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Lack of 2014 Certified EHRs

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I was asked recently by an EHR vendor about the disconnect between the number of 2011 Certified EHR and the number of 2014 Certified EHR. I haven’t looked through the ONC-CHPL site recently, but you can easily run the number of certified EHR vendors there. Of course, there’s a major difference in the number of 2011 certified EHR versus 2014 certified EHR. However, I don’t think it’s for the reason most people give.

Every EHR vendor that gets 2014 Certified likes to proclaim that they’re one of the few EHR vendors that was “able” to get 2014 Certified. They like to point to the vast number of EHR that haven’t bridged from being 2011 Certified to being 2014 Certified as a sign that their company is special because they were able to complete the “more advanced” certification. While no one would argue that the 2014 Certification takes a lot more work, I think it’s misleading for EHR companies to proclaim themselves victor because they’re “one of the few” EHR vendors to be 2014 Certified.

First of all, there are over 1000 2014 Certified EHR products on ONC-CPHL as of today and hundreds of them (223 to be exact – 29 inpatient and 194 ambulatory) are even certified as complete EHR. Plus, I’ve heard from EHR vendors and certifying bodies that there’s often a delay in ONC putting the certified EHR up on ONC-CPHL. So, how many more are 2014 Certified that aren’t on the list…yet.

Another issue with this number is that there is still time for EHR vendors to finish their 2014 EHR certification. Yes, we’re getting close, but no doubt we’ll see a wave of last minute EHR certifications from EHR vendors. It’s kind of like many of you reading this that are sitting on your taxes and we’ll have a rush of tax filings in the next few days. It’s not a perfect comparison since EHR certification is more complex and there are a limited number of EHR Certification slots from the ONC-ATCB’s, but be sure there are some waiting until the last minute.

It’s also worth considering that I saw one report that talked about the hundreds (or it might have been thousands) of 2011 Certified EHR that never actually had any doctors attest using their software. If none of your users actually attested using your EHR software, then would it make any business sense to go after the 2014 EHR certification? We can be sure those will drop out, but I expect that a large majority of these aren’t really “EHR” software in the true sense. They’re likely modularly certified and add-ons to EHR software.

To date, I only know of one EHR software that’s comes out and shunned 2014 Certified EHR status. I’m sure we’ll see more than just this one before the deadline, but my guess is that 90% of the market (ie. actual EHR users) already have 2014 Certified EHR software available to them and 99% of the market will have 2014 certified EHR available if they want by the deadline.

I don’t think 2014 EHR certification is going to be a differentiating factor for any of the major EHR players. All the major players realize that being 2014 Certified is essential to their livelihood and a cost of doing business.

Of course, the same can’t be said for doctors. There are plenty of ways for doctors to stay in business while shunning 2014 Certified EHR software and meaningful use stage 2. I’m still really interested to see how that plays out.

April 11, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

The EHR Market Isn’t Like Other Markets

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Today at a healthcare IT meetup I attended in Dallas I ran into a former contact at an EHR vendor. He no longer works at that EHR company and has moved on to two other companies. In our discussion we had an interesting discussion about the market. Having moved on, he’d lost touch with the EHR market. He asked me, “Are there still 700 EHR vendors?” I told him there were probably 300, but I’ve contended that their have been 300 EHR vendors for a while. I’m not counting the hundreds of ancillary companies that are “certified EHR” but only perform 1-2 EHR related functions.

Over and over again I hear people talking about consolidation of EHR vendors. They say it’s going to happen and we’re going to get down to a really small number of EHR vendors. Some go as far as saying that there will be 2-3 EHR vendors after EHR consolidation happens.

I think this idea is ridiculous. At HIMSS, I figured out why I don’t think it’s going to happen. Someone told me, “Ambulatory healthcare is fragmented. It’s second only to florists when it comes to market fragmentation.”

This to me illustrates exactly why there can and will be so many EHR vendors. The ambulatory market is completely fragmented with thousands of really small businesses (ie. solo doc) doing just fine. Think about it. There are very few businesses that could survive at the size of a solo doctor practice. In every other industry, the businesses the size of a solo doc practice get eating up as the big boy competitors kill them with their buying power. The same can’t be said in healthcare. A solo doctor practice is a very viable business. Thus we see the market fragmentation and the plethora of EHR companies.

The above analysis does make you wonder why the solo doctor practice is still a viable business and if something in the future will make that option unreasonable from a business perspective. Although, that’s a subject for a future blog post.

Of course, when you think about the hospital EMR market there’s a much different story. We’ve seen EHR consolidation. The hospital market is much less fragmented and becoming less so every day. However, I’ll still be surprised if we go below 100 ambulatory EHR vendors.

March 18, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Eyes Wide Shut: Meaningful Use Stage 2 Incentive Program Hardships

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In my January update on Meaningful Use Stage 2 readiness, I painted a dismal picture of a large IDN’s journey towards attestation, and expressed concern for patient safety resulting from the rush to implement and adopt what equates to, at best, beta-release health IT. Given the resounding cries for help from the healthcare provider community, including this February 2014 letter to HHS Secretary Kathleen Sebelius, I know my experience isn’t unique. So, when rumors ran rampant at HIMSS 2014 that CMS and the ONC would make a Meaningful Use announcement, I was hopeful that relief may be in sight.

Like AHA , I was disappointed in CMS Administrator Marilyn Tavenner’s announcement. The new Stage 2 hardship exemptions will now include an explicit criteria for “difficulty implementing 2014-certified EHR technology” – a claim which will be evaluated on a case-by-case basis, and may result in a delay of the penalty phase of the Stage 2 mandate. But it does nothing to extend the incentive phase of Stage 2 – without which, many healthcare providers would not have budgeted for participation in the program, at all, including the IDN profiled in this series. So how does this help providers like mine?

Quick update on my IDN’s progress towards Stage 2 attestation, with $MM in target incentive dollars at stake. We must meet ALL measures; there is no opportunity to defer one. The Transition of Care (both populating it appropriately, and transmitting it via Direct) is the primary point of concern.

The hospital EHR is ready to generate and transmit both Inpatient Summary and Transition of Care C-CDAs. The workflow to populate the ToC required data elements adds more than 4 minutes to the depart process, which will cause operational impacts. None of the ambulatory providers in the IDN have Direct, yet; there is no one available to receive an electronic ToC. Skilled resources to implement Direct with the EHR upgrades are not available until 6-12 weeks after each upgrade is complete.

None of the 3 remaining in-scope ambulatory EHRs have successfully completed their 2014 software upgrades. 2 of the 3 haven’t started their upgrades. 1 has not provided a DATE for the upgrade.

None of the ambulatory EHRs comes with a Clinical Summary C-CDA configured out-of-the-box. 1 creates a provider-facing Transition of Care C-CDA, but does not produce the patient-facing Clinical Summary. (How did this product become CEHRT for 2014 measures?) Once the C-CDA is configured, each EHR requires its own systems integrator to develop the interface to send the clinical document to an external system.

Consultant costs continue to mount, as each new wrinkle arises. And with each wrinkle, the ability to meet the incentive program deadlines, safely, diminishes.

Playing devil’s advocate, I’d say the IDN should have negotiated its vendor contracts to include penalty clauses sufficient to cover the losses of a missed incentive program deadline – or, worst case scenario, to cover the cost of a rip-and-replace should the EHR vendor not acquire certification, or have certification revoked. The terms and conditions should have covered every nuance of the functionality required for Stage 2 measures.

But wait, CMS is still clarifying its Stage 2 measures via FAQs. Can’t expect a vendor to build software to specifications that weren’t explicitly defined, or to sign a contract that requires adherence to unknown criteria.

So, what COULD CMS and the ONC do about it? How about finalizing your requirements BEFORE issuing measures and certification criteria? Since that ship’s already sailed, change the CEHRT certification process.

1. Require vendors to submit heuristics on both initial implementation and upgrades, indicating the typical timeline from kick-off to go-live, number of internal and external resources (i.e., third-party systems integrators), and cost.
2. Require vendors to submit customer-base profile detailing known customers planning to implement and/or upgrade within calendar year. AND require implementation/upgrade planning to incorporate 3 months of QA time post-implementation/upgrade, prior to go-live with real patients.
3. Require vendors to submit human resource strategy, and hiring and training program explicitly defined to support the customer-base profile submitted, with the typical timeframes and project resource/cost profiles submitted.
4. Require vendor products to be self-contained to achieve certification – meaning, no additional third-party purchase (software or professional services) would be necessary in order to implement and/or upgrade to the certified version and have all CMS-required functionality.
5. Require vendor products to prove the CEHRT-baseline functionality is available as configurable OOTB, not only available via customization. SHOW ME THE C-CDA, with all required data elements populated via workflow in the UI, not via some developer on the back-end in a carefully-orchestrated test patient demo script.
6. Require vendor products adhere to an SLA for max number of clicks required to execute the task. It is not Meaningful Use if it’s prohibitively challenging to access and use in a clinical setting.

Finally, CMS could redefine the incentive program parameters to include scenarios like mine. Despite the heroic efforts being made across the enterprise, this IDN is not likely to make it, with the fault squarely on the CEHRT vendors’ inability to deliver fully-functional products in a timely manner with skilled resources available to support the installation, configuration, and deployment. Morale will significantly decline, next year’s budget will be short the $MM that was slated for further health IT improvements, and the likelihood that it will continue with Stage 3 becomes negligible. Vendor lawsuits may ensue, and the incentive dollar targets may be recouped, but the cost incurred by the organization, its clinicians, and its patients is irrecoverable.

Consider applying the hardship exemption deadline extension to the incentive program participants.

March 5, 2014 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

EHR Vendor Says Good Bye to Meaningful Use

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ComChart Medical Software, LLC president, Hayward K. Zwerling, MD, earlier this month posted a letter on The Health Care Blog saying that the ComChart EMR would no longer be meaningful use certified. Here’s a portion of the letter that describes the reasoning:

ComChart EMR will continued to be certified as a Complete EMR for Stage I Meaningful Use. Unfortunately, we will not be able to meet the Stage 2 (or greater) Meaningful Use certification requirements as these requirements are technically extremely difficult to implement.

In addition to the Meaningful Use mandates, there continues to be a never ending stream of new mandates such as ICD-10, PQRI, Meaningful Use 2, Meaningful Use 3, SNOMED, ePrescribing, LOINC, Direct Project, health information exchanges etc. As a result of the mountain of mandates, ComChart EMR and the other small EMR companies will have to choose to implement the mandates or use their resources to add “innovative” features to their EMR. Unfortunately, the small EMR companies do not have the resources to do both.

(I suspect this is also true, to some extent, for all EMR companies.)

While the individual people involved in promulgating these EMR mandates (mostly) have the best of intentions, they clearly do not understand what transpires in the exam room, as many of the mandated features confer little or no benefit to either the patient or the healthcare provider.

In addition to a lack of understanding of what is important during the process of providing healthcare, it has also become apparent to me that the Federal and State health information technology agenda is now largely driven by the strongest HIT companies and health institutions; the individual physician is only an afterthought in the entire process.

This choice basically means that anyone interested in meaningful use and EHR incentive money won’t be doing so with ComChart EMR. The regulations say that even someone attesting to meaningful use stage 1 in 2014 has to use a 2014 certified EHR. ComChart won’t be able to meet that requirement.

I knew that this was going to happen with a number of EMR vendors, but ComChart really missed a huge opportunity with this announcement. The most damning part of the letter is when Dr. Zwerling says “we will not be able to meet the Stage 2 (or greater) Meaningful Use certification requirements as these requirements are technically extremely difficult to implement.” I was aghast by this statement. So much so that I had a brief email exchange with Dr. Zwerling to see if he really meant what he said. Was it that they weren’t able to meet the requirements or that they chose not to meet them?

He responded, “Anything can be done, it is just a question of how much resources are going to be thrown at the problem and what is not going to get done return.”

It seems that Dr. Zwerling didn’t consult a PR or marketing person on how to make the most of this decision. Any of them would have told him that this decision could be a huge opportunity to differentiate the ComChart EHR from all the hundreds of certified carrot chasing EHR companies out there.

If Dr. Zwerling had asked me, I’d have told him that he should have said, “ComChart EHR has talked with our hundreds of physician end users about meaningful use and EHR certification and we’ve found that they don’t value any of the meaningful use criteria. Because of doctors desire to not be bogged down by meaningful use requirements, we’ve chosen to listen to our doctors and focus on what makes doctors lives easier. We’ll continue innovating our product to the needs of doctors, but we’ll be letting doctors drive that innovation versus some committee in Washington.”

I could keep going, but you get the idea. ComChart could have told every doctor out there that they were the ULTIMATE PHYSICIAN EHR that cares so much about the physicians who use their EHR that they’re shunning meaningful use because it’s detrimental to the way physicians should be practicing medicine. Making this case would not be hard and the message would resonate with the majority of physicians.

I’m not sure if this strategy would work or not. Government money that’s perceived as “free” is a hard opponent. However, government bureaucracy and headaches are an easy target that everyone understands and hates. In ComChart’s case, saying that they essentially aren’t capable of the complex meaningful use requirements is sending the wrong message. All doctors hear when they read this is that your EMR development team isn’t sophisticated or strong enough to keep up. What a missed opportunity and likely the nail in ComChart’s coffin!

Hopefully this is a warning message to any other EHR vendors who choose to go the route of shunning meaningful use and EHR certification. I’m not sure that shunning MU is a winning strategy for an EHR vendor, but being the physician advocate at least gives them a fighting chance.

December 30, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

EMR Vendors Struggle With Meaningful Use Stage 2

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CCHIT head Alisa Ray, clearly, is trying to put it delicately. EMR vendors are “struggling a little bit” when it comes to meeting 2014 criteria. “It  has been a slow start,” Ray told Healthcare IT News.

Usually, hearing this would lead to an inside baseball discussion of vendor operations, which wouldn’t be very exciting. But the thing is, meeting 2014 certification criteria is necessary to allow providers to meet Meaningful Use Stage 2. So vendor struggles in complying with CCHIT’s criteria should concern providers a great deal.

There are three areas of Stage 2 that are proving to be an issue for vendors: clinical quality measures, interoperability and automated measure calculation for reporting metrics, Ray said.

This has led to a real lag in certifications. About 40 companies had listed products with the CCHIT in 2011, but a scant 21 percent of those have stepped up and gotten certified in the 2014 criteria.

According to Ray’s chat with Healthcare IT News, “almost everyone has struggled and been surprised by the complexities” of meeting 2014 standards.  Despite having gone through the process yearly since 2006 with CCHIT, several have had to go through repeated certification trials to meet criteria.

ICSA Labs’ Amit Trivedi, meanwhile, noted that while there were close to 3,000 listings, with many having multiple listings — Cerner alone had 800 — so far there less than 300 on ONC’s Certified Health IT Products list.

There are signs that EMR vendors will catch up, the HIT story suggests. For example, vendors have been working particularly hard to offer Continuity of Care Documents or Direct messaging, a capability providers must demonstrate for Meaningful  Use Stage 2, said Matt Kohler, vice president of Network Infrastructure Services at Surescripts.

But vendors clearly have some serious development challenges ahead if they want to keep up with the pace set by Meaningful Use Stage 2.  If I were a provider reading this, I’d call my vendor right away and see where they were at in the certification process.

October 29, 2013 I Written By

Katherine Rourke is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Eyes Wide Shut – Managing Multi-EMR Meaningful Use Stage 2 Is Hard

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Most discussions on Meaningful Use (MU) seem to focus on a single healthcare provider organization (acute or ambulatory), with a single EMR, and a single Medical Record Number (MRN) pool generating unique patient identifiers. Even in that context, the complaints of the difficulties of successfully implementing the technology and obtaining the objectives are deafening. How daunting might those challenges seem, multiplied across a large integrated delivery network (IDN), attempting to make enterprise-wide technology and operational process decisions, in alignment with MU incentive objectives?

Imagine you are an IDN with 9 hospital facilities, sharing a single EMR. You also have 67 ambulatory practices, with 7 additional EMRs. You’ve made the progressive choice to implement a private health information exchange (HIE) to make clinical summary data available throughout the IDN, creating a patient-centric environment conducive to improved care coordination. To properly engage patients across the IDN and give them the best user experience possible, you’ve purchased an enterprise portal product that is not tethered to an EMR, and instead sources from the HIE. And because you’ve factored the MU incentive dollars into the budget which enabled these purchasing decisions, there is no choice but to achieve the core and select menu measures for 2014.

It is now October 2013. The first quarter you’ve chosen to gather Stage 2 attestation data starts on April 1, 2014. All your technology and process changes must be ready by the data capture start date, in order to have the best opportunity to achieve the objectives. Once data capture begins, you have 90 days to “check the box” for each MU measure.

Tech check: are all the EMRs in your IDN considered Certified Electronic Health Records Technology (CEHRT) for the 2014 measures?

Your acute EMR is currently 2 versions behind the newly-released MU 2014-certified version; it is scheduled to complete the upgrade in November 2013. Your highest-volume ambulatory EMR is also 2 versions behind the 2014-certified version, and it cannot be upgraded until March 2014 due to vendor resource constraints. Your cardiology EMR cannot be upgraded until June due to significant workflow differences between versions, impacting those providers still completing Stage 1 attestation. One of your EMRs cannot give you a certification date for its 2014 edition, and cannot provide an implementation date for the certified version. The enterprise portal product has been 2014-certified as a modular EMR, but the upgrade to the certified version is not available until February 2014.

Clearly, your timeline to successfully test and implement the multitude of EMR upgrades required prior to your attestation date is at risk.

Each EMR might be certified, but will it be able to meet the measures out of the box?

Once upgraded to the 2014 version, your acute EMR must generate Summary of Care C-CDA documents and transmit them to an external provider, via the Direct transfer protocol. Your ambulatory EMRs must generate Transition of Care C-CDA documents and use the same Direct protocol to transmit. But did you purchase the Direct module when you signed your EMR contract, or maintenance agreement?

Did you check to see whether the Direct module that has been certified with the EMR is also an accredited member of DirectTrust?

Did you know that some EMRs have Direct modules that can ONLY transmit data to DirectTrust-accredited modules?

You determine your acute EMR will only send to EMRs with DirectTrust-accredited modules, and that you only have a single ambulatory EMR meeting this criteria. That ambulatory EMR is not the primary target for post-acute care referral.

You have no control over the EMRs of providers outside the IDN, who represent more than 20% of your specialist referrals.

Your 10% electronic submission of Summary of Care C-CDA documents via Direct protocol measure is at risk.

Is your organization prepared to manage the changes required to support the 2014 measures?

This is a triple-legged stool consideration: people, process, and technology must all align for change to be effective. To identify the process changes required, and the people needed to support those processes, you must understand the technology that will be driving this change. Of all the EMRs in your organization, only 2 have provided product specifications, release notes, and user guides for their 2014-certified editions.

Requests for documentation about UI, data, or workflow changes in the 2014 versions are met with vague responses, “We will ask product management and get back to you on that.” Without information on the workflow changes, you cannot identify process changes. Without process change recognition, you cannot properly identify people required to execute the processes. You are left completely in the dark until such time as the vendors see fit to release not only the product, but the documentation supporting the product.

Clearly, your enterprise program for Meaningful Use Stage 2 health IT implementation and adoption is at risk.

What is the likelihood that your Meaningful Use Stage 2 attestation will be a successful endeavor for the enterprise?

As a program manager, I would put this effort in flaming red status, due to the multitude of risks and external dependencies over which the IDN organization has zero control. I’d apply that same stoplight scorecard rating to the MU Stage 2 initiative. There is simply too much risk and too many variables outside the provider’s control to execute this plan effectively, without incurring negative impacts to patient care.

The ONC never said Meaningful Use would be easy, but does it have to be this hard?

October 2, 2013 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

Eyes Wide Shut – Teaching to the Meaningful Use Stage 2 Test

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According to Twitter analytics, one of my more engaging tweets recently stated that Meaningful Use is stifling innovation by requiring that health IT vendors and healthcare providers employ very specific tactics to capture and report on clinical data capture and interoperability standards compliance – ostensibly to engage and empower the patient, and improve coordination of care between providers. Of course, I said it much more succinctly than that. In effect, conforming to the Meaningful Use Stage 2 attestation measures is akin to “teaching to the test”:

Here’s a real-world example of what it means to “teach to the test” of Meaningful Use. In order to qualify for CMS incentive dollars, Meaningful Use Stage 2 Year 1 patient engagement measures must be met, with auditable data captured, in a 90-day contiguous period in 2014. An eligible provider (EP) must demonstrate that 50% of all patients with encounters during that time period have online access to their clinical summary within 4 days of the data becoming available to the provider. 5% of those patients must access the clinical information within the 90 days, and 5% of those patients must leverage secure messaging to communicate relevant health information with the provider. Finally, the MU-certified EMR must proffer patient-specific education materials for 10% of the patients seen during that time.

What I believe the ONC had in mind when they crafted these measures: engaged patients who will log in to their portal after each encounter, review the findings and lab results to assess their own progress and outcomes, read or listen to the condition-specific educational materials provided that resonate with them, and ask more meaningful questions of their providers as a result of this new-found, data-enabled empowerment. That is why they categorize these measures as “patient engagement”, right?

Wrong. This is what “patient engagement” looks like, from the EMR implementation, Meaningful Use-consultant, EP business process standpoint.

First, establish the bare minimum thresholds for meeting the measures. If the EP saw 1000 patients during the same 3-month period the previous year, your denominator is 1000; calculate the numerator for each measure based on that. So, we need 500 patients to have access to their clinical data online; 50 patients must access their information; 50 patients must communicate with their provider via secure messaging; 100 patient encounters must prompt specific educational opportunities.

To meet the 500 patients with online access to their clinical data, patient portal software is preloaded with patient demographic accounts, based on the registration data already available in the EMR. An enrollment request is emailed to the patient or authorized representative (assuming an email address is available in their demographic information). The EMR captures the event of sending this email, which contains the information about how to enroll and access the patient’s medical records via the portal. This measure is met, without the patient acknowledging the portal’s existing, and without any direct communication between provider and patient.

The medical records view and secure messaging measures can be met simultaneously, in a matter of days, by planning to add a few extra minutes to each encounter for 50 patients’ worth of appointments. The EMR has already triggered an email with portal enrollment information to each of the patients in the waiting room on a given day. As the medical assistant (MA) is taking vital stats, she asks whether the patient has enrolled in the portal. It’s likely the patient has not; the MA hands the patient a tablet and has him log in to his email, and walks him through the portal enrollment and initial login process. Once logged in, the MA directs the patient to click the link to view his medical record. That click is recorded, and the “view” measure is met; whether a CCD or C-CCD is actually displayed is irrelevant to the attestation data capture.

Having demonstrated how a patient can view his record, the MA then asks the patient to go into the portal’s message center, to send a test communication to the provider. The patient completes the required fields, and the MA prompts him with a generic health-related question to type into the body of the message. Once the patient hits “Send”, the event is recorded, and the “secure messaging” measure is met.

For all patients, whether portal-users or not, a new process begins when the MA finishes, the provider enters the room and begins her evaluation of each of the 100 patients required to meet the education measure. As the patient talks, the provider is clicking through EMR workflow screens, recording the encounter data. The EMR occasionally prompts with a dialogue box indicating educational materials are available for patients with this diagnosis code, or this lab result. Each dialogue box prompt is recorded by the EMR; the “patient-specific education” measure is met, whether the provider acts on the prompt and discusses or distributes the educational information or not.

To put it simply: the patient never has to log in to a portal to meet the 50% online availability requirement, they don’t have to actually view their records to meet the 5% view requirement, they don’t have to have an actual message exchange with their provider to meet the 5% communication requirement, and they don’t have to receive any tailored materials to meet the 10% education requirement. Once those clicks have been recorded, the actions never have to be repeated; meaningful and ongoing patient engagement is not needed to meet the attestation requirements and receive the incentive dollars.

In a previous post, I introduced my interpretation of the difference between the spirit and letter of the Meaningful Use “law”. By teaching to the test, we’re addressing the letter of the law, only, in its narrowest interpretation. When will we incent vendors and providers to go above and beyond and find ways to truly engage patients in meaningful ways, empowering them with accurate, timely data access and tools to analyze it?

September 30, 2013 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

Eyes Wide Shut – Is This Meaningful Use?

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Again and again, I find myself expounding upon the need to differentiate between the “letter of the law” and the “spirit of the law” of Meaningful Use Stage 2. I believe whole-heartedly in the transformative power of health IT, and support the future vision of the Meaningful Use objectives of patient empowerment and nationwide standards for records transmission and interoperability. The spirit of the “law” is a revolutionary movement towards a technology-enabled, patient-centric healthcare system, where clinical data can be shared and consumed instantly, whenever patient desires or requires it.

The letter of the “law” is daunting, and its implementation could be seen as not only counter-revolutionary, but detrimental to the very patient population it is designed to engage and empower.

Consider this acute care scenario:

You’re a hospital healthcare provider, discharging a patient, in compliance with the patient-specific education and Summary of Care measures. You log in to your EMR, complete the discharge instructions in the correlated workflow, print the discharge summary and any condition-specific educational information for the patient, revisit their room to insure that they can review the instructions and ask any questions, and you’re on to assessing the condition of the next patient in need of care. Right?

How many times did you have to close the “patient-specific education” suggestion windows that popped up, alerting you to available materials for download, keyed off diagnosis codes or lab results?

How many minutes did you spend looking for the HISP address of the patient’s cardiologist, so you could transmit the Summary of Care document to them via the Direct module of your EMR? How many clicks did you have to use to FIND the Direct module in your EMR? And how many minutes did you spend cursing the ONC for requiring Direct for Summary of Care transmission for 10% of your discharged patient population when the cardiologist’s address was rejected by the Direct module, giving you a message that the receiver is not DirectTrust-accredited?

How much time did the discharge process take you before your facility decided to attest to Meaningful Use Stage 2? How much time does it take you now?
Consider this ambulatory care scenario:

You’re support staff for a general practitioner, who is deploying a patient portal in support of patient engagement measures. At check-in (or check-out), you provide the patients with the URL for enrollment and access, give them information on the benefits of having their medical records available electronically, encourage them to communicate electronically with their provider with questions or concerns, and you send them on their empowered and engaged way.

How many minutes did you spend validating each portal account owner’s identity once their enrollment request came? How many minutes did you spend validating the relationship of the portal account owner to each of the patients he/she requests to associate with the account? How did you document the due diligence done to insure no medical records are improperly released per HIPAA and other federal guidelines, as in the case of custodial disputes, behavioral health patients, or emancipated minors?

How many minutes did you spend walking patients through the enrollment, login, medical records view, and secure message functions? How much time did you spend answering questions from patients about the portal, rather than the health concerns that prompted the visit?

How much time did the check-out process take before your GP decided to attest to Meaningful Use Stage 2? How much time does it take you now?

In both of these scenarios, did you or the patient see any measurable difference in care as a result of the EMR’s new functionality?

Now, consider the aggregate of these scenarios over an entire day – dozens of encounters, dozens of clicks, dozens of minutes spent engaging the EMR to record requisite “clicks” for attestation numerator reporting, rather than engaging the patient.

Is this meaningful use of a healthcare provider’s time and energy? Is this meaningful use of health IT, meeting very specific targets to obtain finite objectives rather than enabling innovation and deriving best practice long-term solutions?

Is this what the ONC intended?

September 25, 2013 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

Analytics-Driven Compassionate Healthcare at El Camino Hospital

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Given its location in the heart of Silicon Valley, it may not be remarkable that El Camino Hospital was the first hospital in the US to implement EMR. What IS remarkable is that El Camino implemented EMR 51 years ago, leveraging an IBM mainframe system that Lockheed Martin refactored for healthcare from its original intended use for the space program.

Take a moment to process that. El Camino didn’t need PPACA, Meaningful Use, HITECH, or HIPAA to tell them health data is critical. El Camino saw the value in investing in healthcare IT for electronic data capture and communication without federal incentive programs or lobbyists. With that kind of track record of visionary leadership, it’s no wonder they became early analytics program adopters, and recently turned to Health Care DataWorks (HCD) as a trusted partner.

When I sat down with executive leadership from El Camino and HCD to discuss the journey up Tom Davenport‘s analytics maturity scale from rudimentary operational reporting to advanced analytics, I expected a familiar story of cost pressure, clinical informatics, quality measure incentives or alternative payment models as the business drivers for new insights development. Instead, I heard the burgeoning plan for a visionary approach to patient engagement and “analytics-driven compassionate care”.

Greg Walton, CIO of El Camino Hospital, admitted that initial efforts to implement an analytics program had resulted in “textbook errors”: “’Competing on Analytics’ was easier to write than execute,” he said. Their early efforts to adopt and conform to a commercially-available data model were hindered by the complexity of the solution and the philosophy of the vendor. “One of the messages I would give to anybody is: do NOT attempt this at home,” Greg laughed, and El Camino decided to change their approach. They sought a “different type of company…a real-life company with applicable lessons learned in this space.”

“The most important thing to remember in this sector: you’re investing in PEOPLE. This is a PEOPLE business,” Greg said. “And that if there’s any aspect of IT that’s the most people-oriented, it’s analytics. You have to triangulate between how much can the organization absorb, and how fast they can absorb it.” In HCD, El Camino found an analytics organization partner whose leadership and resources understand healthcare challenges first, and technology second.

To address El Camino’s need for aggregated data access across multiple operational systems, HCD is implementing their pioneering KnowledgeEdge Enterprise Data Warehouse solution,including its enterprise data model, analytic dashboards, applications and reports. HCD’s technology, implementation process, and culture is rooted in their deep clinical and provider industry expertise.

“The people (at HCD) have all worked in hospitals, and many still work there occasionally. Laypersons do not have the same understanding; HCD’s exposure to the healthcare provider environment and their level of experience provides a differentiator,” Greg explained. HCD impressed with their willingness to roll up their sleeves and work with the hospital stakeholders to address macro and micro program issues, from driving the evaluation and prioritization of analytics projects to identifying the business rules defining discharge destination. And both the programmers and staff are “thrilled,” Greg says: “My programmers are so happy, they think they’ve died and gone to heaven!”

This collaborative approach to adopting analytics as a catalyst for organizational and cultural change has lit a fire to address the plight of the patient using data as a critical tool. Greg expounded upon his vision to achieve what Aggie Haslup, Vice President of Marketing for HCD, termed “analytics-driven compassionate care”:

We need to change the culture about data without losing, and in fact enhancing, our culture around compassion. People get into healthcare because they’re passionate about compassion. Data can help us be more compassionate. US Healthcare Satisfaction scores have been basically flat over the last 10 years. Lots of organizations have tried to adopt other service industry tools: LEAN,6S; none of those address the plight of the patient. We’ve got to learn that we have to go back to our roots of compassion. We need to get back to the patient, which means “one who suffers in pain.” We want (to use data) to help understand more about person who’s suffering. My (recent) revelation: what do you do w/ guests in your house? Clean the house, put away the pets, get food, do everything you can to make guests comfortable. We want to know more about patients’ ethnicity, cultural heritage, the CONTEXT of their lives because when you’re in pain, what do you fall back on? Cultural values. We want a holistic view of the patient, because we can provide better, compassionate care through knowing more about patients. We want to deploy a contextual longitudinal view of the patient…and detect trends in satisfaction with demographics, clinical, medical data.

What a concept. Imagine the possibilities when a progressive healthcare provider teams with an innovative analytics provider to harness the power of data to better serve the patient population. I will definitely keep my eye on this pairing!

March 25, 2013 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

HIMSS Analytics Clinical & BI Maturity Model

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While the theme of HIMSS 2013 may have been, “How Great Is Interoperability,” the effectiveness of the many facets of interoperability are only as good as the actionable value of the shared data. The clinical insights that should be enabled by Meaningful Use Stage 2+ are expected to drive market trends in myriad areas of the healthcare system: chronic disease management, targeted member interventions, quality measures. In order to assess organizational readiness to capitalize on the promise of Meaningful Use, HIMSS Analytics began measuring the implementation and adoption of EMR and clinical documentation using a maturity model called EMRAM.

EMRAM

But, in analytics terms, EMRAM’s results are simply targeted foundational reporting, answering the question, “WHAT happened with Meaningful Use EMR adoption criteria.” So, you’ve got your clinical data in an EMR. Now what are you able to DO with it?

In 2013, HIMSS Analytics is taking a broader approach with the introduction of a new Clinical Business Intelligence maturity model, creating a framework to benchmark participating providers’ analytics maturity level.

I’ve been fortunate to know James Gaston, Senior Director of HIMSS Analytics Clinical & Business Intelligence, for many years, going back to his days with Arkansas Blue Cross. His appreciation for BI initiatives is matched only by his enthusiasm for the first day of turkey hunting season. When I ran into him at TDWI’s BI World summit in Orlando in November, he acted like a kid on Christmas morning, telling me about the brave new world of clinical data management that he was about to tackle. The excitement continued to build in the months leading up to HIMSS. James was practically glowing when we spoke about the upcoming C&BI Maturity Model release.

“Our customers are interested in not just understanding how to deploy IT applications, but how effectively they’re using those applications to support clinical business intelligence, as well as analytical pursuits,” James said. “So, HIMSS Analytics partnered with IIA to create and present a Clinical & BI Maturity Model that helps healthcare organizations measure that level of effectiveness.”

Sarah Gates, the VP of Research for IIA (the International Institute of Analytics), elaborated. “The HIMSS Analytics C&BI Maturity Model leverages the Competing on Analytics DELTA model, developed by Tom Davenport, which measures not only how well you’re using data and technology, but how well you’re building an analytical organization.” There are 5 core competency measurements in the DELTA model that will inform the HIMSS Analytics C&BI analysis: Data, Enterprise, Leadership, Targets, and Analysts. The methodology is holistic, touching on the cultural aspects of the organization as well as the technical, allowing a longitudinal view of the organization’s analytics program. A yardstick value from 1-5 will be assigned to each respondent based on Davenport’s criteria for each core competency.

Although HIMSS Analytics will eventually offer Level 1-5 certification program for those organizations with observed results for analytics, James and Sarah agreed that it is not appropriate for every provider to reach for the Level 5 gold star. Per Sarah, “Healthcare is an industry just starting to discover analytics. We’re expecting to see lots of practitioners that are emerging in use of analytics, so we believe it (survey results) will be heavy on the lower end of the maturity scale. Data warehouse capabilities and staffing career paths for data analysts will be key differentiators for mature programs.” Not all providers have the resources – financial, human, and/or technical – to attain advanced analytics nirvana, and James wants to insure that these providers don’t feel as if they’ve “failed”; the goal is to baseline against the peer group, identify opportunities for improvement, and focus on what is possible for each individual organization, working within their constraints.

What can we expect to see at next year’s C&BI survey results presentation? James said, “We want to be able to talk about benchmarking the industry as a whole, helping healthcare find its way with clinical business intelligence and begin to understand how important it is, and where opportunities lie Everyone’s talking about clinical and BI – it is the opportunity to realize savings in healthcare, to use information to empower people to make better decisions.”

So, it’s up to you, providers and technology partners. You’ve implemented your EMR, achieved a high adoption rate across your organization’s core clinical processes, attested to Meaningful Use Stage 2, achieved Stage 7 on the HIMSS EMRAM scale, perhaps even participated in multi-HIE CCD medical records sharing with other provider networks. You’ve got the data in-house and availabe. It’s time to see how ready you are to rise to the analytics challenge and maximize your return on those EMR and HIE investments.

Attempt to beat your previous Doug Fridsma long jump.

Note: for the complete HIMSS 2013 Leadership Survey Results, please download PDF here.

March 14, 2013 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.