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What Would Make Us Not Delay ICD-10 in 2015?

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While at the HFMA ANI conference in Las Vegas, I talked to a lot of people about the future of healthcare reimbursement. Talk of ICD-10 and the ICD-10 delay came up regularly with most of us rolling our eyes that ICD-10 was delayed again. Some argued that we still need to be prepared, but from what I’m seeing the majority of the market just pushed their plans out a year and will pick them up again later this year or early next year.

With that said, we all agreed that every organization will be much more hesitant preparing for ICD-10 next year since they’re afraid that ICD-10 will just be delayed again.

As I had these discussions, I started thinking about what will be different in 2015 when it comes to ICD-10? As I asked people this question, all of the same arguments that we made in 2014 are what we’re going to have in 2015. Some of them include: the rest of the world adopted this years ago, we’re falling behind on the data we’re capturing, we need more specificity in the way we code so we can improve healthcare, etc etc etc.

Considering these arguments, what will be different next year?

All of the above arguments for not delaying ICD-10 were valid in 2014 and we’ll be just as valid in 2015. Can you think of any reasons that we should not delay ICD-10 in 2015 that weren’t reasons in 2014? I can’t think of any. The closest I’ve come is that with the extra year, we’re better prepared for ICD-10. Although, given people’s propensity to delay, does anyone think we’ll be much better prepared for ICD-10 in 2015 than we were in 2014? In some ways I think we’ll be less prepared because many will likely think the delay will happen again.

Given that the environment will be mostly the same, why wouldn’t we think that ICD-10 will be delayed again in 2015?

Personally, I’ll be watching CMS and HHS closely and see what they say. I think this year they looked really bad when they very publicly proclaimed that ICD-10 was coming at HIMSS just to be hit from the side by the ICD-10 delay. I’d hope that this time CMS will work with Congress to know what they’re planning or thinking before they make such strong assertions. Of course, this would mean that they’d have to understand what Congress is thinking (not an easy task).

What’s unfortunate is that many of the things you need to do to prepare for ICD-10 can also benefit you under ICD-9. The smart organizations understand this and are focusing on clinical documentation improvement (CDI) as the best way to prepare for ICD-10, but still benefit from the program today.

July 3, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Surviving 2014: The Toughest Year in Healthcare

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The following is a guest blog post by Ben Quirk, CEO of Quirk Healthcare Solutions.
Ben Quirk
How bad is 2014 for the healthcare industry? We’ve all read about ICD-10, EHR incentives, Medicare cuts, and the Affordable Care Act. But the most telling moment for me occurred during this year’s HIMSS conference in Orlando. There was quite a bit of B2B enthusiasm, but among the civilians it was mostly a lot of stunned looks and talk about how to get through the year. Here are some of my observations:

ICD-10. CMS has made it abundantly clear there will be no further delays to the October 1 deadline for ICD-10 implementation. This is possibly the most significant change to the healthcare industry in 35 years, affecting claims payment/billing systems, clearinghouses, and private and public software applications. Anyone who provides or receives healthcare in the US will be touched by this in some way.

In a recent poll of healthcare providers conducted by KPMG, less than half of the respondents said they had performed basic testing on ICD-10, and only a third had completed comprehensive tests. Moreover, about 3 out of 4 said they did not plan to conduct tests of any kind with entities outside their organizations.

Incorrect claims denial will be the most likely result. CMS will not process ICD-9 Medicare/Medicaid claims after October 1, and there is a high potential for faulty ICD-10 coding or bad mapping to ICD-9 codes. Error rates of 6 to 10 percent are anticipated, compared to an average of 3 percent under ICD-9. ICD-10 will result in a 100 to 200 percent increase in denial rates, with a related increase in receivable days of 20 to 40 percent. Cash flow problems could extend up to two years following implementation. This will be a costly issue for providers, and a very visible issue for patients.

We advise our clients to be proactive in their financial planning. This should include preparation for delayed claims adjudication and payments, adjustments to cash reserves, or even arranging for a new/increased line of credit. Having sufficient cash on hand to cover overhead during the final quarter of 2014 could be very important, as could future reserves to cover up to six months of payment delays. Companies not in a position to set aside reserves should consider working with lenders now before any issues arise.

Meaningful Use. As with ICD-10, CMS has stated there will be no delays to MU deadlines in 2014. That means providers who have never attested must do so by September 30, or else be subject to penalties in the form of Medicare payment adjustments starting in 2015. Providers who have attested in the past will have a bit longer (until December 31), but the penalties are the same.

There is much dissatisfaction with the government’s “all or nothing” approach to MU, where even the slightest misstep can invalidate an otherwise accurate attestation. While the ONC has proposed a more lenient model for EHR certification in coming years, everything will be measured against a hard deadline in 2014.  CMS is offering some mitigation through hardship exemptions, based on rules that are somewhat broad at this point. Providers should consider applying for an exemption if no other options are available.

We advise against taking shortcuts or rushing to beat the clock on MU. Up to ten percent of eligible professionals and hospitals will be subject to audit, and large hospitals may have millions of dollars at stake. Being prepared for an audit means more than just making sure an attestation is iron-clad; internal workflow and communication are also important. A mishandled audit notification can result in a late response and automatic failure.  Data security should also not be overlooked. Medical groups have failed audits due to lapsed security risk assessments as required under HIPAA.

Medicare Payment Cuts. Medicare Sustainable Growth Rate (SGR) cuts continue to hover over Medicare providers. Enacted by Congress in 1997, the SGR was intended to control costs by cutting reimbursements to providers based on prior year expenditures. But every year costs continue to rise, as do ever-worse SGR cuts (almost 24% in 2015). And every year Congress prevents the cuts via so-called “doc fix” legislation.

In early 2014 there was surprising bi-partisan agreement on a permanent doc fix, whereby Medicare reimbursements would be based on quality measures rather than overall expenditures. However, the legislation was derailed by linking it to a delay of the ACA’s individual mandate. As of mid-March there is still no permanent or temporary solution. Congress will almost certainly intervene to prevent SGR cuts, but by how much is uncertain.

The ACA. As the cost of insurance has increased over the past decade, high-deductible plans have become more and more common. Due to the Affordable Care Act, this trend has become the norm. Media outlets focus on the impact to consumers, and argue about whether more “skin in the game” leads to better choices or less care. What we’re hearing from the front lines is much more concrete: high deductibles are having a negative impact on revenues.

Very few people understand their liabilities under a typical health insurance plan. Last year George Loewenstein, a health-care economist with Carnegie Mellon University, published a survey showing that only 14 percent of respondents understood the basics of traditional insurance policies. At the same time, hospitals report that about 25 percent of bad debt originates from patients who are currently insured. With millions of new enrollees in high-deductible plans and an ongoing economic slump, the situation can only get worse.

The ACA had a further impact by reducing the amount of Disproportionate Share Hospital (DSH) charity funds available, based on a projected increase in insurance coverage.  But with some states not participating in Medicaid expansion, combined with an increase in patients lacking the knowledge or resources to manage large medical expenditures, the reduction in funds comes at exactly the wrong time.

Providers can cope by adjusting revenue cycle processes. For example, new programs should focus on estimating patient liabilities pre-arrival, educating the patient at check-in, and instituting proactive billing/collection at the point of service. In general, providers must pay more attention to the self-pay process, focusing on patient education and offering transparent, easy-to-use billing and payment methods.

Value Modifier. This program has not been a worry for most providers thus far. Not because it won’t have an impact on revenue, but because they don’t know about it. A little-known provision of the ACA, the Value-Based Payment Modifier mandates adjustments to Medicare reimbursement based on quality and cost measures. The program is being phased in, and so far has applied only to group practices of 100 or more Eligible Professionals (EPs). In 2014, smaller groups of 10 or more EPs will be subject to the legislation. These groups must apply and report to the program by October 1. Otherwise, they will be subject to a 2 percent cut in Medicare reimbursements starting in 2016.

One of the most important aspects of the program is its definition of “eligible professional” when defining the size of a group practice. For the purposes of Value Modifier, eligible professionals include not only physicians but also practitioners and therapists. That means that a practice with 8 physicians, a nurse practitioner, and a physical therapist would qualify as a practice with 10 EPs.

Value Modifier is part of the growing trend toward quality-based reimbursement. Even commercial payers are considering some version of the program. The scoring calculations are complex and poorly understood, so we advise clients to get up-to-speed as soon as possible. Groups with high quality and low cost will receive incentives rather than cuts, with additional upward adjustment for services to high-risk beneficiaries. Groups that are not paying attention may be surprised by an additional hit to revenue in 2016. In addition, quality scores will eventually be published to the general public on the Medicare.gov Physician Compare website.  Sub-par or missing scores could have a negative financial impact on a practice.

Conclusion

These are only the most high-profile impacts to the healthcare industry during the current year. Much else flows from them: changes to workflow, to computer systems, to financial expectations. Tremendous pressures are coming to bear within a limited timeframe.  We’re seeing an industry in the midst of tectonic change, with 2014 as the fault line. It’s unclear whether these disruptions will be for better or worse. But there certainly will be winners and losers, and those who plan ahead are most likely to survive.

______________________

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.

March 26, 2014 I Written By

ICD-10 – Is Everyone Ready? – ICD-10 Tuesdays

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The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
Barry Haitoff
One of the biggest challenges to revenue a practice will face in 2014 is the move to ICD-10 on October 1, 2014. One of the biggest challenges with ICD-10 is that it impacts the entire healthcare ecosystem. This means that revenue flow could be impacted if any one part of the healthcare billing continuum isn’t ready.

The first key step every organization can take to prepare for the switch to ICD-10 is to do an audit of which systems, people, and processes will be impacted by the change. Second, you should evaluate the ICD-10 readiness of each system, people and process. Finally, you should make a plan for how you’ll ensure that each piece of the puzzle is ready for ICD-10.

Here’s a quick look at some of the places you’ll want to look when doing an audit of your ICD-10 readiness:
EHR Software
This is an obvious one. We all know that the EHR vendor needs to be ready for ICD-10. However, as John posted previously, Is Your EHR Ready for ICD-10, Not Just Say They’re Ready? it’s really easy for an EHR vendor to say they’ll be ready for ICD-10. At the core of being ready for ICD-10 is just being able to use a new code. Every EHR vendor will be able to enter the new code. Instead of asking if they are ready for ICD-10, you should ask your EHR vendor what interface they’ve created for you to be able to find the ICD-10 codes. You’ll want to get in and test this new interface for finding codes well before the ICD-10 deadline so they can make any changes to the software.

Providers
Every doctor I know understands they they’re going to have to be ready for ICD-10. They’ve heard about the expanded set of codes and how finding the right code is likely going to take extra time. What many doctors haven’t realized yet is that with increased coding specificity, the doctor’s documentation is going to have to change as well. Coding 101 is that the coding has to match the documentation. This will require every doctor to change the way they document their visit even if it’s only a small change.

Billing Software
This is another obvious one and many of the lessons mentioned above about EHR software apply to billing software. However, you’ll definitely want to make sure that your billing software is ready for ICD-10. Can you imagine the impact to your organization if they’re not ready? You might not think this is possible, but I’ve heard some billing software already announce that they’re not planning to revise their software for ICD-10.

Billers and Coders
This is the group that seems most prepared for ICD-10. Most people realize that the coders or billers in their organization need to be ready for ICD-10. Unfortunately for many organizations, that’s where they think all the ICD-10 preparation needs to happen. As this list shows, they are so wrong. However, if you haven’t invested in getting your billers and coders ready for ICD-10, then you better start doing so now. In some cases you may have an older coder that chooses to retire instead of learning ICD-10. Make sure you learn if this is the case now instead of October 1st.

Billing Company
It’s really hard to imagine a billing company not being ready for ICD-10. It’s a basic fundamental of them being a business. If they can’t do ICD-10 they’ll be out of business. However, it makes sense for you to check with them to see what they’ve done to prepare for ICD-10. You’re their customer and it never hurts to hold them accountable. If they don’t thank you up front, they’ll thank you on October 1st when they’re ready for the change.

Labs and Radiology
You’d think that these wouldn’t be that big of an issue since we’re just talking about a new code that gets sent to the lab or radiology. However, if they’re not expecting ICD-10 codes, your patients could run into issues. Plus, many of you have interfaces which send this information automatically. You’ll want to make sure that these interfaces can handle the new codes as well.

Payors
This is probably the most important one and also one of the most challenging. It is the most important, because if they’re not ready for ICD-10 that could mean that you stop getting paid. In many organizations, a hit to their cash flow could have serious ramifications. My guess is that some of you don’t think that this could ever really happen. I assure you that it could happen. Certainly they’ll eventually fix whatever issues they have and they’ll get rolling with ICD-10. Although, will it take them a week, a month, a couple months, to fix whatever issues they may be experiencing? Can you handle not getting paid for a week, month, or multiple months? The challenge is that there’s no simple way for you to know if the payors are indeed ready for ICD-10. The best advice I can offer is a famous statement, “The squeaky wheel gets greased.” Don’t be afraid to make some noise to make sure they’re ready.

Hospitals and HIE
Many vendors are starting to build interfaces with their hospital or an outside HIE (Health Information Exchange). If you have one of these interfaces, you’ll want to make sure that it can support the new ICD-10 codes. Don’t forget to check and test both sides of the interface for their ICD-10 readiness.

Other ICD-10 Readiness Advice
When assessing the readiness of the various entities listed above (and you will likely have others), it’s important that you ask the right questions to make sure you get the right answers. Much like when you’re evaluating between EHR vendors, you want to avoid asking Yes/No questions. For example, if you ask your EHR vendor, “Are you ready for ICD-10?” then you will quickly get a response of Yes. If instead you ask, “What have you done to get ready for ICD-10?” you will get a much more informative answer that helps you understand their true ICD-10 readiness.

Also, when doing your assessment of their readiness, don’t forget to also verify that they can handle ICD-9 for those situations where an organization still hasn’t moved to ICD-10. Yes, it’s crazy that some government organizations aren’t moving to ICD-10. However, it’s the stark reality, so make sure that when needed to you can still support ICD-9 as well.

In all of this, there’s a challenging balance between doing your training too early or too late. If you train your doctors on ICD-10 too early, then they’re likely to forget it by the time October 1st rolls around. However, if you wait until the ICD-10 deadline approaches, the resources for ICD-10 won’t be available. Can you imagine what it will be like to try and hire an ICD-10 coder or ICD-10 trainer in September?

Medical Management Corporation of America, a leading provider of medical billing services, is a proud sponsor of EMR and HIPAA.

March 25, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Eyes Wide Shut: Meaningful Use Stage 2 Incentive Program Hardships

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

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

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

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

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

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

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

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

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

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

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

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

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

March 5, 2014 I Written By

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

PQRS Incentives, Penalties and the Coming Value Based Payment Modifier

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The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
Barry Haitoff
Much of the focus of healthcare has been on meaningful use and the EHR incentive money. Considering we just reached $19 billion of payouts, it’s definitely a topic worthy of attention. However, a topic which hasn’t gotten nearly as much attention, but is nearly or possibly more important than meaningful use is PQRS and the Value Based Payment Modifier.

Before I dig into some of the details and timelines for PQRS and the Value Based Payment Modifier, it’s really important to note that both of these programs are really just a preview of what’s happening with Medicare reimbursement. These programs are the core of the shift towards paying physicians differentially based on the quality and cost of the care they provide and away from the traditional fee for service model. We’ve seen similar value based payment arrangements with the advent of ACOs, CINs and other clinical networks establishing innovative payment models with payers. Understanding where these programs are going will give you a preview of what’s happening with healthcare reimbursement.

PQRS
When it comes to PQRS, much like meaningful use, there is both a PQRS incentive and PQRS penalty (carrot and stick if you prefer). 2014 is the final year to receive the PQRS incentive money (0.5% of Medicare Part B claims) and participants must submit 12 months of 2013 CQM data by February 28, 2014 if reporting by claims data, March 21, 2014 if reporting by GPRO web interface, and March 31, 2014 if reporting by registry data. (Note: The 2013 MU reporting deadline was moved to March 31, 2014, but the PQRS deadlines have not changed.). However, more important is that providers who don’t report PQRS 2013 data will be penalized 1.5% in 2015. Those who don’t participate in PQRS in 2014 will be penalized 2% in 2016.

Value Based Payment Modifier
While most people have heard about PQRS and are hopefully participating to avoid the penalties, many people haven’t heard about the Value Based Payment Modifier that is built on the PQRS foundation. While you could look at the Value Based Payment Modifier final rule, this Value-Based Payment Modifier summary is a much better overview of the program.

Essentially, the Affordable Care Act (ACA) required that CMS implement a value based payment modifier that would apply to Medicare fee for service payments. This program will start with physicians in groups of 100 or more eligible professionals under the same TIN beginning January 1, 2015, and apply to all physicians and groups by January 1, 2017. CMS also recently announced that this applies to both par and non-par Medicare providers with 100 or more eligible professionals.

Here’s a look at how this new Value Modifier will work for groups of physicians with 100 or more eligible professionals and will likely be a preview of what’s to come for all Medicare physicians:
CMS Value Modifier

While the program starts with relatively small 1% adjustments, this quote from CMS also provides a clear indication of where they want to take this program:

We also anticipate that we would propose to increase the amount of payment at risk for the Value Modifier as we gain additional experience with the methodologies used to assess the quality of care, and the cost of care, furnished by physicians and groups of physicians.

What should you do to be prepared for this new Value Based Payment Modifier?
1. Participate in the PQRS program since it’s the foundation of what’s to come.
2. Keep an eye on changes to the PQRS and Value Based Modifier programs. They are changing regularly and it’s worth knowing what’s changing with these programs.
3. Work with your professional organization to provide feedback on these programs. No doubt they’re keeping an eye on them and providing feedback as part of the government rule making process. Make sure your voice is heard.

CMS looks at this new value based modifier as a budget neutral program. That means that there are going to be winners and losers. By understanding how these programs work, you can better assess if you want to work to avoid the payment adjustments or if you’re ok taking them on.

Like it or not, PQRS is the start of the movement towards quality based reimbursement and likely a small preview of coming attractions. Of course, if the SGR Fix gets funded by congress, then PQRS, Meaningful Use and the Value Based Modifier will be sunset at the end of 2017 and rolled into a new Merit-Based Incentive Payment System (MIPS) that will start in 2018. More on MIPS in the future, but I think we can safely say that MIPS will be an amalgamation of all these incentive programs.

Medical Management Corporation of America, a leading provider of medical billing services, is a proud sponsor of EMR and HIPAA.

February 20, 2014 I Written By

Meaningful Use Playbook 2014: Overcoming Adversity – Breakaway Thinking

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The following is a guest blog post by Carrie Yasemin Paykoc, Senior Instructional Designer at The Breakaway Group (A Xerox Company). Check out all of the blog posts in the Breakaway Thinking series.
broncos
I apologize in advance, but I am still mourning the Super Bowl loss of the Denver Broncos. I can’t stop replaying each moment and thinking of alternative scenarios. What if Peyton Manning utilized a quick huddle instead of audibles and hand-signals? What if Denver’s defense had better protected Peyton? What if the Broncos had scored more than eight points?

Regardless of the what-ifs and wounds resulting from the loss, the team has to step up and prepare for the next season, if they want to finish at the top. In the healthcare world, providers must also change their playbook and approach, if they wish to capitalize on the next phase of Meaningful Use.

For the past year, providers have been scrambling to select, implement or optimize a new electronic health record system to meet federal requirements for Meaningful Use Stage 1. Adding to providers’ challenges is the evolving nature of the rules for achieving meaningful use incentives; federal agency Centers for Medicare and Medicaid Services (CMS) is constantly updating the Meaningful Use Playbook. Similar to football players at the end of the season, providers are tired and wounded. However, they must be aware of and prepare to take on the new requirements for 2014. Otherwise, they risk future penalties and foregoing funds. To help healthcare providers prepare for this new season, here is a summary of changes taking effect this year.

  • Three-month reporting period
    All providers are now required, regardless of their stage of meaningful use, to demonstrate meaningful use for a three-month EHR reporting period. Medicare providers may elect to report clinical quality measures (CQM) for the entire year or select an optional, three-month reporting period for CQMs that is identical to their meaningful use reporting.
  • Exclusions and vital sign objectives
    All eligible professionals, eligible hospitals and critical access hospitals are now responsible for adhering to the latest changes in Meaningful Use Stage 1. This includes new requirements for electing exclusions toward menu objectives, age limits for recording and charting changes to vital signs, and new exclusions toward reporting height, weight and blood pressure.
  • View, download and transmit all health information or admissions online
    To better align with the new capabilities of certified EHR technology, CMS is replacing Meaningful Use Stage 1 objectives for accessing information online with the capacity to view, download and transmit this information.
  • Reporting of clinical quality measures
    All providers, regardless of their stage of meaningful use, must report on clinical quality measures to CMS. Eligible hospitals must report 16 of the 29 CQMs and eligible providers must report 9 of the 64 CQMs.(Source)

For providers making the leap to Stage 2 of meaningful use, this is only the beginning. Not only must they abide to the changes mentioned above, but they also need to plan and execute a strategy for integrating diverse IT systems and engaging patients. Neither are simple tasks. However, just as I believe that Peyton can shake this last performance and finish strong next year, I believe in the resiliency of providers too. With the right leadership and planning, they will take patient care to the next level.

Omaha! Omaha! Omaha!
Carrie Yasemin Paykoc
Xerox is a sponsor of the Breakaway Thinking series of blog posts.

February 19, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Did Meaningful Use Try to Do Too Much?

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When I was reading Michael Brozino’s post on EMR and EHR about the Value of Meaningful Use, I was hooked in by his comment that meaningful use standards only went halfway. I’m not sure if this was the intent of his comment, but I couldn’t help but sick back and consider if meaningful use missed the mark because it only went half way.

When I think about all of the various features of meaningful use, it really feels to me like ONC and CMS tried to bite off more than they could chew. They tried to be all things to everyone and they ended up being nothing to no one. Ok, that’s not perfectly correct, but is likely pretty close.

Think about all of the meaningful use measures. Which ones go deep enough to really have a deep and lasting impact on healthcare? By having so many measures, they had to water them all down so it wasn’t too much for an organization to adopt. I’m afraid these watered down measures and standards render meaningful use generally meaningless.

Certainly the EHR incentive money has stimulated EHR adoption. However, could this EHR adoption have had even more impact if it would have just focused on two or three major areas instead of dozens of measures with good intentions but little impact?

In many ways, this is just a variation on my wish that EHR incentive money would have focused on EHR interoeprability. As meaningful use stands today, we’ve made steps towards interoperability, but we’re still not there. Could we have achieved interoperability of health records if it had been our sole focus? Instead, we’re collecting smoking status and vital signs which get stored in an EHR and never used by anyone outside of that EHR (and some would argue rarely inside of the EHR).

The good news is we could remedy this situation. ONC and CMS have something called meaningful use stage 3. How amazing would it be if they essentially through out the previous stages and built MU stage 3 on 2-3 major goals? The foundation is there for MU stage 3 to have an enormous impact for good on healthcare, but I don’t think it will have that impact if we keep down the path we’re currently on.

Yes, I realize that a change like this won’t be easy. Yes, I realize that this means that someone’s pet project (or should I say pet measure) is going to get cut. However, wouldn’t we rather have 2-3 really powerful, healthcare changing things implemented than 24 measures that have no little lasting impact? I know I would.

Side Note: Think how we could simplify EHR Certification if there were only 2-3 measures.

February 12, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Meaningful Use Audits and Appeals

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Meaningful Use Expert, Jim Tate, has a really interesting post up on his Meaningful Use Audits website that shares some of the details CMS offered on the EHR incentive audits and appeals process. I know many of my readers are worried about the meaningful use audits and are interested in these details.

You can go and read Jim’s full post for all the details, but I wanted to highlight a few of the items he mentions.

First, CMS said that 5-10% of providers will be subject to pre/post-payment EHR incentive audits. Jim calls this casting a “wide net” for the MU audits. Considering meaningful use stage 1, it makes some sense why the MU audit net would be cast wide. I’m sure many who read this have a friend who’s been through the audit.

I was really intrigued that CMS said “If a provider continues to exhibit suspicious/anomalous data, could be subject to successive audits.” This reminded me of something my brother said about the military. He said that if you got your uniform inspection right the first couple times, then the officers would stop looking at you quite as much. However, if you had something wrong at first, be ready to be scrutinized. It seems like CMS is taking a similar approach. As in most things in life, it’s just better to be honest and accurate. Then, you don’t have to look over your shoulder.

Jim also notes that CMS said that no risk profile will be made public. Basically, we aren’t going to get any clue into how they chose who to audit. Plus, Jim notes that the only next step if you fail an meaningful use audit is to file an appeal.

As long as we have meaningful use tied to EHR incentive money and payment adjustments, I don’t see these MU audits going anywhere. So, if you’re attesting to meaningful use, make sure you’re prepared for an MU audit if it comes.

February 11, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Will Your EHR Vendor Be Around in 5 Years?

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The following is a guest post by Angela Carter, marketing manager at ChartLogic.
Angela Carter
A major concern physicians have dealt with over the past 10–15 years has been choosing the right EHR solution for their practice. With the rise and fall of numerous electronic health record companies, that concern has evolved to whether a chosen EHR will still be in business five years from now.

According to the Centers for Medicare and Medicaid Services (CMS), there are over 900 EHR vendors currently on the market, many of whom offer more than one product. In some ways, the huge number of EHR choices has been a good thing for healthcare; it has forced vendors to be more innovative and to cater to the needs of their users. However, the market can’t possibly sustain this many similar projects for long. Eventually, small vendors will be swallowed up by larger vendors and many others will simply go out of business.

So how do you know if your EHR vendor will survive the EHR purge that has already started? Of course there is no way of knowing for sure, but below are a few questions you can ask yourself that will give you a good idea of your EHR’s future.

1. How long has the vendor been in business?

Past performance is usually a good measuring stick for the future. Hundreds of vendors were born after the HITECH Act was passed in 2009, which means that most EHR vendors are still relatively new. Newer EHR companies aren’t necessarily a bad thing—some of them are actually better than some of the legacy systems that have been around for decades—but be wary of any company that doesn’t have the years in business to back it up. A vendor that has already proven it has weathered the EHR storms for 10–15 years will be much more likely to survive current and future challenges than the new, promising EHRs.

Don’t just look at how long the vendor has been in business, though. Research the vendor’s track record as well. If your vendor has a high retention rate—90 percent or higher—then you’re in good company.

2. How usable is the EHR?

For years, doctors put up with EHRs that didn’t meld with their workflow, but that tolerance is coming to an end. Black Book Rankings called 2013 “The Year of the Great EHR Switch” because most EHR implementations happened in practices that were on their second or third EHR. The reason for this shift? Usability. Eighty-seven percent of doctors cited usability as their primary complaint about EHRs. (Source: http://www.prweb.com/releases/2013/7/prweb10926499.htm)

For some reason it took many years for usability of EHR systems to catch on, but now that it has, the difficult-to-use systems will have a difficult time holding on to customers. Point-and-click EHRs have never been popular among physicians, especially those who see 50+ patients a day. EHRs that utilize voice technology, though, are growing in popularity. It is highly unlikely that any EHR system will cater 100 percent to a physician’s needs and preferences, but voice offers much more flexibility than traditional point-and-click systems do, not to mention voice-driven systems are more likely to follow the workflow physicians already use.

3. How well does your vendor understand your specialty?

The reason the industry hasn’t settled on just a couple of vendors by now is because workflow among different specialties varies so widely. Physicians need vendors that are very good at their specialty, not those that claim to answer to the needs of all physicians. A vendor that dedicates itself to producing and improving capabilities that align with your specific needs will take much better care of you. Not only that, but they will be more able to evolve with you as technological demands change, giving the company more stability in a shaky market.

4. How’s the support?

Never underestimate the power of a good support team. Most EHRs aren’t designed to work flawlessly fresh out of the box; you need adequate training and ongoing support, too. A recent Software Advice survey revealed that about 60 percent of respondents reported “learning to use the system” as a one of the main challenges with their EHR, even more challenging than achieving meaningful use or finding costs to support the system. (source: http://www.softwareadvice.com/medical/userview/ehr-survey/)

As a business metric, support may be even more powerful than usability, especially since federal regulations keep tightening, limiting the freedom to change certain aspects of an EHR. A vendor that communicates with its customers regularly will stand out.

5. Is the vendor ready for meaningful use stage 2? ICD-10?

Over a thousand vendors certified for meaningful use the first time around. Less than 40 of those vendors have received complete ambulatory certification required for 2014. Add ICD-10 to the mix and very few vendors will be able to keep up with these increasingly difficult technological advancements. Vendors that don’t have a plan already in place regarding how they will re-certify for meaningful use and be ICD-10 compliant will be among the first to go.

A vendor that scores well in each of the five questions above will most likely have what it takes to make it through the next five years.

Angela Carter is a marketing manager at ChartLogic, an EHR for orthopedists, ENT doctors, and other specialists. In addition to managing all of the company’s content, she writes regular blog posts for various health IT sites. She is also the associate editor for Utah Technology Magazine, a start-up magazine that aims to tell the tech story happening in Utah.

January 10, 2014 I Written By

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

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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

December 6, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.