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Features of the Coming “Care Management System”

Posted on October 28, 2015 I Written By

John Lynn is the Founder of the 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 and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Back in May I wrote about the Care Management System being the next big purchase for healthcare in the same trend as PM/HIS, EHR, and now a care management system. The biggest feature of the care management system is that it would have the patient at the center. The more I talk with people, the more I think this vision of a patient centered platform is the future of healthcare.

I was also pleased the Sandeep Puri from Patientriciti is working to build such a platform. In fact, he’s outlined the 5 attributes of a robust Care Management System:

  1. Personalization
  2. Behavior Change
  3. Ease of Use for Providers
  4. HIPAA Compliant
  5. Scalability

He also outlined the 10 capabilities of a Care Management system:

  1. Patient Data Intake
  2. User and Role Management
  3. Targeting Analytics
  4. Program Development
  5. Program Administration
  6. Response Analytics
  7. Survey Analytics and Alerts Management
  8. Rewards Management
  9. Care Manager Dashboard and Workflow Tool
  10. Backward Integration of patient-generated data

I think these lists might complicate things a little bit when trying to communicate what the care management system should accomplish. However, I love that people like Sandeep are thinking deeply about what they’re working to accomplish. Plus, I’m really happy he’s sharing these perspectives with the world so that we can all work to refine them and make healthcare better.

What do you think of the concept of a care management system? How about the way Sandeep has laid it out? What would a patient centered platform look like to you?

CMS Redefines Telemedicine by Bringing Better Care to 15 Million Patients and Huge Profitability to Medical Facilities

Posted on September 17, 2015 I Written By

The following is a guest blog post by Donald Voltz, MD.
Donald Voltz - Zoeticx
Telemedicine is about reaching out to patients in remote locations, but limited to videoconferencing between patients and health providers. It is similar to a face-to-face service with the exception that the patient and primary care provider are not physically together. Such efficiency is limited in term of scope and only addresses the geographical challenge and scarcity of physician availability, a far cry from what CMS wanted for its Chronic Care Management Services (CCM) which would fundamentally change telemedicine as it is practiced.

CCM services bring the telemedicine definition to the next level – a quiet continuous monitoring and collaboration from all care services to the patient, given the ability to anticipate and engage in care issues. Such ability not only curbs care costs, it would also increase care provider bandwidth, giving them the ability to cover more patients with better efficiency. The challenge is not on the requirements part of CCM services, but the lack of an IT solution to really address all CMS guidelines, including its intent to enforce the concepts through the healthcare industry.

The New England Journal of Medicine has covered the major challenges from the new CCM guidelines, touching on all the major shortcomings in today healthcare IT offerings.  Healthcare providers recognized that the fee-for-service system, which restricts payments for primary care to office-based visits, is poorly designed to support the core activities of primary care, which involve substantial time outside office visits for tasks such as care coordination, patient communication, medication refills, and care provided electronically or by telephone.

The time has come for a paradigm shift to reengineer how we deliver care and manage our patients. To arrive at a new plateau requires rethinking the needs of our patients and how to meet these needs in an already resource constrained system. Unless we develop solutions that both integrate with and enhance the technologies currently available and those yet to be realized, we will not realize a return on health IT investment.  This needs to be an area of focus for hospital CEOs, CIOs and CMOs.

Huge Market Opportunity

According to the 2010 Census, the number of people older than 65 years was 40 million with increasing trends to 56 million in 2020 and not reaching a plateau until 2050 at 83.7 million.  With two-thirds of Medicare beneficiaries having two or more chronic conditions while one-third has more than three chronic conditions according to CMS data, putting the number of patients who qualify for CCM services at 15 million. This number is predicted to continue on an upward trend until 2050.

The World Health Organization (WHO) recognized the growing burden this trend in chronic disease places on the healthcare system and addressed the need for innovative solutions in their 2002 report. While the potential market is huge, in the billions of dollars yearly, healthcare organizations have been struggling to address the CMS guidelines with key requirements from CMS. We can no longer afford not to address the needs of patient with chronic medical conditions along with engaging them in their healthcare decisions.

CMS’ CCM guidelines are as follows:

  • 24×7 access to clinical staff
  • Patient care continuum
  • Collaboration, coordination between primary care providers and other care services
  • Electronic management of care transition among care providers
  • Coordination between home and community care services
  • Patient engagement

Here is how these guidelines are now being addressed:

The Patient-Centric Model

While each patient has a primary care provider who is responsible for CCM service, they are not confined to receiving care in a single practice or institution. The primary care provider assumes the role of care coordinator, but care is likely to be distributed between multiple care providers, often across different care locations. In a patient-centric care model, care services can come from any care providers – geographically and organizationally diverse, necessitating an accountable provider to coordinate and orchestrate high-quality care across multiple chronic conditions.

Secure Electronic Care Transition

CMS clearly states these CCM care plans must be electronically available at all times to all care providers who will be delivering care to these patients, not available by faxing, or scanning as patient data is currently shared. The chronic care management plan must be available to all healthcare providers who might take care of these patients 24×7. In addition, the primary care provider who assumes the care coordinator responsibility for a patient is expected to follow-up on the care delivered, additional needs of the patient and changes in chronic condition that may have been addressed by a healthcare professional remote to the patients’ primary practice.

CMS neither authorizes how such a CCM system is designed nor enforces how efficient the implemented care service is. The monthly reimbursement limits the time and additional resources physicians are able to allocate for the development, implementation and daily operations of a CCM program in their practice. The manual implementation of a system that meets all of the requirements defined by the CMS will far exceed the reimbursement recovered. It is also likely to be inferior to one with some degree of automation coupled with messaging when a patient’s condition changes or their chronic care management plan is accessed by other providers. Efficiency along with automated logging of time spent on care coordination are critical requirements for a service to be effective.

A CCM service solution must meet the requirements defined by CMS while integrating into the current operational structure of primary care practice and integrate with current health IT systems and manage the secure documentation flow.  It must also offer a built-in notification system to alert physicians to changes in patient status and/or access to the care plan while maintaining an efficient operation in clinics with a lower overhead and no need for additional infrastructure.

While CMS does not enforce the efficiency of a CCM care service, the monthly payment must represent an increase of revenue to care providers. Care providers cannot implement a new potential code while increasing its cost due to manual labor increase. So, efficiency must be part of the solution requirements.

The answer to CCM service would be a new healthcare application offering secure documentation flow, built-in notification and collaboration services to support a low cost, efficient operation for clinics.

The CCM application must address the following requirements:

  • No disruption of existing services. The application must operate and integrate seamlessly with any existing EHR so to not change provider workflow or disrupt current processes; defining a very stringent requirement to keep the existing EHR systems untouched and unchanged while allowing for this new service to co-exist.
  • Secure electronic care transition with CCM care plan sharing. Patients can engage with this new care service even when the service may not be contained within the same network as the primary care provider. Patients ultimately maintain control of what information and with whom this information is shared. The primary care provider is responsible for maintaining the CCM care plan, as well as the patient, and should expect any information shared will be used for a single care session and not beyond it. Although the CCM care plan is expected to contain the most up-to-date medication information, primary care providers are not interested in opening up their entire system to others, but instead need to maintain control and secure access while allowing for access to these protected documents.
  • Automation, automation and automation. Efficiency of the whole CCM service must be at the core so that primary care providers can enhance patient care without adding expense and resources to implement it. Consider a patient with Congestive Heart Failure (CHF) where continuous monitoring of weight is critical for early intervention and the avoidance of hospitalizations. To engage patient’s in their care, they must be given a mechanism to report daily weight to their primary care provider. The primary care provider must have a solution where attention is given if the patient’s condition so it not has exceeded a certain threshold. Automation is required so that primary care providers can be efficient and only given attention when attention is required. Automation must be in place so that no activities such as follow-up would be omitted.
  • An EHR-agnostics solution. Implementation of a CCM service must address the constraints of a non-homogeneous environment. Healthcare organizations and physician practices are not able to control the EHR environments when patients receive care outside of their primary practice. The requirement for electronic document exchange along with the expectation of the latest patient health data being contained in the CCM care plan goes beyond a static solution offered by a data duplicated HIE (Health Information Exchange) infrastructure.
  • Visible value to a patient. A critical requirement for CMS reimbursement is a patient’s opting into a CCM management program that includes out-of-pocket monthly co-pay for the service of 8 dollars per month. A patient must see the value for CCM services which can be demonstrated through enhanced engagement, access to providers and the assurance that their condition is being overseen each month by their chronic care coordinator. Anticipation of an early intervention for potential problems along with the ability to inquire and receive feedback on their condition(s) brings added value to patients and their loved ones. This value can only be delivered if such a service can be developed in an efficient manner with a low cost of operating and a limited expansion of personal to bring it about.
  • Documentation of discontinuous time spent on care coordination. CMS requires at least 20 minutes are spent on care coordination activities each month in order to bill for this for patients enrolled in the program. Without a seamless component to log such activity, the efficiency of the overall process comes into question. A comprehensive CCM application must address the practice management side to account for and generate monthly reports of the CCM activities completed.

Future of Healthcare Impacted by Integration, Patient Data and New Modes of Delivery

The future of healthcare will be impacted by the integration of technology, patient collected data, and enhancement of healthcare professionals’ ability to deliver care in modes not yet imaged. With respect to management of chronic medical conditions, leveraging technology to coordinate the care delivered so these patients can lead productive lives at a reduced cost with less time in the hospital for exacerbations of their disease is a goal that is now possible.

Development of tools to coordinate care without additional health IT expense, in either time spent learning a new workflow or cost of such an application, is now available. Finding such an innovate model that works for patients, healthcare professionals and health systems for chronic care management will likely spread into other areas of healthcare. CCM services and care coordination allow remote, discontinuous, non-face-to-face management of patients with complex health conditions when it meets stringent requirements – a quiet, continuous monitor of health status and interventions, collaboration of all care delivered to the patient, an ability to anticipate, engage and alert patients and care professionals of impending issues, along with the administrative side of billing and logging such activity.

This ability not only changes the direction of the chronic care cost curve, it also increases care provider bandwidth, giving them the ability to successfully manage more patient, with better efficiency while delivering high quality, valuable care.

About Donald Voltz, MD
Donald Voltz, MD, Aultman Hospital, Department of Anesthesiology, Medical Director of the Main Operating Room, Assistant Professor of Anesthesiology, Case Western Reserve University and Northeast Ohio Medical University.

Board-certified in anesthesiology and clinical informatics, Dr. Voltz is a researcher, medical educator, and entrepreneur. With more than 15 years of experience in healthcare, Dr. Voltz has been involved with many facets of medicine. He has performed basic science and clinical research and has experience in the translation of ideas into viable medical systems and devices.

Thanh Tran, CEO of Zoeticx, also contributed.

Are ACOs More About Good Accounting and Reporting Than Improving Care?

Posted on August 28, 2015 I Written By

John Lynn is the Founder of the 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 and 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 recently reading David Harlow’s analysis of the recently released data from CMS on ACO performance and found a lot to chew on. Most people have found the results underwhelming unless they’re big proponents of ACOs and value based reimbursement and then they’re trying to spin it as “early on” and “this is just the start.” I agree with both perspectives. Everyone is trying to figure out how to reimburse for value based care, and so far we haven’t really figured it out.

These programs aside, after reading David Harlow’s post, I asked the following question:

The thing I can’t figure out with ACOs is if they’re really changing the cost of healthcare or if they’re mostly a game of good accounting and reporting. Basically, do the measures they’re requiring really cause organizations to change how they care for patients or does it just change how organizations document and report what they’re doing?

I think this is a massive challenge with value based reimbursement. We require certain data to “prove” that there’s been a change in how organizations manage patients. However, I can imagine hundreds of scenarios where the organization just spends time managing how they collect the data as opposed to actually changing the way they care for patients in order to improve the data.

Certainly there’s value in organizations getting their heads around their performance data. So, I don’t want to say that collecting the right data won’t be helpful. However, the healthcare system as a whole isn’t going to benefit from lower costs if most ACOs are just about collecting data as opposed to making changes that influence the data in the right way. The problem is that the former is a program you can build. The later is much harder to build and track.

Plus, this doesn’t even take into account that we may be asking them to collect the wrong data. Do we really know which data we need to collect in order to lower the costs of healthcare and improve the health of patients? There is likely some low hanging fruit, but once we get past that low hanging fruit, then what?

In response to my comment, David Harlow brought up a great point about many of the ACO program successes not being reproducible. Why does an ACO in one area improve quality and reduce costs and in another it doesn’t?

All of this reminds me of the question that Steve Sisko posed in yesterday’s #KareoChat:

There are a lot of things that seem to make sense until you dig into what’s really happening. We still have a lot of digging left to do in healthcare. Although, like Steve, I’m optimistic that many of the things we’re doing with ACOs and value based care will provide benefits. How could they not?

HIMSS15: Adoption Still a Problem for Organizations Swapping EHRs – Breakaway Thinking

Posted on May 20, 2015 I Written By

The following is a guest blog post by Todd Stansfield, Instructional Writer from The Breakaway Group (A Xerox Company). Check out all of the blog posts in the Breakaway Thinking series.
Todd Stansfield

Each year the Health Information and Management Systems Society’s (HIMSS) annual conference is the Super Bowl of health IT. No other conference boasts more attendees ranging from health IT innovators and collaborators to pioneers. This year 40,000 plus participants descended on Chicago, all eager to learn about the new direction, trends, and solutions of the industry.

As always, buzzwords were aplenty—interoperability, care coordination, patient experience, and value-based care, to mention a few. During her keynote address on April 16, Karen DeSalvo, National Coordinator for the ONC, called the current state of health IT the “tipping point.” In 2011 the ONC released its four-year strategic plan focused on implementing and adopting electronic health records (EHRs). Now, DeSalvo says the industry is changed and ready to move beyond EHRs to technologies that will create “true interoperability.”

Enlightening conversations were happening among the crowded booths, hallways, and meeting rooms between organizations looking to ‘rip and replace’ their current EHR for a new one. While some organizations are struggling to unlock data across disparate systems, others are looking to upgrade their current system for one compatible with ICD-10, Meaningful Use, analytics solutions, or a combination of these. Still others are looking to replace systems they dislike for lack of functionality, vendor relationships, etc. In many cases, replacing an EHR is needed to ensure interoperability is at the very least viable. This buzz at HIMSS is a strong indicator that EHRs are still an important and essential part of health IT, and perhaps some organizations have not reached the tipping point.

In addition to the many challenges these organizations are facing—from data portability, an issue John Lynn wrote about in August 2012, to the cost of replacing the system—leaders are agonizing over the resistance they are facing from clinician end users. How can these organizations force clinicians to give up systems they once resisted, then embraced and worked so hard to adopt? How can leadership inspire the same level of engagement needed for adoption? The challenge is similar to transitioning from paper to an EHR, only more significant. Whereas the reasons for switching from paper were straightforward—patient safety, efficiency, interoperability, etc.—they are not so clear when switching applications.

Clinicians are also making harsher comparisons between applications—from every drop-down list, to icon, to keyboard shortcut. These comparisons are occurring at drastically different phases in the adoption lifecycle. Consider the example of an end user needing to document a progress note. In the old EHR, this user knew how to copy forward previous documentation, but in the new system she doesn’t know if this functionality even exists. Already the end user is viewing the new system as cumbersome and inefficient compared to the old application. Multiply this comparison by each of the various tasks she completes throughout her day, and the end user is strongly questioning her organization’s decision to make the change.

This highlights an important point: Swapping one EHR for another will take more planning, effort, and strategy than a first-ever implementation. The methods for achieving adoption are the same, but the degree to which they are employed is not. Leadership will not only have to re-engage end users and facilitate buy-in, they will have to address the loss of efficiency and optimization by replacing the old application.

Leadership should start by clearly outlining the reasons for change, a long-term strategy, as well frustrations end users can expect. They should establish a strong governance and support structure to ensure end users adhere to policies, procedures, and best practices for using the application. The organizations that will succeed will provide end users with role-based education complete with hands-on experience completing best practice workflows in the application. Education should include competency tests that assess end users’ ability to complete key components of their workflow. Additionally, organizations must capture and track performance measurements to ensure optimized use of the system and identify areas of need. And because adoption recedes after application upgrades and workflow enhancements, all efforts should be sustained and modified as needed.

While HIMSS15 brought to the stage a wealth of new ideas, solutions, and visions for the future of health IT, the struggle to adopt an EHR has not completely gone away. Many organizations are grappling with their current EHR and choosing to replace it in hopes of meeting the triple aim of improving care, costs, and population health. For these organizations to be prepared for true interoperability, they must overcome challenges unseen in paper to electronic implementations. And if done successfully, only then will our industry uniformly reach the tipping point, a point where we can begin to put buzzwords into practice.

Xerox is a sponsor of the Breakaway Thinking series of blog posts.

Great Meaningful Use and Eligible Providers Chat

Posted on April 29, 2015 I Written By

John Lynn is the Founder of the 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 and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

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

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

Then, he asked me an important question:

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

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

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

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

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

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

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

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

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

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

Mobile Health to Transform Care: The Case for Adoption Now – Breakaway Thinking

Posted on February 18, 2015 I Written By

The following is a guest blog post by Todd Stansfield from The Breakaway Group (A Xerox Company). Check out all of the blog posts in the Breakaway Thinking series.
Todd Stansfield
Mobile health (mHealth) is here to stay, and you don’t have to look far for proof. Patients now use mHealth to comparison shop basic healthcare services and access test results. Providers use it to increase efficiencies and lower costs. And CIOs use it to get more out of an electronic health record (EHR) while juggling new security challenges from the bring your own device (BYOD) movement.

Perhaps one of mHealth’s greatest areas of impact is providers’ bottom line. A new study finds that baby boomers and millennials prefer providers who incorporate mobile technology into their practices. Seven percent of patients responded that they are willing to leave their current provider for one who offers remote care, a move that could have a significant financial impact on independent physician practices. This is especially clear when considering that an overall 20 percent of patients reported seeing the same doctor for less than 2 years and 14 percent reported not having a doctor. Additionally, the Centers for Medicare & Medicaid Services (CMS) is now offering providers roughly $42 a month to manage care for Medicare patients with two or more chronic conditions in its Chronic Care Management program. These patients comprise two-thirds of Medicare beneficiaries. For practices with 20 eligible patients, that figure translates to over $10,000 per provider per year. Providers must use mHealth to meet some requirements of Chronic Care Management, such as offering 24-7 access to consultation, and companies are now creating technologies to help. Just last month, Qualcomm and Walgreens announced a joint venture to pair medical devices with mobile and web apps to provide remote patient monitoring and transitional care support.

And then there’s efficiency. Another study finds that “the average hospital loses $1.7 million per year due to inefficient care coordination,” according to a HealthIT Analytics article. Providers are finding mobile technology valuable for improving health information exchange and communication, areas underserved by current EHR systems. More providers are text messaging care information rather than communicating face-to-face with colleagues, resulting in more informed care teams and fewer avoidable healthcare errors. Providers are also using mobile devices to enhance real-time patient engagement rather than relying on cumbersome computers to document in the EHR. Often the result is improved patient care, shorter appointments, and more time to see more patients. And besides getting in and out of their provider’s office sooner, patients are also welcoming new efficiencies with real-time access to their medical records via smartphone, a selling point among younger generations pursuing an active role in their care. In a recent survey of Americans, millennials indicated a preference for patient portals that they can access via a smartphone or tablet.

Yet providers should plan carefully when implementing mHealth, as there are major costs for failing to set up robust infrastructures that support safe mobile use. Providers should perform security risk analysis to ensure the safety of protected health information (PHI). This includes evaluating the security of all mobile devices—tablets and smartphones—ensuring that each device stores, sends, and receives PHI securely using encryption and other methods. Providers must perform this analysis routinely to receive payments under Meaningful Use (MU) and to prevent the ever-growing number of data breaches. Data security has remained a chief concern for healthcare providers and leaders and has largely stifled the widespread adoption of mHealth. This may change as the Department of Health & Human Services plans to offer more guidance to mHealth developers and users for adhering to HIPAA rules, as it recently announced.

Providers must adopt mHealth to survive in today’s competitive marketplace. Not only will they reap the short-term benefits of higher revenues through Chronic Care Management and attracting new patients, but they will also build the secure infrastructure and tools needed for long-term success. mHealth will be critical to population health and health information exchange, two eventual destinations for the healthcare industry. Providers who adopt mHealth now will be ready for when our industry makes the complete shift toward a population-focused, value-based care model.

In my experience at The Breakaway Group, A Xerox Company, effective adoption begins when leaders engage their workforce in the vision and mission of the project; when education is focused, accessible, and targeted; when performance is measured, collected, and analyzed; and when adoption is sustained amid changing technologies and process improvements. For providers to make the transition successfully healthcare leaders must find and implement technologies that patients and providers want to use. They must provide education that is convenient, focused, and practical for providers, education that spans not only how to optimize the technology but also how to use it safely and in accordance with government regulations. Healthcare leaders must also track performance in quality and efficiency, and highlight areas for improvement. And lastly, they must ensure all efforts are sustained, reinforced, and tailored to changing needs.

mHealth is poised to transform healthcare. It’s no wonder that mHealth raised $1.2 billion in venture capital last year, or more than triple what it raised in 2013. I’d venture to say that a significant share of new patients, new revenues, and new efficiencies will be earned by providers who are going “mobile.”

Xerox is a sponsor of the Breakaway Thinking series of blog posts.

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

Posted on January 29, 2015 I Written By

John Lynn is the Founder of the 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 and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

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

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

Here’s the modifications that they’re proposing:

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

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

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

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

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

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

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

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

CMS’ HIPAA Risk Analysis Myths and Truths

Posted on October 21, 2014 I Written By

John Lynn is the Founder of the 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 and 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’ve been writing about the need to do a HIPAA Risk Assessment since it was included as part of meaningful use. Many organizations have been really confused by this requirement and no doubt it will be an issue for many organizations that get a meaningful use audit. It’s a little ironic since this really isn’t anything that wasn’t already part of the HIPAA security rule. Although, that illustrates how well we’re doing at complying with the HIPAA security rule.

It seems that CMS has taken note of this confusion around the HIPAA risk assessment as well. Today, they sent out some more guidance, tools and resources to hopefully help organizations better understand the Security Risk Analysis requirement. Here’s a portion of that email that provides some important clarification:

A security risk analysis needs to be conducted or reviewed during each program year for Stage 1 and Stage 2. These steps may be completed outside OR during the EHR reporting period timeframe, but must take place no earlier than the start of the reporting year and no later than the end of the reporting year.

For example, an eligible professional who is reporting for a 90-day EHR reporting period in 2014 may complete the appropriate security risk analysis requirements outside of this 90-day period as long as it is completed between January 1st and December 31st in 2014. Fore more information, read this FAQ.

Please note:
*Conducting a security risk analysis is required when certified EHR technology is adopted in the first reporting year.
*In subsequent reporting years, or when changes to the practice or electronic systems occur, a review must be conducted.

CMS also created this Security Risk Analysis Tipsheet that has a lot of good information including these myths and facts which address many of the issues I’ve seen and heard:
CMS HIPAA Security Risk Analysis Myths and Facts

Finally, it’s worth reminding people that the HIPAA Security Risk Analysis is not just for your tech systems. Check out this overview of security areas and example measures to secure them to see what I mean:
CMS HIPAA Security Risk Analysis Overview

Have you done your HIPAA Risk Assessment for your organization?

Meaningful Use Hardship Exceptions Reopened

Posted on October 8, 2014 I Written By

John Lynn is the Founder of the 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 and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

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

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

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

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

What are your thoughts on this extension?

What Healthcare Must Plan for in Q4

Posted on September 19, 2014 I Written By

The following is a guest blog post by Ben Quirk, CEO of Quirk Healthcare Solutions.
Ben Quirk
In some ways, 2014 turned out to be not quite as cataclysmic. The early announcement of delaying the adoption of ICD-10 and the more recent announcement to allow hospitals/CAHs and Eligible Professionals participating in CMS’ Meaningful Use programs to attest using their existing Certified Electronic Health Record Technology (CEHRT) took the pressure off healthcare providers scrambling to upgrade their CEHRT to a version that was both ICD-10 and MU-compliant. However, this is only a temporary reprieve through the end of 2014 and there are other priorities that must be addressed before the year ends.

Navigating the ever-evolving healthcare environment will seem much less daunting if you focus on these four areas:

  • Meaningful Use
  • Value-Based Payment Modifiers
  • Transparency
  • Open Enrollment for ACA

Meaningful Use (MU)

If you were not able to upgrade to the 2014 Edition EHR, you will still be able to attest for MU using 2013 criteria. This provides reprieve from the 2014 criteria that requires the implementation of and patient enrollment in a patient portal.

In order to be MU-ready, your organization must proactively:

  • Determine your strategy based on the final rule. Gather data and be prepared to attest for MU by the deadline for the MU program you participate in..
  • Create an audit binder which should include screenshots of required EHR configuration during the reporting period. Should you get an audit 2 years from now, you can refer to this binder for accurate information.
  • Prepare a statement citing why you should be allowed to opt out of those MU measures that you think do not pertain to your practice. Auditors will ask for this on any audit preformed.

All organizations should be prepared to start collecting data for MU 2 by January 1, 2015. This includes having a strategy around the implementation of a patient portal and patient enrollment, sharing data amongst community and other healthcare providers, and radiology interfaces.

Value-Based Payment Modifier

The current Value Based Payment Modifier for providers who serve Medicare beneficiaries is a descendent of the Physician Quality Reporting System (PQRS). It is a way to keep the ACA cost-neutral, but there are some important things you need to know about this newer system. Value-Based Payment Modifier takes claims, Meaningful Use, and physician quality data and rates the quality of care you provide against your peers. Consequently,

  • When you report your Clinical Quality Measures or any clinical data to CMS, make sure your thresholds demonstrate that your practice is providing high quality care.
  • If your practice suffered from vendor problems with data accuracy in the past, this should be fixed.


Transparency is something all providers should be aware of. Although available only in a few markets right now, all patients will soon be able to look up information about physicians before deciding where they would like to have their medical procedures done. For instance, if a patient decides to have an ACL repair, s/he can go online to compare exact costs and quality measures (based on the Patient Quality Reporting System) for ACL repair. Practices need to be aware that their prices and quality are being reported publicly. The implications go beyond losing reimbursement. You can actually be delisted from an insurance network. To ensure that your practice remains a viable option for patients:

  • Market your own practice and post your own prices.
  • Make sure you are reporting good quality data.
  • Use sources such as MGMA or OPTUM to see what providers in your area are charging and how you compare.
  • Determine how your reimbursement ranks vs. your competitors on the Medicare website and ensure data accuracy.

Open Enrollment for the ACA

November 15 marks the beginning of the second Open Enrollment period for the Affordable Care Act and there is no indication that this time around will be any easier than the first. Patients will be choosing plans, dealing with things very unfamiliar, and perhaps unaffordable, to them, like deductibles. This directly impacts clinics and the bottom line, especially with those patients who cannot pay their share of the costs. Last year, patients became the number one payor for many practices, even more than insurance companies, because so much revenue came from deductibles. That all resets January 1, but there are things you can do to avoid a possibly painful Q1 of 2015:

  • Check and confirm all patients’ eligibility, what plan they are on, and what their deductible is prior to their scheduled appointment, preferably through an automatic batch eligibility service. Keep this information in the practice management system.
  • Notify patients about their deductibles before they come into the clinic, and make sure to collect payments upfront, or keep a card on file.

The healthcare industry as we knew it for the past many years has ceased to exist. As we move into a new era of integrated delivery systems and a greater emphasis on value-based rather than volume-based reimbursements, the industry is going to remain in a state of flux before it stabilizes once again. The only way organizations are going to survive in this shifting landscape is by anticipating and planning for the next change so that they can stay ahead of the curve. The more an organization knows, the better it can be prepared to confront any potentially negative impact of the ever-evolving nature of the industry.

About Ben Quirk
Ben Quirk is CEO of Quirk Healthcare Solutions, a consulting firm specializing in EHR strategic management, workflow optimization, systems development, and training. The company’s clients have enjoyed remarkable success, including award of the Medicare Advantage 5-star rating. Quirk Healthcare presents a weekly webinar series, Insights, to inform clients and the general public about government programs and industry trends. Mr. Quirk is also Executive Director of the Quirk Healthcare Foundation, a learning institution which fosters innovation in the healthcare industry.