHRT criteria, released in conjunction with the Stage 3 rule, have significant implications for healthcare privacy and security.  By opening up the certification program to include new types of health IT, and therefore new types of patient data, the ONC plans to achieve widespread interoperability.  How will federal rule makers ensure that personal health information is sufficiently protected without overburdening providers and EHR developers?

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IOM Panel Recommends Addition to Stage 3 Meaningful Use

IOM Panel Recommends Addition to Stage 3 Meaningful Use | EHR and Health IT Consulting |

A committee from the Institute of Medicine (IOM) has released recommended guidelines urging the federal government to include patient socioeconomic status and behavioral health data in Stage 3 Meaningful Use regulations. The IOM report was published in the New England Journal of Medicine last month.

The committee suggests incorporating a number of social determinants into EHRs and asking patients 12 questions about their socioeconomic status and behavioral health. Out of these 12 measures, four are currently being evaluated within the healthcare industry while eight are original questions. This process may cut costs in the healthcare industry as well as provide patient-centered accountable care.

Using such data could lead to improved diagnoses and treatments as well as strengthened decision making among providers. Clinicians would be able to identify risk factors more quickly by learning about a patient’s social background.

In addition to basic healthcare services, physicians would be able to refer patients to community organizations or public health departments when different issues arise such as domestic abuse. Along with these benefits, this kind of questionnaire would broaden the amount of patient data available and aid population health management strategies.

The recommendations stem from an IOM report released in November that attempted to uncover social and behavioral domains that are directly related to health outcomes, Politico reports. The panel in charge of the paper analyzed the ways to capture this data in EHR systems.

Some criticism from the American Medical Informatics Association claims that adopting this questionnaire will cause physician workflow issues as well as patient privacy complications. Additionally, some experts wondered if patients would provide honest answers to the questions.

The authors of the IOM report, however, hold a different opinion. The authors stated that by having data on socioeconomic status, employment status, and personal relationships, doctors would be able to “better partner with the patient to make informed and realistic medication choices.”

“Any new diagnostic technology or mode of therapy creates added demands and necessitates changes in practice,” William Stead of Vanderbilt University and Nancy Adler of the University of California, San Francisco, wrote in the report. “We believe that the benefits of adopting and using the measurement panel will outweigh these costs.”

Nonetheless, providers would need to take patient privacy and security into account when implementing a socioeconomic and behavioral health questionnaire in their practice. The change in workflow, however, will be minor, as much of the data can be self-reported or recorded during initial medical visits.

The most recent report hopes to expand the number of organizations involved in considering the implementation of this socioeconomic and behavioral health questionnaire. In particular, it asks the U.S. Department of Health & Human Services (HHS) to take part in including the survey within Stage 3 Meaningful Use requirements.

To qualify for the EHR incentive program under Stage 3 Meaningful Use regulations, the panel calls for behavioral health and socioeconomic data to be stored in EHR systems. Time will tell whether the federal government decides to include a behavioral health and socioeconomic survey as part of Stage 3 Meaningful Use.

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