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Meaningful Use Stage 3 Timeline – Meaningful Use Monday

Posted on November 19, 2012 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The big meaningful use news this week was the release of the meaningful use stage 3 recommendations (PDF) that the meaningful use workgroup released to the public. Some on Twitter thought that this was the meaningful use stage 3 rule that could be commented on. This is not open for public comment yet, but should be soon.

In fact, Healthcare IT News listed the following timeline for meaningful use stage 3:

  • Dec. 21, 2012 – RFC deadline
  • January 2013 – ONC to synthesize the RFC comments for HIT Policy committee workgroups to review
  • February 2013 – The workgroups will reconcile RFC comments
  • March 2013 – The workgroups will present a revised draft of Stage 3 requirements to ONC
  • April 2013 – ONC is expected to approve final Stage 3 recommendations
  • May 2013 – ONC will transmit final Stage 3 recommendations to HHS

That’s a pretty aggressive timeline to have meaningful use stage 3 published by May 2013. If my dates are right, meaningful use stage 3 won’t be effective until 2016. I like that ONC wants to get the MU stage 3 out soon so that no one can use not having the meaningful use details as an excuse for not complying. However, I also don’t think ONC should rush the process either. We have to live with meaningful use, good and bad, for a long time to come.

I’d love to hear what you notice in the meaningful use stage 3 proposal (PDF). We’ll be sure to cover it a lot more in the future.

Some of the Thinking Behind Meaningful Use Stage 2 – Meaningful Use Monday

Posted on August 29, 2011 I Written By

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

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

A great deal of work, discussion, and debate by the HIT Policy Committee and its Workgroup members went into developing the recommendations for meaningful use Stage 2 (discussed in the last two Meaningful Use Monday posts). Meetings were frequent and lengthy, but I tried to listen in on most of them to gain some insights into the thinking behind the decisions being made and the future direction of meaningful use. 

Committee members struggled with striking the right balance between aggressively pressuring providers so that adoption would be accelerated, on the one hand, and maintaining a realistic and practical view of their capabilities, on the other. Some committee members were adamant about staying on track to reach the Stage 3 end goals within the predetermined 2015 time frame, (i.e. remaining on the escalator, as the progression is often referred to), while others recognized that overburdening providers could lead to program failure, i.e., discouraging adoption by imposing unreasonable expectations that would cause providers to doubt their ability to earn the incentives and abandon the effort altogether. The debate led to an open question: does everything have to be accomplished under the umbrella of meaningful use?

 An issue that I think could have used more discussion is how to make meaningful use relevant for specialists—a subject raised frequently by Committee member Gayle Harrell. There was general agreement about the importance of having all types of physicians participate in the incentive program, and testimony from a variety of specialists was solicited. Other than suggesting a large number of new clinical quality measures, however, the basic recommendations are still predominantly primary-care focused. 

Lastly, there was a prevailing sense of frustration over the fact that the calendar did not allow time for an analysis of the experience of Stage 1 before requiring the definition of Stage 2.

More on Stage 2: Clinical Quality Measure Reporting – Meaningful Use Monday

Posted on August 22, 2011 I Written By

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

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

In addition to the Meaningful Use Stage 2 recommendations discussed in last week’s Meaningful Use Monday, the HIT Policy Committee proposed a new framework for the reporting of clinical quality measures that was designed by its specifically-tasked Quality Measure Workgroup. The recommended concept is depicted in the graphic below—the intention is to broaden the scope of reporting to address a wider spectrum of factors affecting care and to accommodate all types of physicians.

Providers would report on some number of the core measures, (between 5 and all 8 or 9 is the recommendation), and at least one measure from each of the 6 menu “domains”. The core quality measure set would include all of the core and alternate core measures from Stage 1 and an additional 2 measures related to care coordination. Interestingly, there was no mention of establishing required thresholds to be met on any of the quality measures.

The intention is that all physicians (including specialists) will find measures relevant to their specialty in the core set as well as in each of the domains. This seems like a tall order from a practical perspective, given the primary-care focus of the Stage 1 quality measures, (particularly true of the core, but also the additional measures.) To accomplish this, the workgroup submitted quite a lengthy “library” of measures to CMS for its consideration—some measures are carried forward from Stage 1, others are recently retooled, and many are still “to be developed”.

We’ll be watching intently to see what CMS does with clinical quality measures, since this is such a fundamental part of meaningful use.

What’s in Store for Meaningful Use Stage 2? – Meaningful Use Monday

Posted on August 15, 2011 I Written By

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

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

A few weeks ago, the HIT Policy Committee forwarded its Stage 2 meaningful use recommendations to CMS. CMS is expected to issue a Proposed Rule in early 2012 and the Final Rule in mid-2012. 

The first recommendation—intensely debated, but overwhelmingly supported in the end—is to delay the start of Stage 2 until 2014, recognizing the unrealistic time pressure that vendors and providers would face if required to upgrade, implement, and train for the new set of requirements by 2013. 

Most of the proposed changes to the measures themselves are not dramatic in scope. Some measures did not change at all, (e.g., problem list, medication list, etc.) Others, (e.g., ePrescribing, smoking status), would have higher thresholds to meet—not a major obstacle if the higher-than-required performance trend reported among early attesters continues—and some would have a slightly broader scope, (e.g., CPOE would include radiology). 

All menu measures would become core measures, which means that they would be required of all providers. If CMS adopts this recommendation, it will be important to identify exclusion criteria to accommodate physicians for whom particular measures may not be relevant, as they did for specific core measures in Stage 1. 

The changes that are more controversial are those that hold physicians responsible for factors beyond their control, such as requiring that a given percent of patients actually view their electronic health information (Stage 1 only requires that the information be made available), or requiring that a given number of patients send a secure message to the physician/practice. Also interesting is that some of the new measures recommended for Stage 2 are measures that were specifically removed by CMS during the Stage 1 rule-making process, such as advance directives and progress notes.

If you are interested in the specifics associated with the recommendations summarized above, Computer Sciences Corporation’s Update on Stage 2 (PDF) presents a nice review.

Early Attestation Results: Some Observations – Meaningful Use Monday

Posted on August 8, 2011 I Written By

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

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

At last week’s HIT Policy Committee meeting, Robert Tagalicod, (the new director of the Office of E-Health Standards & Services), presented an analysis of the attestation experience to-date [See John's previous Meaningful Use Details post for the slides and report]. The results lend themselves to some interesting observations—admittedly preliminary findings, but revealing nonetheless: 

  • The average performance levels were quite high—on those measures that have thresholds to be met, providers attested to results considerably above the level required for successful accomplishment. This is a positive sign that once providers commit to an EHR and to meaningful use, they try to use the EHR on a routine basis, not just to satisfy the minimum requirements. True, these initial attesters represent early EHR adopters who have had time to become successful EHR users, but hopefully this trend will be sustained.
  • Care coordination measures seem to present a challenge for many providers—the most commonly deferred (i.e., not selected) menu measures were medication reconciliation and summary of care at transitions.
  • Very few providers were actually able to conduct a test of their ability to electronically submit syndromic surveillance information to public health agencies or submit immunization data to registries (5% and 28% of attesters, respectively). Not surprisingly, most EPs either excluded or deferred these public health measures

Of the 2,383 EPs that attested, 137 were unsuccessful. I’d be interested to know where they stumbled and if they will succeed in another reporting period.

Preliminary Meaningful Use Details Out

Posted on August 5, 2011 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Brian Ahier has a great post up that had the presentation and report (embedded below) that CMS provided to the HIT Policy Committee. It has a lot of great information worth talking about. I’m going to embed the presentation and report below and pull out some of the key points in a post later. Let me know what catches your eye.

The CMS Meaningful Use Presentation

The CMS Meaningful Use Report

Meaningful Use Measures: Electronic Copy of Health Information – Meaningful Use Monday

Posted on July 11, 2011 I Written By

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

Meaningful Use Core Measure: More than 50% of all patients who request an electronic copy of their health information are provided it within 3 business days.

Exclusion: Any EP who receives no requests for this information in electronic format.

 This measure is distinguished from  the clinical summary measure, (discussed in the previous Meaningful Use Monday post), in two major ways:

1)      “Electronic copy of health information” covers all health information that the provider has regarding the patient, whereas the “clinical summary” is a snapshot of a particular visit.

2)      This measure is driven by requests made by patients or their agents—electronic access must be provided in response to at least 50% of the specific requests received by a provider. By contrast, clinical summaries have to be provided for 50% of office visits, regardless of whether or not the patient asked to receive the information. 

The measure is limited to the information that is contained electronically in the EHR, and it can be delivered in any electronic format, including patient portal, CD, USB fob, etc. 

An interesting note about the future of this measure: The Meaningful Use Workgroup has recommended to the HIT Policy Committee that this measure be dropped in Stage 2 because it is incorporated into other objectives. There is already a menu measure in Stage 1 that requires providing “timely electronic access to health information.”

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

ONC Blog – Federal Advisory Committee – Judy Sparrow

Posted on October 29, 2009 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

All I can say is that it’s very cool that ONC now has a blog. This is probably right up there with when I found past HHS secretary Mike Leavitt’s blog. Ok, yes I am a complete blog nerd. At least I’m able to admit it up front.

Basically, Judy Sparrow has just done an introduction post where she talks about the Federal Advisory Committees and their role at ONC. She’s the ONC liason for these committees and so hopefully she’ll keep us updated on progress with these two very important committees. She also provides this explanation about the committees in her first ONC blog post:

“FACAs” get their name from the Federal Advisory Committee Act, which lays out the guidelines for such committees. FACAs are advisory and intended to provide external guidance to the government. Typically members of the group are not federal employees. They are also very open committees – meetings are held in public, information on the meetings is posted in the Federal Register, and all FACA records are readily available. At the very root of the FACA mandate is transparency and collaboration.

ONC has two FACAs – the HIT Policy Committee and the HIT Standards Committee. These committees were established to obtain outside advice or recommendations on key health information technology topics from leaders who represent various stakeholder groups.

I think we generally knew this, but it was nice to have a bit more background. This would have been really useful 6 or so months ago when these committees were a new thing (at least for me).

I hope that Judy is able to keep the blog up to date and that it won’t just turn into an announcement site. I hope Judy will provide real content about the process, timelines and perspectives of ONC. If she does that, then it will be really interesting and a great part of the EMR conversation which is already happening on blogs like this one.

HIT Policy Committee Meeting on Certified EHR

Posted on September 11, 2009 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ve been meaning to post about the HIT Policy Committee meeting for a month or so now. The reason I didn’t is that when I post about things like this, I like to make sure that I’ve had a chance to digest the information and provide some thoughtful analysis and commentary on what’s happening. Of course, thoughtful analysis and commentary takes a lot more work and time and so thus the delay. Enough about me…

Yes, on August 14th the HIT Policy Committee met to mostly talk about what certified EHR will mean under ARRA. You can see the full powerpoint from the presentation here. Luckily, CCHIT (I guess they have an interest in the topic) wrote a pretty good summary of what was said about EHR certification at the meeting (with a few of my own modifications):

  • There will be a new form of certification. The Policy Committee recommended the term HHS Certified. (The labeling could change if there are issues.)
  • The criteria for HHS Certification are recommended by the Standards Committee to ONC, then submitted for a formal approval process at HHS. As an experienced certifying body, CCHIT is offering suggestions and advice during the comment process, just as other stakeholders are.
  • The Policy Committee recommended that ONC work with NIST to develop an accreditation process for certifying bodies and not place a formal limit on the number of entities that can be accredited.
  • The Committee recognized the importance of leveraging work to date and maintaining momentum. For the near future—until the accreditation process is developed and operational — the Policy Committee recommended that CCHIT certification should be leveraged and that granting Preliminary HHS Certified status for EHR technologies should be done so as not to slow EHR adoption as the final HHS Certification criteria is approved.
  • The Policy Committee recommended that HHS Certification be offered to modular products and that there be flexible approaches for non-vendor software.
  • The Policy Committee recommended that HHS certification requirements focus on meaningful use.

While I still think that CCHIT has been marginalized to some extent, there’s no doubt that this meeting brought CCHIT and their criteria back into the fold to some degree. What will be interesting is to watch how much of the CCHIT certification criteria is accepted and used by HHS in developing the HHS EHR Certification.

In response to this, CCHIT sent the following materials (zip file) to HHS. I believe the excel file included in that zip file will turn out to be a crucial document in HHS’s development of the HHS EHR certification. I expect they’ll make some changes (it’s government after all), but I also expect it will form the basis of the HHS certification to at least some extent. I’m planning to do a full analysis of the document in a future blog post.

The question is when will we know what HHS has determined as an HHS Certified EHR and which bodies will become the certifying bodies for that HHS Certification? Here’s the timeline as best I can make of it:

  • ONC Interim Final Rule by 12/31/09 – 60 day public comment period might not be required for EHR Certification. Don’t ask my why they wouldn’t do it since they’re doing it for meaningful use.
  • Spring 2010? – ONC/NIST Definition of new accreditation Process for certifying bodies
  • Fall 2010? – Completed accreditation of EHR certification bodies

The x factor in the schedule is how HHS plans to deal with preliminary ARRA certification. The HIT Policy committee recommended that HHS do a preliminary certification so that certification bodies wouldn’t have to wait to get started on EHR certification. CCHIT is moving forward full bore on doing preliminary ARRA certification. Maybe I don’t understand the process completely, but I haven’t seen where HHS/ONC has acknowledge that they’re going to go forward with this recommendation from the HIT Policy Committee. If they do, then we’ll start seeing some preliminary EHR certifications this year. If they don’t it looks like we’ll be waiting until next Fall to know for sure.

For those that attended the meeting, was there anything else important that I missed?

Marc Probst Talks About Meaningful Use

Posted on August 1, 2009 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

A relatively new reader of EMR and HIPAA, Michael Archuleta, sent me his notes from the Utah Medical Group Managers Association 6/25/09 where the keynote speaker was Marc Probst. For those that don’t know, Marc Probst is the CIO of Intermountain Healthcare (IHC). IHC is huge in Utah and I think it does pretty well in a number of surrounding states as well. Plus, Marc Probst is also a member of the HIT Policy Committee. You may remember that I’ve talked about Marc Probst on EMR and HIPAA a few times before.

Anyway, I found some of the points that Michael captured interesting. I guess in the end I was interested to hear what Marc Probst was telling people. Michael Archuleta’s notes are as follows (published with permission and the emphasis added was mine to highlight some interesting parts):

Mark Probst – Intermountain Health Care – government wants to invest 42 billion in IT healthcare. IHC has 500,000 enrollees, 28,000 employees. 600 physicians. They are a unique integrated health care organization. Feels Obama framed the problem (related to health care, in previous nights TV pitch) well, and wants his plan in by Oct 09. Referred to how IHC is the lowest cost per capita.

Probst has met with 3 congressman and 20 government staffers. Using Mayo Clinic as a benchmark, could save 30 pct in chronic illnesses. There are 300,000 uninsured Utahns.

Four stages of an EMR. Third stage was commercial products. Stage four will have broad adoption of solutions. Second increased knowledge. Third is introduction of clinical decision support. A stage 3 EMR could save a 300 bed hosp at least 11M.

At LDS hospital there were 581 adverse drug events in 1990 and in 2004 there are only 270 . Their stats showed that waiting to 39 weeks (for OB delivery) was best for infants and reduced neonatal admissions. The docs said they knew this already and didn’t induce unnecessarily. But when showing them the data, they were in fact inducing. The same stats showed improved outcome with acute respiratory stress.

150 people are working on a new EMR system (for IHC) with GE and people from India. A complete clinical information system has automation (taking common tasks and automating it like voice, scanning, bar codes. Helps you with inventory management and pricing. Provides automated data entry with hot texting.), connectivity (using a network. Allows doctors to see and share information and this brings more specialists into the picture.), decision support (prompts and alerts for obvious things. Advanced decision support like glucose management and need to push the human mind.), data mining (using historical data to identify patterns and to test hypotheses).

Commercial systems were good at automation and connectivity but were weak on decision support. IHC was good in that area so they decided to build their own hybrid.

Rather than rip and replace, they aggregate, view, analyze, alert and then gradually replace existing systems.

The government HIT policy committee: Meaningful use says that to get money you need a certified system and have meaningful use. There must be a certification and an adoption. Must have the ability to do health information exchange. Time frames are aggressive: They originally thought they had until October to define requirements and then were told by the Obama administration that it was moved up to July 16. It will move from policy to a standards committee.

The intent and commitment of the people involved on the HIT committee is to do the right thing.

Questions from the floor: Doesn’t HIPAA preclude the ability to share information? In his opinion it allows for protection.

How do we get our voices heard? Have to get involved with AMA.

What is meaningful use? Capture discreet data like BMI, weight. Then there is an adoption process.

How will costs go down? If other things are in place, then we will minimize duplications. We may be connected but we can’t talk.

What about CCHIT? It is unclear what their role will be. IHC, for instance, is a hybrid of best of systems. Who would certify us?