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Are We Chasing the Carrot or Afraid of the Stick?

Posted on May 29, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The other day SGC asked in my hospital EHR adoption chart post: “If there were no penalties for non-EHR adoption, what would that chart look like?”

For those that are too lazy to click over to that post to see the chart, it basically shows hospital EHR adoption being massively accelerated thanks to the government EHR incentive program. In fact, we’re approaching full adoption of EHR in the hospital space (worth noting is that the ambulatory provider space is lagging far behind that adoption). SGC asks the question about whether that adoption would have occurred without the penalties.

My personal experience is that most organizations appreciate the EHR incentive money and plan that in as part of their budgeting for an EHR, but that they were really much more motivated by the EHR penalties that would accrue if they didn’t adopt an EHR. So, I’d say that people are more afraid of the stick than they are motivated by the carrot.

This is probably more so the case because the penalties are going to exist in perpetuity. I think most hospital organizations believe (and I think rightly so) that the EHR penalties for not using an EHR are not going to stop. In fact, they could get much worse. Not to mention, other payers might start implementing similar penalties for non-EHR use as well.

What’s been your experience? Are the carrot or the stick more motivating to healthcare organizations?

Another related question would be, “If there had been no EHR incentive or penalties, what would the EHR adoption chart look like today?” That’s a topic for another blog post.

Great Meaningful Use and Eligible Providers Chat

Posted on April 29, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I recently received an email from a regular reader, Dr. Mike, who owns a single specialty ortho group. In the email Dr. Mike talks about the challenges that Eligible Providers (EPs) are facing with meaningful use stage 2. He describes the story as falling on “deaf ears” at CMS and ONC. He also offered these stats on meaningful use to illustrate his case that meaningful use is a failure:

Only 38,472 have attested to Stage 2, My guess is that only about half actually did Stage 2 as there was the Stage 1 reprieve. Even so, that is only 18% of EPs have successfully attested which is an complete failure of MU.

Then, he asked me an important question:

Someone ask CMS and ONC the tough questions please…Now what are they going to do?

In response to him, I told him that I’d been talking about the challenge that meaningful use is for doctors for quite a while. However, I also told him that most hospitals are participating in meaningful use, so “we’ll see how that plays out.” What I meant is that in the meaningful use program we now have one group (EPs) that are not doing so well with meaningful use and their hospital counterparts that are relying on the millions in EHR incentive money (not to mention avoiding the penalties).

Then I answered his important question, “I can tell you what ONC and CMS are going to do. Spin It!”

Of course, Dr. Mike is great at engaging in conversation so he offered this reply:

1. Elizabeth Myers and the rest of CMS and ONC really did try to spin every bad number and “we cannot assess the numbers yet” was a constant theme.
2. I totally agree they will continue to try to spin the numbers or ignore them as long as possible. I’m not sure why they cannot face the truth about MU.
3. The 36K that did MU 2 are the cream of the crop. I would even argue that the other 82% are the cream also as they were the early adopters and gung ho about MU. The fact that 82% of the over achieving EPs have skipped out on MU 2 is a travesty. There is NO chance ONC and CMS is going to pull in the lagging EPs.
4. If you don’t know already, I own a single specialty Ortho group and we skipped MU completely after we saw the MU 2 rules. Proposed MU 3 just help us box it up and bury it.

I have no idea why ONC and CMS cannot let go of the program, let EHR vendors actually work with EPs for all the thing we are missing from our IT (usability, safety, security, efficiency). Right now we cannot do anything to customize our workflow or improve our experience as it will potentially decertify the EHR for MU. MU sucks all the air out of the room. EHRs right now are a billing and click box for MU system with a marginal clinical system slapped on…

Its about time ONC lets the market do its thing, instead of this constant objective, measures, menu, core, numerators, denominators, attesting, auditing disaster they created.

Once EPs leave the program, they are not coming back. So this should be a big deal for ONC and CMS.

I haven’t gone in and fact checked his numbers (I’d love to hear if you have different numbers), but the emotion in his comments is something I’ve heard from many providers. In fact, I’ve heard it from many EHR vendors. They’re tired of coding their EHR software to the test and the government regulations as well. They want to do more innovative things, but the government regulations are stifling their ability to do it. Resources only go so far.

I think we’re in the early days of provider discontent with meaningful use. However, it’s starting to boil. I’ll be interested to see what happens when it boils over. I’m predicting that will happen once many of these doctors start seeing the penalties hit their pocketbooks.

The Healthcare Penalties Are Coming!!

Posted on April 3, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

We all know about the Meaningful Use penalties. The PQRS penalties. The Value Based Modifier penalties. Individually, they’d all be annoying, but I don’t think most healthcare organizations have understood what these penalties will be in aggregate.

This hit home to me when I was reading a smartly titled post by Jim Tate called “What you don’t do in 2015 will cause 9% CMS penalties in 2017” Here’s how he describes the penalties that are in store for healthcare:

MU: Failing to achieve MU in 2014 will bring a 2% penalty beginning in 2016 with a 1% annual increase up to 5%.

Physician Quality Reporting System (PQRS): Non-participation brings a Medicare reimbursement reduction of 2.0% in 2016 based on 2014 data.

Value-Based Modifier(VBM): The VBM, which many providers are not aware of, is linked to PQRS. Beginning in 2016, eligible providers (EPs) in groups with 10 or more EPs will be subject to a penalty based on performance. In 2017, this will include all EPs, not just those in larger groups.

Taken together, this adds up to a 9% penalty in 2017 based on 2015 participation.
To avoid these penalties, immediately assess your current participation in the MU, PQRS, and VBM programs. If you are not on track you must take steps to mitigate your risk as soon as possible.

Risk mitigation is the right way to describe it. As I mentioned in the beginning, I don’t think that many providers are planning ahead to avoid these penalties. I also don’t think they realize the long term consequences of the choices they make today.

Thanks Jim for waking us up to the reality.

Meaningful Use Audit Advice

Posted on January 30, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In response to my post on Meaningful Use Audits and the Inconsistent Appeals Process, Todd Searls. Executive Director at Wide River LLC, offered this interesting meaningful use audit advice on LinkedIn:

We’ve assisted numerous clinics and hospitals through their audits, and you’re absolutely correct John. Those clinics that have the people and processes already in place, this ends up (most of the time), being a non -issue, just time consuming. However, we have clients that have undergone significant changes since 2011 and now that they are being audited, the changes are coming back to haunt them since tracking MU documentation through the changes may not have been the highest priority.

Even those clinics that have the right documentation are now finding that they shouldn’t just mail the documents in bulk to the auditors unless they’ve spent time creating a good summary document which clearly defines each and every appendix document being sent. Case in point, we had one clinic call us to help them with their appeal for a failed audit. When we engaged we spent a few hours trying to determine why they failed the audit since the documents they had on file to support their attestation were excellent. Then we reviewed how they sent them in (in just one mass mailing with no cover letter or explanation beyond a title for each document (ie, In Reference to Measure 2)).

Once we created a clear cover letter and resubmitted, they were notified very quickly that their appeal was successful. The clinic had mixed feelings – great that they passed, but unhappy about having to ‘mind-read’ the preferred format that the auditor was looking for. Right or wrong, many clinics are in the same place – frustrated with the process.

I don’t know anyone who enjoys an audit. However, an audit can at least be bearable if it’s clear what’s expected in the audit. I think we’re going to have a lot more stories about meaningful use audits coming down the pipe. Hopefully Todd’s advice helps some who run into a meaningful use audit.

CMS Listens to Those Calling for a 90 Day Meaningful Use Reporting Period

Posted on January 29, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I think that most of us in the industry figured this was just a matter of time, but it’s nice that we were right and CMS is working to modify the requirements and reporting periods for meaningful use. I imagine they heard all the many voices that were calling for a change to meaningful use stage 2 and it’s just taken them this long to work through the government process to make it a reality.

Before I act like this change is already in place, CMS was very specific in the wording of their announcement about their “intent to modify requirements for meaningful use” and their “intent to engage in rulemaking” in order to make these “intended” changes. Basically they’re saying that they can just change the rules. They have to go through the rule making process for these changes to go into effect. That said, I don’t think anyone doubts that this will make it through the rule making process.

Here’s the modifications that they’re proposing:

  1. Shortening the 2015 reporting period to 90 days to address provider concerns about their ability to fully deploy 2014 Edition software
  2. Realigning hospital reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 Edition software into their workflows and to better align with other quality programs
  3. Modifying other aspects of the programs to match long-term goals, reduce complexity, and lessen providers’ reporting burden

They also added this interesting clarification and information about the meaningful use stage 3 proposed rule:

To clarify, we are working on multiple tracks right now to realign the program to reflect the progress toward program goals and be responsive to stakeholder input. Today’s announcement that we intend to pursue the changes to meaningful use beginning in 2015 through rulemaking, is separate from the forthcoming Stage 3 proposed rule that is expected to be released by early March. CMS intends to limit the scope of the Stage 3 proposed rule to the requirements and criteria for meaningful use in 2017 and subsequent years.

I think everyone will welcome a dramatic simplification of the meaningful use program. The above 3 changes will be welcome by everyone I know.

In the email announcement for this, they provided an explanation for why they’re doing these changes:

These proposed changes reflect the Department of Health and Human Services’ commitment to creating a health information technology infrastructure that:

  • Elevates patient-centered care
  • Improves health outcomes
  • Supports the providers who care for patients

Personally, I think they saw the writing on the wall and it wasn’t pretty. Many organizations were going to opt out of meaningful use stage 2. These changes were needed and necessary for many organizations to continue participating in meaningful use. They believe meaningful use will elevate patient-centered care, improve health outcomes, and support the providers who care for patients. I’m glad they finally chose to start the rulemaking process to make the changes. I think many that started meaningful use can still benefit from the rest of the incentive money and will be even happier to avoid the penalties.

Meaningful Use Created A Big Need for Certified MAs

Posted on December 26, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

One of the changes that as best I can tell has come from meaningful use (if there are other forces at play, I’d love to hear them) is the push to use certified MAs. A whole cottage industry has sprung up around certifying MAs. In fact, I even know some EHR vendors who are certifying MAs because it’s such an important need.

Now when I say need, I use that word lightly. It’s a need because meaningful use requires that many of the MAs be certified in order for that MA to participate in many aspects of the meaningful use program. The EHR vendors that are doing it likely don’t want to be in this business at all. However, for their customers to be successful with meaningful use, they need their MAs to be certified.

Certainly there are ways for a doctor to attest to meaningful use without using certified MAs. For example, if you use RNs, then their RN certification is sufficient to meet the needs of meaningful use. Plus, you can have MAs do some tasks in the office that aren’t impacted by meaningful use. However, if you’re using an MA in your office and want to attest to meaningful use, you probably need to have that MA certified.

I’ll admit that I’m not an expert on the MA certification, but I can’t imagine that this new MA certification improves the quality of care that a patient receives in the office. I’d love to be proven wrong on this. Does your office provide better patient care because you know have a group of certified MAs as opposed to non-certified MAs? I just don’t see a short certification like the one that’s required making a huge difference.

Chalk this up to one more layer of bureaucracy and hoop jumping that’s required for a clinic. When will we start really focusing on the value of something? Is there a value to these certified MAs that I’m missing? If so, I’d love to hear about it.

Karen DeSalvo and Jacob Reider Leave ONC

Posted on October 24, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

UPDATE: It seems that DeSalvo will still be National Coordinator of Healthcare IT along with her new position.

It’s been a tumultuous few months for ONC and it’s just gotten even more tumultuous. We previously reported about the departures of Doug Fridsma MD, ONC’s Chief Science Officer, Joy Pritts, the first Chief Privacy Officer at ONC, and Lygeia Ricciardi, Director of the Office of Consumer eHealth, and Judy Murphy, Chief Nursing Officer (CNO) from ONC. Yesterday, the news dropped that Karen DeSalvo, ONC’s National Coordinator, and Jacob Reider, ONC’s Deputy National Coordinator, are both leaving ONC as well.

Karen DeSalvo has been tapped by HHS Secretary Sylvia Mathews Burwell to replace Wanda K. Jones as assistant secretary of health which oversees the surgeon general’s office and will be working on Ebola and other pressing health issues. I think DeSalvo’s letter to staff describes it well:

As you know, I have deep roots and a belief in public health and its critical value in assuring the health of everyone, not only in crisis, but every day, and I am honored to be asked to step in to serve.

DeSalvo’s always been a major public health advocate and that’s where her passion lies. Her passion isn’t healthcare technology. So, this change isn’t surprising. Although, it is a little surprising that it comes only 10 months into her time at ONC.

The obvious choice as Acting National Coordinator would have been Jacob Reider who was previously Acting National Coordinator when Farzad Mostashari left. However, Reider also announced his decision to leave ONC:

In light of the events that led to Karen’s announcement today–it’s appropriate now to be clear about my plans, as well. With Jon White and Andy Gettinger on board, and a search for a new Deputy National Coordinator well underway, I am pleased that much of this has now fallen into place–with only a few loose ends yet to be completed. I’ll remain at ONC until late November, working closely with Lisa as she assumes her role as Acting National Coordinator.

As Reider mentions, Lisa Lewis who is currently ONC’s COO will be serving as Acting National Coordinator at ONC.

What’s All This Mean?
There’s a lot of speculation as to why all of these departures are happening at ONC. Many people believe that ONC is a sinking ship and people are doing everything they can to get off the ship before it sinks completely. Others have suggested that these people see an opportunity to make a lot more money working for a company. The government certainly doesn’t pay market wages for the skills these people have. Plus, their connections and experience at ONC give them some unique qualifications that many companies are willing to pay to get. Some have suggested that the meaningful use work is mostly done and so these people want to move on to something new.

My guess is that it’s a mix of all of these things. It’s always hard to make broad generalizations about topics like this. For example, I already alluded to the fact that I think Karen DeSalvo saw an opportunity to move to a position that was more in line with her passions. Hard to fault someone for making that move. We’d all do the same.

What is really unclear is the future of ONC. They still have a few years of meaningful use which they’ll have to administer including the EHR penalties which could carry meaningful use forward for even longer than just a few years. I expect ONC will still have money to work on things like interoperability. We’ll see if ONC can put together the patient safety initiative they started or if that will get shut down because it’s outside their jurisdiction.

Beyond those things, what’s the future of ONC?

Meaningful Use Hardship Exceptions Reopened

Posted on October 8, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

CMS has announced its intent to reopen the Meaningful Use Hardship Exceptions filing period and set the new deadline for MU hardship exceptions to November 30, 2014. With the new hardship exception extension, providers can now choose from a number of reasons why they were unable to attest in time. Here’s the details from the CMS announcement:

This reopened hardship exception application submission period is for eligible professionals and eligible hospitals that:
* Have been unable to fully implement 2014 Edition CEHRT due to delays in 2014 Edition
CEHRT availability; AND
* Eligible professionals who were unable to attest by October 1, 2014 and eligible hospitals that were unable to attest by July 1, 2014 using the flexibility options provided in the CMS 2014 CEHRT Flexibility Rule.

These are the only circumstances that will be considered for this reopened hardship exception
application submission period.

This is a big move since the meaningful use hardship exceptions deadline for hospitals was April 1, 2014 and July 1, 2014 for eligible professionals. I imagine there are many organizations that will benefit from this extension. Although, there are probably quite a few organizations that wish they’d known about this exception before now or that think the exceptions are too narrow (ie. they can’t benefit from them).

What are your thoughts on this extension?

What If Meaningful Use Were Created by Doctors?

Posted on September 17, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

It’s safe to say that meaningful use is growing through its challenges right now. My post yesterday about killing meaningful use and the new Flex-IT Act should be illustration enough. While it’s easy to play Monday Morning Quarterback on meaningful use, I think it’s also valuable to consider what meaningful use could have been and then use that to consider how we can still get there from where we are today.

Many of you might have read my post on The Purpose of the EHR Incentive Program Accordign to CMS. CMS clearly stats that the purpose of the EHR incentive money and meaningful use is to move providers towards advanced use of health IT to:

  • Support Reductions in Cost
  • Increase Access
  • Improve Outcomes for Patients

This has very clearly been CMS’ goal and it’s reflected in what we now know today as meaningful use. Let’s think about those from a physician perspective.

Support Reductions in Cost – So, you’re going to pay me less for doing the same work?

Increase Access – So, you’re going to send me patients who can’t pay their bill? Or does this mean I have to do more work making my records accessible?

Improve Outcomes for Patients – Every doctor can support this. However, many are skeptical (with good reason) that the various elements of meaningful use really do improve outcomes for patients.

If I were to step back and think what a doctor might consider meaningful use of an EHR system, this might be what they’d list (in no particular order):

  • More Efficient
  • Improved Care
  • Increased Revenue

More Efficient – Will the technology help me see patients more efficiently? Will it allow me to spend more time with the patient?

Improved Care – Will the technology help me be a better doctor? Will the technology help me make better use of my time with the patient?

Increased Revenue – Will the technology help me get paid more? Will the technology lower the cost of my malpractice insurance and reduce that risk? Will the technology create new revenue streams beyond just churning patient visits?

I’m sure there are other things that could be listed as well, but I think the list is directionally accurate. When you look at these two lists, there’s very clearly a major disconnect between what end users want and what meaningful use requires. With a lot of the EHR incentive money already paid out, this divide has become a major issue.

Killing Meaningful Use and Proposals to Change It

Posted on September 16, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Isn’t it nice that National Health IT Week brings people together to complain about meaningful use? Ok, that’s only partially in jest. Marc Probst, CIO of Intermountain and a member of the original meaningful use/EHR Certification committee (I lost track of the formal name), is making a strong statement as quoted by Don Fluckinger above.

Marc Probst is right that the majority of healthcare would be really happy to put a knife in meaningful use and move on from it. That’s kind of what I proposed when I suggested blowing up meaningful use. Not to mention my comments that meaningful use is on shaky ground. Comments from people like Marc Probst are proof of this fact.

In a related move, CHIME, AMDIS and 15 other healthcare organizations sent a letter to the HHS Secretary calling for immediate action to amend the 2015 meaningful use reporting period. These organizations believed that the final rule on meaningful use flexibility would change the reporting period, but it did not. It seems like they’re coming out guns blazing.

In even bigger news (albeit probably related), Congresswoman Renee Ellmers (R-NC) and Congressman Jim Matheson (D-UT) just introduced the Flexibility in Health IT Reporting (Flex-IT) act. This act would “allow providers to report their Health IT upgrades in 2015 through a 90-day reporting period as opposed to a full year.” I have yet to see any prediction on whether this act has enough support in Congress to get passed, but we could once again see congress act when CMS chose a different course of action like they did with ICD-10.

This story is definitely evolving and the pressure to change the reporting period to 90 days is on. My own personal prediction is that CMS will have to make the change. I’d love to hear your thoughts.

Happy National Health IT Week!