As I look forward to EHR in the year 2012, it was suggested to me at HIMSS that we’re going to see an EHR adoption rush starting in August 2012. If you think about the timeline and all the other EHR happenings, I think this very much will be the case.

I saw a tweet (which I can’t find now) which said something to the effect of meaningful use attestation in January of 2012 was as big as all of 2011. I also have read about the mass of meaningful use attestation that happened at the end of 2011. With only having to attest for 90 days it makes sense why so many people waited until the end of 2011 to attest to meaningful use.

I expect we’re going to see the same rush to meaningful use attesation in 2012 as well. However, you don’t just implement and EHR and then start your meaningful use attestation the week after you implement an EHR. In most cases, you need at least a couple months (more in the hospital case) after implementing an EHR to “get your feet under you” and be ready to concern yourself with the meaningful use requirements.

With this in mind, I expect these next 3 months will be critical for EHR vendors that want to fill their Fall EHR sales pipeline. EHR adoption will slow down a bit during summer when doctors head out on vacations. Then, Fall 2012 will start the rush of EHR adoption in order to meet meaningful use requirements in 2012.

Of course, it’s also likely that many doctors will procrastinate their EHR selection process. They’ll wait until Fall and then rush through EHR selection. I think this would be a real tragedy for EHR since selecting the right EHR is the mot important part of the EHR implementation.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

With all the attention that meaningful use Stage 2 has received in the last 2 weeks, it’s easy to forget that most providers are just ramping up for meaningful use stage 1 and are still trying to understand the requirements they must satisfy for the next 2 years. So I’m going to let the dust settle a bit on the Stage 2 proposal and go back to addressing lingering questions about Stage 1.

Last week’s post talked about the increased frequency with which providers are switching EHRs. Some are replacing legacy EHRs that are not ONC-certified in order to qualify for meaningful use incentives, while others are switching from one certified EHR to another to better meet their practice needs. An EMR and HIPAA reader who is changing EHRs in mid (meaningful use) stream submitted the following question:

Q:  “If we attest for 2011, then 3-4 months into 2012 we change to another software vendor, is there a way to attest using both software vendors since we have to combine or run reports to attest for the whole year of 2012?”

A: Yes, you can attest using both EHRs—in fact, you must report from both EHRs. First, enter both certified complete EHRs into the Certified Health IT Product List (CHPL) website to generate a new EHR Certification ID number to use for 2012 attestation. You will need to combine the results, measure by measure including clinical quality measures, from the two sets of reports that you run. For measures that require a count of actions, this is fairly easy—you simply add the numerators and denominators. Where this becomes somewhat challenging is in reporting measures where the denominator is “unique patients.” According to a CMS FAQ regarding a similar situation, (i.e., providers who see patients in multiple locations with different certified EHRs), “…it is the responsibility of the EP….to reconcile information from multiple certified EHR systems in order to ensure that each unique patient is counted only once for each objective.”  No further guidance is provided on how to accomplish that.

For this week’s Meaningful Use Monday, I decided I’d go through the large list of meaningful use stage 2 commentary that’s been put out over the past week. I’ll do my best to link to some of the most interesting commentary, summaries, etc of meaningful use stage 2 and point out some resources that I’ve found useful.

John Halamka on Meaningful Use Stage 2
First up is the blog post by John Halamka about MU stage 2. I really like his recommendation to read pages 156-163 of the MU rule (PDF here). Sure, the rule is 455 pages, but many of those pages are a recap of things we already know or legalese that is required in a government document. Halamka also created a meaningful use stage 2 powerpoint that people can reuse without attribution. Worth looking at if you’re not familiar with MU stage 2 or if you have to make a presentation on it.

Health Affairs on MU Stage 2
Health Affairs has a nice blog post covering meaningful use stage 2. They offer “3 highlights that seem particularly important:”

1. The bar for meeting use requirements for computerized provider order entry (CPOE), arguably the most difficult but potentially the most important EHR functionality, has been raised: now a majority of the orders that providers write will have to be done electronically.
2. There is a major move to tie quality reporting to Meaningful Use. We knew this was coming, but CMS has laid out a host of quality measures that may become requirements for reporting through the EHR.
3. Health Information Exchange moves from the “can do it” to the “did do it” phase. In Stage 1, providers had to show that they were capable of electronically exchanging clinical data. As expected, in Stage 2, providers have to demonstrate that they have done it.

Health Affairs also talks about the timeline for this rule and the feedback that CMS is likely to get on MU stage 2. I’m sure they’re going to get a lot of feedback and while they suggest that the rule will look quite similar to the proposed rule, I expect CMS will make a couple strong changes to the rule. If nothing else to show that they listened (and I think they really do listen).

Stage 2 Meaningful Use by The Advisory Board Company
The Advisory Board Company has a good blog post listing the 10 key takeaways on stage 2 of meaningful use. Below you’ll find the 10 points, but it’s worth visiting the link to read their descriptions as well.
1. Centers for Medicare & Medicaid Services (CMS) affirms a delay for 2011 attesters.
2. Stage 1 requirements will be updated come 2013.
3. Medicaid definitions are loosened; more providers are eligible.
4. While the total number of objectives does not grow, Stage 2 measure complexity increases significantly.
5. Information exchange will be key, but a health information exchange (HIE) will not be necessary.
6. Patients will need to act for providers to succeed.
7. Sharing of health data will force real-time, high-quality data capture.
8. More quality measures; CMS’ long term goals—electronic reporting and alignment with other reporting programs—remain intact.
9. The Office of the National Coordinator’s (ONC) sister rule proposes a more flexible certification process and greater utilization of standards.
10. Payment adjustments begin in 2015.

AMA MU Stage 2
The American Medical News (done by the AMA) has a blog post up which does a good job doing an overall summary of where meaningful use is at today (post MU stage 2). Meaningful Use experts will be bored, but many doctors will appreciate it.

Justin Barnes on Meaningful Use Stage 2
Justin Barnes provides his view on meaningful use stage 2 in this HealthData Magement article. It seems that Justin (and a few other of his colleagues at other EHR vendors) have made DC their second home as they’ve been intimately involved in everything meaningful use. I found his prediction that the meaningful use stage 2 “thresholds and percentages will remain largely in place come the Final Rule targeted for August, and should not be decreased via the broader public comment phase next underway like we saw with Stage 1.” Plus, he adds that the 10 percent of patients accessing their health information online will be a widely discussed topic. Many don’t feel that a physician’s EHR incentive shouldn’t be tied to patients’ actions. Add this to the electronic exchange of care summaries for more than 10 percent of patients and the healthcare data is slowly starting flow.

Meaningful Use Stage 2 and Release of Information
Steve Emery from HealthPort has a guest post on HIT Consultant that talks about how meaningful use stage 2 affects ROI. This paragraph summarizes the changes really well:

The bottom line for providers is that Stage 2 MU changes with regards to these specific criteria will drive organizations to implement a patient portal or personal health record application; and connect their EHR systems to these systems. Through these efforts it is expected that patient requests to the HIM department for medical records will decrease; as patients will be able to obtain records themselves, online and at any time.

e-Patients and Meaningful Use Stage 2
e-Patient Dave got together with Adrian Gropper MD, to put together a post on meaningful use stage 2 from an e-Patient perspective. This line sums up Adrian Gropper MD’s perspective, “My preliminary conclusion is that Stage 2 is a huge leap toward coordinated, patient-centered care and makes unprecedented efforts toward patient engagement.”

Meaningful Use Stage 2 Standards
Those standards geeks out there will love Keith Boone’s initial review and crosswalks from this rule to the Incentives rule here.

Shahid Shah on Meaningful Use Stage 2
I like Shahid Shah’s (the Healthcare IT Guy) overview and impressions as well. He’s always great at giving a high level view of what’s happening in healthcare IT.

Are there any other meaningful use stage 2 resources out there that you’ve found particularly useful or interesting?

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Although I cannot claim to have read through the entire 455-page Proposed Rule on Stage 2 Meaningful Use, the fact that it is shorter than the 864-page rule that defined Stage 1 does not mean that it is simpler—it just requires less explanation since the basic structure of the program has not changed.

Rather than trying to summarize the Rule at this point, I am just going to point out some highlights gleaned from the presentations at HIMSS last week and from my quick skim through the document:

• The meaningful use bar has been raised significantly for Stage 2.
• The earliest that any providers will be subject to Stage 2 requirements is 2014; all EPs operate under Stage 1 requirements for their first 2 years of participation, regardless of when they first enter the program.
• Most measures have higher thresholds, some have increased complexity, and new measures have been added.
• Providers have fewer choices—there are 17 Core Measures that all providers must meet (subject to the same types of exclusions as Stage 1), all Stage 1 Menu Measures except syndromic surveillance become Core Measures, and providers will have to meet 3 of the 5 Stage 2 Menu Measures.
• True interoperability is required—Stage 2 no longer asks providers to test their ability to exchange clinical data, but rather requires them to successfully exchange information on an ongoing basis across organizational and EHR vendor boundaries.
• Providers will be accountable, to some degree, for actions by patients. For example, it will no longer be sufficient to make clinical information available to patients online—in Stage 2, a percentage of patients will have to actually access this information.
• Providers will have the flexibility to purchase just the capabilities that they need to meet meaningful use—e.g., a chiropractor who does not prescribe will not have to have an EHR with ePrescribing capabilities, and a provider who is still at Stage 1 will not have to possess the meaningful use capabilities relevant to Stage 2 (until he gets to Stage 2).
• Providers will report on 12 clinical quality measures, and there will be a broader array of measures from which to choose. One option under consideration would consolidate reporting for meaningful use and PQRS.
• 2015 penalties can be avoided by demonstrating meaningful use in 2013, or for those who enter the program in 2014, by successfully attesting no later than October 3, 2014.

For more information, see the CMS Stage 2 Meaningful Use Fact Sheet.

Yep, that’s the major noise you heard at HIMSS today. The Meaningful Use Stage 2 NPRM sucked the life out of HIMSS today it seems. It was funny seeing many of the major EHR vendors scrambling to get their thoughts on MU stage 2 out. I’m not sure what’s the big rush.

You can also get the meaningful use stage 2 fact sheet on CMS.gov.

I will refrain from any rush to judgment about meaningful use stage 2. It’s not going to be implemented for quite a while, so we have time to digest it properly. I’m sure we’ll cover meaningful use stage 2 a lot more to come in the future.

Until then, I’m ready for my post-HIMSS recovery. Although, both keynotes look pretty interesting tomorrow.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

As the industry anxiously anticipates the Proposed Rule for Stage 2 meaningful use—likely expected during HIMSS this week—many providers are still struggling to understand meaningful use Stage 1. So while we wait for the impending news story to break, let me address another question that was recently posed by a reader. 

Q: Can a physician attest and earn a Medicare EHR incentive for his second reporting year if he will be retiring in the middle of the year? 

A: To my surprise, this situation is not explicitly addressed in the regulations. One would think that a physician who works full time for part of the year would be just as eligible as one who works part time for the full year. The retiring physician, however, faces two obstacles: 1) The regulations require that an EP report for an entire calendar year after receiving a first meaningful use payment. 2) The EP must have an active enrollment record in PECOS (Medicare) to be eligible to attest—if he retires and withdraws from Medicare, he would no longer have active status. These factors suggest that a retiring physician is not eligible for an incentive (unless, of course, he times his retirement for the end of the year!)

In lieu of a definitive answer to the question, however, I offer the following food for thought: 1) Couldn’t the retiring physician simply wait until December 31 to attest and then report on the full calendar year? 2) What if he simply postpones surrendering his PECOS enrollment until the end of the year? (According to a local Medicare contractor, nothing prohibits him from doing that even though he would no longer be submitting claims.) If there are countervailing reasons not to do this that readers are aware of—and there may well be—please share your insights by commenting below. 

(Note: This is not an issue for retiring physicians in their first incentive year since they attest immediately upon the conclusion of their 90-day reporting period.)

It’s Sunday and the excitement to see old friends and hear interesting things at HIMSS 2012 is just around the corner. The #HIMSS12 hashtag is off the charts with people flying into Las Vegas and others talking about what they’re doing, seeing, hearing and expecting from HIMSS Las Vegas.

Most people on Twitter are quite excited for HIMSS (as am I), but a few have said that people won’t be missing much. I thought about it for a minute and realized that the thing I love most about HIMSS is meeting really smart people. With 37,000 people likely to attend HIMSS 2012, there are plenty of smart people to meet and connect with at HIMSS.

Justin Barnes, VP at Greenway Medical, is one of the smart people I like to talk with at HIMSS. Turns out that tonight he was sharing some of that wisdom, information and perspective on Twitter tonight. So, this EMR and Health IT Twitter roundup is the Justin Barnes edition.

Strong #MeaningfulUse progress ~ $3.1+ billion paid to 43,000+ care providers. #CMS #EHR #EMR @ONC_HealthIT @CMSGov #HealthIT #HIMSS12

— Justin Barnes (@HITAdvisor) February 20, 2012

I wish he would have broken this out into ambulatory doctors versus hospitals. $3 billion of ~$36 billion projected. I guess they’re expecting a windfall next year?

That is the billion-dollar question @theEHRGuy. There are good reasons to stay the #ICD10 course & good reasons to delay…. #HIMSS12

— Justin Barnes (@HITAdvisor) February 20, 2012

Is a billion dollars at stake in the ICD-10 delay decision? Regardless of the exact amount, it shows you the magnitude of the ICD-10 delay announcement.

Tuesday looks to be the day now when we should see the #MeaningfulUse Stage 2 proposed rule. #CMS did try to get it out on Friday. #HIMSS12

— Justin Barnes (@HITAdvisor) February 20, 2012

Someone on Twitter asked if it could be delayed past Tuesday. Neil Versel from Meaningful Healthcare IT News answered well: “Never underestimated bureaucracy.”

Good #MeaningfulUse update ~ $71M+ paid to 3,379 Nurses & Physicians Assistants under #Medicaid #EHR Program. #CMS #HIMSS12

— Justin Barnes (@HITAdvisor) February 20, 2012

That’s a little surprising to me that so many Nurses and PA’s got paid so much since they only qualify under Medicaid. I’m glad to hear it.

$412,866,000 in #EHR #MeaningfulUse incentives paid to 22,937 #Medicare Eligible Professionals. #HIMSS12 #EHRAssociation @CMSGov #EMR

— Justin Barnes (@HITAdvisor) February 20, 2012

When the number is totally written out, that’s a lot of 000′s and that’s only millions.

Looking forward to seeing many old friends and making many new friends at HIMSS this week.

If you live and love the EMR, EHR and Healthcare IT world like I do, then you’re enjoying all the big news that’s coming out right now. A part of me thinks that the big news is coming out because HIMSS is so close, but some of the news seems like it might not necessarily be timed directly to HIMSS. (To see company news coming out at HIMSS, check out our EMR, EHR and Healthcare IT News site.)

For those not keeping track, here’s a quick run down of some of the major news pieces I’ve seen that really point to larger trends in healthcare IT:

Meaningful Use Stage 2
We know that meaningful use stage 2 is imminent. It’s just a question of when we’re going to hear it. In fact, it might be announced as I’m writing this post. Neil Versel first queued us into the Meaningful Use Stage 2 Announcement prior to HIMSS, but the Twittersphere is also full of rumors about the announcement. Brian Ahier commented on my Facebook message about it:

Nothing is official until it’s released, but since Monday is a holiday it is very unlikely they will wait until next week. My understanding is that the review at the OMB is complete and the proposed rule is ready to be published…

For those who want a sneak preview on what to expect in meaningful use stage 2, check out Jennifer Dennard’s meaningful use stage 2 post.

ICD-10 Delayed
Many have wondered if ICD-10 would be delayed with most arguing that 5010, meaningful use and ICD-10 was a lot to change all at once. Two days ago I got an email from someone saying they thought ICD-10 wouldn’t be delayed. I replied that I wasn’t sure either way, but it seemed like there was movement that could make a delay quite possible. Although, I must admit that I didn’t even think the ICD-10 delay announcement would happen so quickly.

Regardless of prognostication, ICD-10 is going to be delayed. You can read my thoughts on the ICD-10 Delay on EMR Thoughts.

HIMSS Acquires mHealth Summit
Maybe this feels like bigger news since it’s so close to HIMSS and I can see how powerful this conference has become. You can read the press release on the acquisition here. This isn’t that surprising since HIMSS had partnered with the mHealth Summit last year. I think this spells really good things for the growth of the mHealth Summit. I’m not sure I’d want to be another mHealth conference, but there’s a niche for the right event.

I still have a hard time distinguishing mHealth from healthcare IT in general. There could be some differentiation, but I still believe that over time the dividing line between the two is going to be hard to see. Richard Scarfo, HIMSS’ vice president of vendor events (previously mHealth Summit director) is right to be concerned that it will be HIMSS 2.0.

Navinet Acquired by Blues Plans and Lumeris
Read more about the acquisition here. I must admit that I’m still trying to process exactly what this means. Although, one thing I’m sure it means we’re moving the tectonic ACO plates that will be necessary to change how we pay for healthcare.

Vince Kuraitis and Leonard Kish provide some interesting insight in this Google+ thread asking whether this is a shift from institution (enterprise) centered IT to patient centric IT or if it’s becoming payer centric IT. They also mention United’s restructuring of payments and Aetna’s acquisition spree as indicators of the shifting plates of healthcare reimbursement.

Aneesh Chopra as Senior Advisor to the Advisory Board Company
This isn’t as big of news, but it just came out so I thought I’d throw it in. For those that don’t know Aneesh Chopra is now former CTO of the US. Everyone just wondered what he’d do next. Brian Ahier posted that Aneesh Chopra landed at The Advisory Board Company where he worked previously for about 10 years. Looks like Aneesh and his energy and enthusiasm will still be around healthcare. I think that’s a very good thing.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

A reader posed the following question: What happens if a physician receives a Medicaid EHR incentive in 2011, no longer meets the 30% eligibility threshold for Medicaid in 2012 and therefore elects not to apply for any incentive that year, and then has to switch to the Medicare program in 2013 because his Medicaid volume is still too low to qualify under Medicaid? Below is a follow-up to a prior post, (“Switching Between Medicare and Medicaid Incentive Programs”), that provides the additional information needed to not only answer this particular question, but also to evaluate the financial impact of other scenarios in which a provider might skip years and/or switch between programs. 

Here are the rules regarding switching programs and skipping years:

• An EP can switch between programs only once after receiving his first incentive payment, and the switch must occur in 2014 or earlier.
• When an EP switches programs, he is “placed in the payment year he would have been in had he begun in—and remained in—the program to which he has switched.”
• Medicare and Medicaid treat skipping years differently. Medicare incentives require that payment years be consecutive—so while an EP can skip a year, if he does, he forfeits that year’s incentive permanently. Medicaid incentive payments, on the other hand, can be non-consecutive with no adverse impact on total available revenue.
• The last year that payments will be available also differs between the two programs. Under Medicare, no payments will be made after 2016, whereas EPs have until 2021 to earn incentives under Medicaid.
• Although an EP who switches to or from the Medicare program could—under certain circumstances—earn more than the total Medicare incentives ($44,000), in no cases would any EP be paid more than the maximum available under Medicaid ($63,750). 

To get back to the physician in the reader’s question, when he switches to the Medicare program after skipping 2012, 2013 would be considered (and paid as) his third payment year. 

Confused? To analyze the financial implications of switching programs and/or skipping a year under scenarios that might apply to your practice, make a chart and do the math—taking into account the above rules and the schedules of annual incentives.

I’m sure many of you are recovering from the Super Bowl right now. I got exactly what I wanted from the Super Bowl: a great game. I didn’t care too much either way, but I am glad that I predicted the Giants to be the winners. Too bad I’m not a betting man. Although, I guess that’s the trick with betting….but I digress.

Time for my regular weekend round up of interesting things happening in the healthcare IT and EMR twittersphere. We’ve got some really interesting tweets this week. Here we go.

@NateOsit We also have a webinar of @eCollab12 for those that wont’ be able to make it to #HIMSS12.ecollab12.eventbrite.com #hitsm

— Leonard Kish (@leonardkish) February 3, 2012

When I created and posted my list of HIMSS 12 sessions, they hadn’t created the agenda for the eCollaboration Forum at HIMSS and so I couldn’t add any sessions. However, the eCollaboration Forum at HIMSS 12 agenda is up now, so check it out. I know there are a number of sessions I’m going to add from the forum. I also love that they have the online option linked in this tweet for those not attending HIMSS 2012.

Yes, stage 2 #meaningfuluse NPRM will be out before #HIMSS12. meaningfulhitnews.com/2012/01/30/yes… #healthIT #ONC #CMS #hitpol #EHR #EMR

— Neil Versel (@nversel) January 31, 2012

This is really important news. I think a lot of us are REALLY interested to see the final meaningful use stage 2 details. Good find by Neil Versel.

Speaking doctor-to-doctor(s) using healthcare social media bit.ly/wiqbyu #hcsm #hcsmeu

— H2Online (@H2Ohu) January 30, 2012

I’m sure we’re going to continue seeing the trend of more and more doctors gleaning value from engaging in social media. At a minimum doctors are going to start finding more and more new patients using social media including things like physician blogging. A well done practice website and social media effort is going to be really valuable for the doctor of the future.

3 reasons why you should start a blog for your hospital bit.ly/ypCE78 #hcsm #blogging

— Mark Ragan (@MarkRaganCEO) January 30, 2012

Yes, blogging will also help hospitals in a number of ways too. Social media can benefit hospitals, doctors, practices, etc.

@DonRosenthal Tablets are for content consumption. PCs are for content creation. Much more intellectual flexibility w/ PCs. #HITsm

— Erica V. Olenski (@TheGr8Chalupa) February 3, 2012

I was fascinated by this tweet. First because I wonder what changes will make tablets more than just great for content consumption. Second, the idea of PCs being more intellectually flexible.

RT @patientslikeme: “my healthcare data is not nearly as portable/accessible as my financial data.” @jeff_cole #hcsm

— Jacqueline Thong (@jacthong) January 30, 2012

I know there are reasons why financial data is more portable and accessible than healthcare data, but it still irks me that we haven’t overcome those reasons…yet!