A couple quick tweets to welcome your new week. Both tweets stand on their own and link to some good reads for those interested in the topics. The second one is particularly good since it’s John Halamka’s 2011 wrap up across all the various parts of John Halamka’s life. Let me know what you think of both reads.

Very good guidance on accounting and reporting for #EHR incentive payments bit.ly/xuX9Un

— Brian Ahier (@ahier) January 7, 2012

Healthcare CIO on 2011: #EHRs…added features for certification resulting in…lack of #usability & #workflow integration ehr.bz/lv

— Charles Webster, MD (@c_wb) January 2, 2012

The following is part of an email interaction I had with an EHR vendor about the future of CCD. Of course, I can never let strong opinions go unpublished. So I asked if I could put this on my site. I have a feeling there will be many people who have a different view of CCD and how these standards will play out. I’d certainly be happy to publish an opposing view as well. My contact page is here. I’m interested to hear other view points on the subject.

Stage 1 MU allowed either CCR or CCD. Stage 2, and the short term efforts will require CCD. The jury is still out on what Stage 3 of MU will focus upon. Many at the ONC can see that the CCD will never have the flexibility to deliver. These are largely the same people that facilitated the Direct Project initiatives.

I still predict that it is inevitable that the data will become uncoupled from unwieldy, anachronistic document structures. That will be the only means to get to true information portability that can deliver patient-centric use of the information. The CCD will still be around for a while to come, just as CD’s are still around for music sharing. For now, we have to have the CCD to preserve legacy, industry-centric control of the information.

John Halamka has a couple of recent posts that do a good job of explaining what is evolving…. http://geekdoctor.blogspot.com/2011/09/september-hit-standards-committee.html and http://geekdoctor.blogspot.com/2011/10/cool-technology-of-week.html . Both of these contain links to some very interesting information. When the ONC proceeded to issue an advanced notice of rulemaking, the industry power elites became enraged. http://www.ihealthbeat.org/articles/2011/9/22/groups-urge-onc-not-to-include-metadata-standards-in-stage-2.aspx

Technology delivering to patients will eventually win out just as the open-platform WWW won out over proprietary CompuServe. http://www.healthdatamanagement.com/news/onc-metadata-ehr-meaningful-use-43021-1.html Once we have a means to truly exchange the content without the overhead associated with the CCD/RIM crap, we will see a revolution in healthcare similar to the social networking phenomenon.

Again, the whole CCD/CDA will stick around to support legacy information needs, but it will eventually be largely eclipsed by more straight-forward solutions that don’t require a team of consultants and IT engineers to implement.

Dan Neuwirth is the CEO of MedCPU, provider of the innovative MedCPUAdvisor™ platform: with applications for decision support for clinical guidelines, Meaningful Use, and care pathways, that captures the complete clinical picture in real time, including narrative text and structured data to deliver the most accurate clinical and compliance guidance.

There’s no question that healthcare needs to adopt new technology that makes us more effective and efficient and curbs costs, like Electronic Medical Records (EMR) solutions and Clinical Decision Support (CDS) systems. In today’s world, providers of all sizes continue to find it challenging to integrate existing HIT systems with EMRs for a variety of reasons. As our industry evolves, technology solutions need to be smarter and empower seamless integration.

EMR and HIPAA guest author Susan White covers in depth how a lack of connectivity standards affects EMR integration. There are no mandated standards for EMR vendors to follow, making it hard to coordinate data sharing between medical devices and other systems (including from one EMR to another), even at the same facility. As those systems operate in disparate fashions, critical clinical information is often lost or stuck in silos. Most importantly, the information is not where clinicians need it most–at their fingertips, in an exam room, with a patient.

This lack of data sharing is a pervasive concern. One Markle report finds that roughly 80 percent of both consumers and physicians demand that hospitals and doctors be required to share information that improves coordination of care, cuts unnecessary costs, and reduces medical errors.

In 2010, more than $88 Billion were spent on developing and implementing EHRs, health information exchanges (HIEs) and other health IT initiatives. When you consider that the average 10-physician practice spends more than $137,000 per year on prior authorizations and pharmacy callbacks alone, you’ll have to agree that the lack of data integration and sharing get very costly. And although I agree with John Halamka, who recently wrote these challenges exist because healthcare is inherently more complicated than other industries, I am a strong believer that a lot of them can be overcome by the use of smart technology.

We need smart, flexible solutions, which capitalize on existing technologies and require minimal integration. Technologies that employ advanced screen extraction, for example, empower several important improvements in the clinical decision support space such as the capturing and analysis of both free and structured text. A lot of time such solutions are rendered ineffective as they either lack compatibility with leading EMR systems or are too hard to integrate.

As the industry evolves, developing robust protocols for capturing both structured and unstructured data along with standards for data integration and sharing will become increasingly important. With all the data points created on patients every day, we will need a consistent, secure, and reliable way to capture and share patient data among all systems and healthcare providers. What is your experience? What are top data capturing and integration challenges faced by your organization? Looking forward to continuing the dialog and hearing your feedback.

I’ve been wanting to write about ePrescribing controlled substances since 9/13/09. In fact, I even did write post about the FDA approving a pilot to do electronic prescribing of controlled substances which I posted on that day. Turns out, it was a press release that was sent to me prematurely, so I hid it from view.

Well, a couple weeks ago, the Drug Enforcement Administration (DEA) released it’s interim final rule on ePrescribing of controlled substances (PDF). John Halamka described some of the most important details of this rule on his blog:

(a) To sign a controlled substance prescription, the electronic prescription application must require the practitioner to authenticate to the application using an authentication protocol that uses two of the following three factors:
(1) Something only the practitioner knows, such as a password or response to a challenge question.
(2) Something the practitioner is, biometric data such as a fingerprint or iris scan.
(3) Something the practitioner has, a device (hard token) separate from the computer to which the practitioner is gaining access.
(b) If one factor is a hard token, it must be separate from the computer to which it is gaining access and must meet at least the criteria of FIPS 140-2 Security Level 1, as incorporated by reference in § 1311.08, for cryptographic modules or one-time-password devices.
(c) If one factor is a biometric, the biometric subsystem must comply with the requirements of § 1311.116.

Halamka also suggests they’ll consider 3 approaches to support strong authentication:
*Fingerprints (Bio-Key software?)
*Hard Tokens (such as those provided by RSA)
*Cell Phones (As Gemalto talked about in this video)

I also recently heard someone tell me that the banking has a 6 percent failure rate for matching people. It’s hard for me to believe that it’s high and that the banking industry is willing to deal with that type of failure rate. Of course, that’s not good enough for controlled substances. So, they’re going to have to find some way to lower the patient matching failure rate. Although, I wonder what the failure rate is with the current model. Seems like electronic prescribing shouldn’t make it any worse than it currently is.

John Halamka wrote some interesting comments about the various feedback he’s heard on the meaningful use guidelines on his blog. He gives some interesting insight into why ONC’s interim final rule is so vague (basically regulation/rule making mess). However, I couldn’t help but see how many times John Halamka used the words:

Need for additional guidance

This is no news to people like myself who’ve been writing about this since the beginning. There is a great desire for information on how to get the EMR stimulus money.

The real problem is that when things are vague and not well defined, then misinformation starts to take its place to satisfy our need for information and guidance. We want to be informed and so people start informing us even if the information is incorrect.

Today I got an email from someone stating that “We have the EMR already installed by a certified institution” and so they wanted to know how they could get the EMR stimulus money.

I felt so bad for this emailer. Someone (likely their EMR vendor) had either told them a lie about certification or more likely is that this person didn’t understand the details of the “certified EHR” component of the stimulus money. This is going to be a major challenge going forward as doctors who don’t have time to follow all the stimulus money movement get bad information. Plus, it’s only going to get worse if we continue to get partial pieces of information.

Sadly, most of the people emailing me about the EMR stimulus will continue to get the “Need for additional guidance” response from me. At least until ONC provides some additional guidance.

The wonderful John Chilmark posted a short message he heard from a Keynote address by John Halamka at the PHAT conference put on by the Harvard School of Public Health. Here’s the message:

there will be no partial reimbursement for meeting just part of meaningful use. Its all or nothing folks.

I think we all assumed this was basically the case, but it’s interesting to hear John Halamka say it. Let’s not take this quote too far out of context. I don’t think that John Halamka was saying that if you don’t qualify for one year of EMR incentive, that the next year you won’t have any more chances to qualify. I think he’s saying that either you’re going to get that years portion of EMR stimulus money or you’re going to be stuck waiting for the next year.

Let me repeat my mantra:

Implement EMR because it’s the right thing to do for your clinic (and I tell you that it is the right thing to do for almost ANY clinic) and not in the hopes of getting the EMR stimulus money. Stick with the now proven EMR benefits and use the EMR stimulus money as a possible bonus and you’ll be happy you did.

I read that the HIT Policy Committee meeting that happened on July 16, 2009 was a “big one” according to Chilmark Research. He said that “the committee went from hearing revised recommendations for Meaningful Use, to recommendations from the HIE workgroup and lastly recommendations regarding certification processes for EHRs.”

I was unfortunately tied up doing a presentation on ARRA EHR Stimulus money and so I wasn’t able to follow the event live (or on one of my twitter accounts). I know that Chilmark is planning to do some posts and I’m looking forward to those.

I also found this short summary from John Halamka about the changes to meaningful use in the final definition:
1. For inpatient CPOE, only 10% of orders must be entered electronically
2. For problem lists, ICD9 or SNOMED must be used
3. Advanced directives must be recorded
4. Smoking status must be recorded
5. Quality measures must be reported to CMS
6. Clinicians and Hospitals must implement at least one clinical decision rule relevant to a high clinical priority
7. Administrative transactions, including eligibility and claims, must be completed electronically

I think it was wise for them to split it out into an “eligible provider” and a “hospital” set of requirements since the needs are different, but at first glance it seems a bit like ambulatory clinics are getting a bit of a shaft in this regard. I’ll reserve final judgement until I have more time to really review the changes.

I do think this change as described by John Halamka is a good one: “The Meaningful Use Workgroup recommended use of an ‘adoption year’ timeframe (i.e., ’2011 measures’ applies to first adoption year even if HIT adopted in 2013; ’2013 measures’ applies to 3rd adoption year.”

This powerpoint about EHR certification was also presented at this meeting. There’s a lot of information in that powerpoint, but it looks like they’re proposing that CCHIT be relegated to a certifying body, but not be involved in defining the certification criteria. HHS will be defining the EHR certification criteria. I’m sure I’ll be writing much more about the content in this presentation. Lots to still digest.

I also found two draft transcripts from the meeting.

If anyone else knows of some other summaries from this meeting please let me know in the comments and I’ll add them here. Or feel free to make your own summary in the comments. I’m always interested to hear what people thought was important from meetings like this.

The healthcare IT airwaves are abuzz with the date of June 16th.  That’s the date that they say we should get more indications on how the government is going to define the all important term “meaningful use.”  Here’s a short quote from John Halamka about the meaningful use dates:

On June 16th, the Quality workgroup will receive meaningful use guidance from the HIT Policy Committee. We’ll work hard over the following week and will present our strawman standards, implementation guidance, and certification criteria at the June 23rd public meeting of the HIT Standards Workgroup. We’ll continue to refine the matrix in July and complete our work in August.

John Halamka also described the format for the HIT Standards Committee’s meaningful use document:

On the call we discussed that the HIT Policy Committee will review a draft of meaningful use criteria at its June 16th meeting. Once this draft is delivered to the HIT Standards Committee, its workgroups can review the standards and certification criteria which map to meaningful use. Imagine a 4 column table

Column 1 – An aspect of meaningful use i.e. e-Prescribing

Column 2 – The standards and implementation guidance needed for meaningful use i.e. NCPDP Script 10.5 and RxNorm as implemented in the HITSP Capability document “Issue Ambulatory and Long-term Prescriptions”

Column 3 – The certification criteria i.e. Conformance testing using the CCHIT Laika tool for appropriate implementation of NCPDP Script 10.5

Column 4 – The meaningful use measure i.e. what percentage of prescriptions in a practice were e-prescribed?

The above examples are illustrative only – they are not work products of any committee.

Certainly we’re going to get some more information and fodder for discussion about the term “meaningful use” and it’s implications for EHR stimulus money. I’d just caution people from looking too deep into the document we receive on June 16th. As is said above, there’s still a few more committees that need to meet to refine this document.

I do encourage people to provide feedback and commentary on the June 16th document. I’ll be looking around to find the best avenues for people to communicate any comments on the document. If you know of any avenues to share your feelings on “meaningful use” please let everyone know in the comments.

We’re all still sitting here waiting for the government to finally decide two key terms in regards to gaining access to the $18 billion in stimulus money in the HITECH act (ARRA). I’ve been interested in the subject myself since before it was even settled that we’d call it meaningful use as opposed to meaningful EMR user. From the looks of that post back in February, there was still a lot of confusion about “meaningful use” and “certified EHR.”

Turns out that a few months later, we still have very little clarification about what these two terms mean. Certified EHR discussion has really revolved around CCHIT certification or some other alternative. We’ll try to leave that discussion for other posts. What has been interesting is in just the past week or two there has been a literal flood of people offering their perspective on meaningful use. Sometimes I like to be on the cutting edge of these definitions (like I was in the link above) and other times I like to sit back and let them play out. This time I’ve been letting it play out and it’s really interesting to see the multitude of perspectives.

I’m not planning on writing my own plan for how they should do meaningful use. I may do that at a later time if so inclined. For now, I’ll just focus on highlighting points from what other people have suggested and provide commentary that will hopefully enhance people’s understanding of this complicated mandate (yes, that means this post will be quite long).

I think it’s reasonable to first point you to the NCVHS hearing on “Meaningful Use” of Health Information Technology. This matters, because at the end of the days hearings like these are where most of the information are going to come. Then, with the information from these hearing decisions will be made. The other sources like blogs won’t carry nearly as much weight (although it’s unfortunate that more politicians aren’t listening).

John Chilmark on Meaningful Use
Next, I’ll go to one of my newly found favorite bloggers named John Chilmark (any coincidence we’re both named John). John from Chilmark Research commented that HHS is bringing together the “usual suspects” to discuss “meaningful use. Chilmark also states that the following criteria are what’s required for meaningful use:

1. Electronic Prescribing
2. Quality Metrics Reporting
3. Care Coordination

I’m not sure where he got this list, but this list feels kind of weak if you ask me. In fact, John suggests that these requirements will be simple and straightforward and first and then ratcheted-up in future years. Interesting idea to consider. I hope that they do draft the requirements for meaningful use in a way that it can be changed in the future if it turns out to not be producing the results it should be producing.

John Halamka on Meaningful Use
Next up, the famous John (another John) Halamka, Chief of every Health IT thing (at least in Boston), calls defining “meaningful use” “the most critical decision points of the new administration’s healthcare IT efforts.” He’s dead on here. In fact, it might not be the most critical decision for healthcare IT, but for healthcare in general as well. Here’s John Halamka’s prediction for how “meaningful use” will be defined:

My prediction of meaningful use is that it will focus on quality and efficiency. It will require electronic exchange of quality measures including process and outcome metrics. It will require coordination of care through the transmission of clinical summaries. It will require decision support driven medication management with comprehensive eRx implementation (eligibility, formulary, history, drug/drug interaction, routing, refills).

Basically, he’s predicting inter operable EMR software and ePrescribing with a little decision support sprinkled on top. I won’t be surprised if this is close to the final definition. The only thing missing is the reporting that will be required to the government. The government needs this data to fix Medicare and Medicaid (more on that in another post).

Blumenthal Comment to Government Health IT
Government Health IT has a nice quote from David Blumenthal that says: “The forthcoming definition of the “meaningful use” of health information technology will set the direction of the Obama administration’s strategy for health IT adoption, said David Blumenthal, the new national coordinator for health IT.”

I think there’s little doubt that David Blumenthal has a good idea of the importance of the decisions ahead. What should be interesting is to see how involved Obama is in these very important decisions. I’m guessing Obama won’t do much more than sign a paper to make it happen. I just hope I’m wrong.

HIMSS Definition of Meaningful Use
Here’s a short summary of the HIMSS definition of “meaningful use”

According to HIMSS officials, EHR technology is “meaningful” when it has capabilities including e-prescribing, exchanging electronic health information to improve the quality of care, having the capacity to provide clinical decision support to support practitioner order entry and submitting clinical quality measures – and other measures – as selected by the Secretary of Health and Human Services.

Basically, e-prescribing, interoperability and clinical decision support. Turns out a BNET Healthcare article suggested the same conclusion “The consensus of physician and industry representatives was that meaningful use should include interoperability, the ability to report standard quality measures, and advanced clinical decision-making.”

I think we’re starting to see a bit of a pattern here. I should say that these are all very good things, but the challenge I see is that any requirement needs to be easily and consistently measured. Interoperability and clinical decision support are both very difficult to measure. Just wait until they see the variety of software that tries to do those two things. It’s very difficult to measure it consistently across so many EHR software.

Wow!! I barely even got started on this subject. Instead of belaboring the point, let me just point you to some other interesting readings about the HITECH Act, ARRA, and “meaningful use.”

• Fred Trotter’s Open Source Perspective
• Blackford Middleton’s Comments on “Meaningful Use”
• Steve Beller’s Definition of “Meaningful Use”
• Human Factors and “Meaningful Use”
• AHIMA Comments on “Meaningful Use” (pdf)
• Markle Foundation Framework (PDF)

Please let me know if there are other good sources for perspectives on defining “meaningful use.” This really is a landmark decision for healthcare IT.