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Your EHR Vendor Isn’t Certified – How Should You Approach MU Stage 2?

Posted on May 12, 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.

A recent study conducted by Wells Fargo Securities stated “Over 700 EHR vendors had solutions certified for Stage 1, but at this point about 40 have been certified for Stage 2. While there is still time, we believe 300-500 vendors will ultimately disappear from the government program.”

We talked about the possibility of many EHR vendors not being 2014 certified in our interview with John Squire. This is a real possibility for many EHR vendors. It will be interesting to see which ones choose not to tell their customers that they won’t be ready until it’s too late to switch EHR. I think that will say something about the company.

Allscripts has put out a whitepaper that looks at some of the meaningful use stage 2 challenges and what you should do to make sure you’re ready.

  • Where to begin with Meaningful Use Stage 2
  • The new requirements for Stage 2 attestation
  • Technology upgrade and replacement considerations
  • Meaningful Use reporting
  • Transitioning to population health management

I find the idea of using MU stage 2 as a way to get ready for population health pretty interesting. I know this is a challenge when an organization is overwhelmed by the day to day life of someone in healthcare.

Considering the abysmal meaningful use stage 2 numbers that were released, it seems that many organizations could benefit from some meaningful use stage 2 help this whitepaper provides. I’d be interested to hear if people think that MU stage 2 does help their organization move towards population health management. Is that a reasonable goal you can work on as you work on MU stage 2? Reminds me of those who are doing CDI (clinical documentation improvement) projects alongside their ICD-10 work.

Lack of 2014 Certified EHRs

Posted on April 11, 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.

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.

Eyes Wide Shut – January, 2014 Meaningful Use Stage 2 Readiness Reality Check

Posted on January 13, 2014 I Written By

Mandi Bishop is a hardcore health data geek with a Master's in English and a passion for big data analytics, which she brings to her role as Dell Health’s Analytics Solutions Lead. She 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.

Happy New Year?

As I begin the 2014 Meaningful Use measures readiness assessment and vendor cat-herding exercises, I’m reflecting on this portion of CMS’s Director of E-Health Standards and Services, Robert Tagalicod and the ONC’s Acting National Coordinator Jacob Reider’s statement regarding the Meaningful Use timeline modification: “The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2.” (Previously published on EMRandHIPAA.com.)

I call BS.

If the “goal” is a “successful implementation”, then CMS failed miserably by not addressing the START of the quarterly attestation period for Stage 2, which is still required in 2014. CMS and the ONC need more time to successfully implement the measures, and they are bureaucratic agencies that don’t directly deal with patient medical care. Why wasn’t the additional time required to truly succeed at this monumental task extended to the healthcare provider organizations? Because the agencies want to save face, and avoid litigation from early adopters who may be already beginning their 2014 attestation period amidst heroic back-breaking efforts?

Here’s a reality check for what a large IDN might be going through in early January, in preparation for the start of the 2014 quarterly attestation period. Assume this particular IDN’s hospitals’ fiscal year runs October-September, so you MUST begin your attestation period on July 1. You have 6 months.

As of December 31, 2013, only 4 of the 8 EMRs in your environment completed their 2014 CEHRT certification.

Each of those 4 EMRs has a different schedule to implement the upgrade to the certified edition, with staggered delivery dates from March to July. The hospital EMR is not scheduled to receive its certified-edition upgrade until April. You pray that THIS implementation is the exception to your extensive experience with EMR vendor target timelines extending 6-8 weeks beyond initial dates.

The EMR upgrades do not include the Direct module configuration, and the vendor’s Direct module resources are not available until 6-9 weeks after the baseline upgrade implementation – if they have knowledgeable resources, at all. Your hospital EMR vendor can’t articulate the technical infrastructure required to implement and support its own Direct module. Several vendors indicate that the Direct module configuration will have to be negotiated with a third-party. Your clinicians don’t know what Direct is. Your IT staff doesn’t know how to register with a HISP. Your EMR vendor doesn’t support a central Direct address directory or a lookup function, so you contemplate typing classes for your HIM and clinical staff.

The number of active patient problems requiring manual SNOMED remediation exceeds 60,000 records in your hospital EMR. You form a clinical committee to address, but they’re estimating it will take 6 months of review to complete. You’re contemplating de-activating all problems older than a certain date, which would whittle down the number and shorten the timeframe to complete – but would eliminate chronic conditions.

There are still nagging questions regarding CMS interpretation of the measures, so you ask for clarification, and you wait. And wait. And wait. The answers impact the business rules required for attestation reporting, and you know you need any help you can get in whittling down the denominator values. Do deceased patients count in the view/download/transmit denominator? If records access is prohibited by state/federal law, does that encounter count in the view/download/transmit denominator?

Consultant costs skyrocket as you struggle to find qualified SME resources to blaze a trail for your internal staff. Their 60-to-90-day assessments inevitably end with recommendations for “proof of concept” and “pilot” approaches to each of the 2014 measures, which don’t take into account the reality of the EMR upgrade timelines and the looming attestation start date. Following their recommendations would delay your attestation start by 9-12 months. So, your internal staff trudges forward without expert leadership, and you throw the latest PowerPoint deck from “Health IT Professionals-R-Us” on the pile.

Who needs testing, when you can go live with unproven technology the day it’s available in order to meet an arbitrary deadline? Healthcare.gov did it – look what a success that turned out to be!

But wait, this is real clinical data, generated by real-world clinical workflows, being used to treat real patients, by real healthcare providers. By refusing to address the start of the 2014 attestation period, CMS and the ONC are effectively using these patients and providers as lab rats.

I did not give permission to be part of this experiment.

One EHR Vendor’s Experience with Meaningful Use Stage 2 Certification

Posted on January 3, 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.

I always love hearing from the CEO of EHR vendors. One that never disappoints is a man that most people in the EHR world have probably never heard of. His name is Michael Archuleta and he’s the Founder and CEO of a company called ArcSys (RedPlanet is their EHR). In response to my article on ComChart not going after meaningful use certification, he sent me a newsletter he recently sent his staff and some other side comments. They provide some real insight into the 2014 certification process and meaningful use stage 2.

Excerpts from the newsletter:

ArcSys has invested heavily in meeting the demands of Meaningful Use Stage 2. Whereas we thought Stage 1 was difficult, Stage 2 has taken substantially more time to meet the requirements.

We are not alone in meeting these challenging complexities. In reading the Internet chatter, there are other vendors who are facing the daunting task at hand.

ComChart Medical Software, has thrown in the towel by saying, “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.”

Obviously, ArcSys does not share this same viewpoint. If we can do it, then it means anyone should have been able to do it, too. We are either smarter (not true) or we had a superior software design from the beginning (probably quite true). The first round of software development has now been completed and we are prepared for certification. Our certifier, the Drummond Group, has a backlog of systems to be tested and have given us a mid-April test date. Having completed this development, we know with great precision what each doctor will have to do in order to meet MU2. And, yes, it will be difficult.

There are 37 testing “points” that we have focused on. It took us two months to do 36 of these points and another two months to do the remaining point (clinical quality measures). Many of the testing points had literally hundreds of scenarios to evaluate. There were situations we would discover after working for weeks that necessitated going back to the beginning and having to start over on retests.

Now for some really interesting bullet points on meaningful use stage 2 certification:

ArcSys has to be the tiniest company on the planet seeking MU2 certification.

Yes, I dislike the extra burdens being placed on providers for MU2.
Yes, I dislike the vague (non-existent?) guidelines on how to properly use SNOMED, Rxnorm, and LOINC.
Yes, I dislike the committees who dream up measures and certification rules that have little relevance to how docs like to treat and interact with patients. Do they really believe MU2 and seeing 40+ patients/day can co-exist??
Yes, I have written every line of code for our product to handle MU2 and I know of flaws and weaknesses the testing tools are ignoring.
Yes, I hate being pulled away from being able to work on software enhancements.
Yes, we were naive in thinking that MU2 would take as much time as MU1 to develop and test. It was easily 10 times more complicated.
Yes, I dislike wading through the Google/JIRC posts to see what other hapless souls like me our stumbling for answers regarding certification.
Yes, it is nearly impossible to read any document produced by HL7.org and find helpful guidelines.
Yes, I dislike the Cypress testing tool.
Yes, I dislike the XML bloat for reporting measures and transporting patient data.

So, why do we continue? Simple. We made a commitment to our client base who likes our service and support. And, in the end, we’ll be as conversant as anyone on the ins and outs of MU2.

How’s that for a real look at some of the nitty gritty EHR vendors face when it comes to 2014 Certification and meaningful use stage 2?

Meaningful Use Stage 2 Extension, MU Stage 3 Delay and New 2015 EHR Edition Certification Proposed

Posted on December 6, 2013 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 big news of the week just came out of CMS at 4 PM EST on a Friday. Feels like they’re trying to bury the news story, but maybe it was just the way the timing worked out. Either way, there’s no way anyone who lives in the EHR and meaningful use would miss the announcement (not to mention I’ve already seen it posted on every major health IT news site). CMS is proposing an extension of meaningful use stage 2 another year through 2016 and so that means a delay in meaningful use stage 3 until 2017.

Here’s how Robert Tagalicod, Director, Office of E-Health Standards and Services, CMS and Jacob Reider, MD, Acting National Coordinator for Health Information Technology, ONC described the change in meaningful use timeline:

Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2. The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.

The phased approach to program participation helps providers move from creating information in Stage 1, to exchanging health information in Stage 2, to focusing on improved outcomes in Stage 3. This approach has allowed us to support an aggressive yet smart transition for providers.

Meaningful Use Stage 2 and 3
This shouldn’t come as a surprise to many. In fact, we’d been discussing the possible meaningful use stage 2 extension in the comments of my post: ICD-10 will be delayed. We thought meaningful use delay was possible, and now it’s happened.

I do like that this delay gives CMS and ONC more breathing room to know what to include in meaningful use stage 3. Plus, maybe they’ll get the MU Stage 3 certification requirements out in plenty of time for EHR vendors to be able to update their software.

One thing that is really interesting about this delay is that meaningful use stage 3 won’t go into effect until after the Medicare EHR incentive money is over. The Medicare EHR incentive money is only scheduled to be paid through 2016. Medicaid wasn’t implementing MU stage 3 until year 6, so I expect there’s no change there. While you won’t have to show MU stage 3 for Medicare EHR incentive money, you will have to attest to meaningful use stage 3 in 2017 if you want to avoid the EHR penalties (Payment Adjustments if you prefer CMS’ terminology). In 2017, those EHR penalties will be at 3%.

Many have called for a delay to meaningful use stage 2 as well, but that didn’t happen today.

2015 Edition EHR Certification
The other part of the CMS announcement is the 2015 Edition EHR certification. They propose having an additional 2015 EHR certification that sounds like it would amount to an update to the 2014 edition. The 2015 edition would fix any issues with the 2014 edition and update any changes to interoperability standards. Sounds like an EHR certification patch.

The catch is that EHR vendors that are 2014 Edition EHR certified wouldn’t have to do 2015 Edition. This is good since we don’t need software vendors having to certify again (as much as certifying bodies would love the new revenue). Although, I won’t be surprised if most EHR vendors take the new standards in the 2015 edition and update their software to those standards. Let’s just hope that if they choose to do so, it doesn’t kill their 2014 Edition EHR certification. We should all be using the latest and greatest standards. Even more important, we need to all be on the same standard.

What do you think of the announcement? I look forward to hearing your thoughts in the comments.

See Also:
HIMSS Response – HIMSS Supports Stage 2 Extension
CHIME Response – Meaningful Use Timeline Shift Does Not Afford Flexibility in 2014