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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.

Meaningful Use Final Rule Published

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This morning HHS held a live webcast (I guess it’s a news conference?) announcing the final meaningful use rule. Unfortunately, it was a little early for me on the west coast (the life of a blogger), but I caught the second half of the webcast.

Seems like they have made some changes to the meaningful use program. The most notable I think are the drop in percentage of ePrescriptions that are required (now at 40% I believe) and the mandatory and ala carte meaningful use requirements.

I’m really interested to look into how they’ve implemented the second option. I believe this is how they’re trying to deal with the problems of meaningful use and specialties. So, hopefully the mandatory meaningful use requirements will be those that apply to ALL specialties and then the ala carte items can be customized to each specialties needs.

I’m sure I’m missing some other notable details. I’ll do what I can over the next week to look over the documents and the other meaningful use coverage on the web to bring you more analysis on the announcement.

In the mean time, it looks like CMS has published a website on the EHR incentive programs. They even have this page on Meaningful Use which includes the download of the Meaningful Use final rule.

July 13, 2010 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

Looking Back: Meaningful Use Consultant Lies, EMR Conversions, EMR Backlog and Sunday Funnies

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This weekend I decided to look back at some random posts. Yes, call it my deep dive into the over 800 different EMR blog posts I’ve done on EMR and HIPAA. No sense in good quality posts not being seen.

Lies from Meaningful Use Consultants – Yes, the title is a bit sensational, but I was (and still am) aghast at the amount of misinformation (and lies) that are out there misleading the unsuspecting. Expect this to increase in 2011 as the EMR stimulus money starts rolling out. I’d love to post the first picture of someone getting their EMR stimulus check. Too bad it will be part of their Medicare reimbursement. Word of Caution: Be Careful with what you hear!

Converting Data from Old EMR to New EMR – I loved this email. The way he describes the difficult process of converting data from an old EMR to a new one is spot on. I expect in about 5 years, we’re going to have thousands of more stories like this one.

Plus, the comments on the cultural change of switching EMR software is beautiful to read also. This is something that Allscripts and Eclipsys EMR users are going to have to think about after Allscripts acquisition of Eclipsys.

EMR Backlog – I can’t believe I haven’t written about this for a while. It was such a hot topic back when I wrote this post in August of 2009. It’s still in the back of people’s minds. However, so far I haven’t seen any real major EMR backlog. Have you? We’ll see if that changes once the final Meaningful Use rule is out. Or maybe the checks need to start rolling in first. Either way, I’m not too worried. I think a backlog would be a good thing.

Kathleen Sebelius on The Daily Show with Jon Stewart – Just a little something to make you laugh. I should post more things like this. Maybe Saturday will become the Saturday Funnies. If you have healthcare or technology related jokes let me know on my Contact Us page. I’d love to publish them.

July 11, 2010 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

Kathleen Sebelius on The Daily Show with Jon Stewart

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On the weekend I try and go a little big lighter since not as many people read on the weekend. This weekend I decided to go really light and post a couple video clips of Kathleen Sebelius’ appearance on The Daily Show with Jon Stewart.

The Daily Show With Jon Stewart Mon – Thurs 11p / 10c
Kathleen Sebelius Pt. 1
www.thedailyshow.com
Kathleen Sebelius Pt. 2
www.thedailyshow.com

Thanks to Neil Versel for pointing out this videos. Have a great weekend.

August 15, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

Delays in EHR Stimulus Time Frame

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About a month ago I read an interesting post by Will Weider, CIO of Ministry Health Care and Affinity Health System, where Will is the first to announce delays in the HITECH Act (ARRA) EHR stimulus money. To make his case he gives two reasons for his belief:

  1. In my experience, government mandates delays are the rule
  2. This EHR deadlines are completely unreasonable

HHS finally has Kathleen Sebelius in as secretary and so that should help move things along. However, I have to agree with Will that the EHR stimulus money will be delayed.

I’m not really blaming HHS or ONC or any other government organization for this. The HITECH Act (ARRA) guidelines are so vague that they should take their time and make sure the $18 billion is spent wisely. Luckily, I feel like David Blumenthal seems to understand the importance of the decisions they make as far as what’s defined as a “certified EHR” and meaningful use. That’s a good thing and it’s better to do things slowly than to do things poorly.

This will be bad news for all those EHR vendors who aren’t selling products. More delays on the definitions of these two things could put a number of EHR vendors in trouble (as I’ve spoken about a few times before).

I think we’re in for a really interesting year for those interested in selecting an EHR and the EHR space. I wonder if the first person to get a stimulus check from the government will take a picture and post it on Twitter or some blog. That will be a momentous occasion indeed.

May 3, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

Kathleen Sebelius Sworn in as HHS Secretary – Impact on EHR

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I’m sure that most of you in healthcare saw that Kathleen Sebelius was finally sworn in as the new HHS secretary. You can read the reuters report on the confirmation and swearing in of Kathleen Sebelius.

From the report, there’s no doubt that a lot of Kathleen Sebelius’s first job will be to work on this swine flu. No doubt a very important thing for her to keep an eye on and do what she can to protect us from having a major outbreak.

However, I must admit that I get the feeling that were going to hear very little from this new HHS secretary about EMR and EHR. I could be wrong, but I just don’t see her getting really involved in all the discussions of EHR implementation and the $18 billion of EHR stimulus money as part of the HITECH Act (ARRA).

Certainly she’ll be around for major announcements, but I get the strong impression that it’s actually David Blumenthal that’s going to be in the trenches doing the work of defining “certified EHR” and “meaningful use.”

Anyone know more about the situation that can help clarify what might happen, who will be responsible and whether Kathleen Sebelius will do much for EMR as HHS secretary?

April 30, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

Kathleen Sebelius as Obama’s HHS Secretary

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An AP report is announcing that Kathleen Sebelius will be announced as Barack Obams’s new nominee for HHS secretary tomorrow. The article says the following about Kathleen Sebelius as HHS secretary:

Sebelius, 60, is seen as a steady hand, an experienced public official who knows how to work across political lines. As a former state insurance commissioner, she is unfazed by the complexities of health care and insurance issues.

Of course, Sebelius will still have to gain confirmation from the Senate which could be interesting because Sebelius has clashed with abortion opponents in Kansas and the fight might head to Washington.

Another delay in the nomination of the HHS secretary could mean even more delays in the HITECH act and EHR adoption. I for one hope that health care doesn’t have to wait even longer for the HHS secretary to start getting down to business. There’s just far too much to do for us to be without a leader.

UPDATE: It’s now official that Kathleen Sebelius has been named as Obama’s HHS secretary. Check out the Huffington Post report and the Washington Post.

March 2, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.