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Eyes Wide Shut – Teaching to the Meaningful Use Stage 2 Test

Posted on September 30, 2013 I Written By

Mandi Bishop is a hardcore health data geek with a Master's in English and a passion for big data analytics, which she brings to her role as Dell Health’s Analytics Solutions Lead. She 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.

According to Twitter analytics, one of my more engaging tweets recently stated that Meaningful Use is stifling innovation by requiring that health IT vendors and healthcare providers employ very specific tactics to capture and report on clinical data capture and interoperability standards compliance – ostensibly to engage and empower the patient, and improve coordination of care between providers. Of course, I said it much more succinctly than that. In effect, conforming to the Meaningful Use Stage 2 attestation measures is akin to “teaching to the test”:

Here’s a real-world example of what it means to “teach to the test” of Meaningful Use. In order to qualify for CMS incentive dollars, Meaningful Use Stage 2 Year 1 patient engagement measures must be met, with auditable data captured, in a 90-day contiguous period in 2014. An eligible provider (EP) must demonstrate that 50% of all patients with encounters during that time period have online access to their clinical summary within 4 days of the data becoming available to the provider. 5% of those patients must access the clinical information within the 90 days, and 5% of those patients must leverage secure messaging to communicate relevant health information with the provider. Finally, the MU-certified EMR must proffer patient-specific education materials for 10% of the patients seen during that time.

What I believe the ONC had in mind when they crafted these measures: engaged patients who will log in to their portal after each encounter, review the findings and lab results to assess their own progress and outcomes, read or listen to the condition-specific educational materials provided that resonate with them, and ask more meaningful questions of their providers as a result of this new-found, data-enabled empowerment. That is why they categorize these measures as “patient engagement”, right?

Wrong. This is what “patient engagement” looks like, from the EMR implementation, Meaningful Use-consultant, EP business process standpoint.

First, establish the bare minimum thresholds for meeting the measures. If the EP saw 1000 patients during the same 3-month period the previous year, your denominator is 1000; calculate the numerator for each measure based on that. So, we need 500 patients to have access to their clinical data online; 50 patients must access their information; 50 patients must communicate with their provider via secure messaging; 100 patient encounters must prompt specific educational opportunities.

To meet the 500 patients with online access to their clinical data, patient portal software is preloaded with patient demographic accounts, based on the registration data already available in the EMR. An enrollment request is emailed to the patient or authorized representative (assuming an email address is available in their demographic information). The EMR captures the event of sending this email, which contains the information about how to enroll and access the patient’s medical records via the portal. This measure is met, without the patient acknowledging the portal’s existing, and without any direct communication between provider and patient.

The medical records view and secure messaging measures can be met simultaneously, in a matter of days, by planning to add a few extra minutes to each encounter for 50 patients’ worth of appointments. The EMR has already triggered an email with portal enrollment information to each of the patients in the waiting room on a given day. As the medical assistant (MA) is taking vital stats, she asks whether the patient has enrolled in the portal. It’s likely the patient has not; the MA hands the patient a tablet and has him log in to his email, and walks him through the portal enrollment and initial login process. Once logged in, the MA directs the patient to click the link to view his medical record. That click is recorded, and the “view” measure is met; whether a CCD or C-CCD is actually displayed is irrelevant to the attestation data capture.

Having demonstrated how a patient can view his record, the MA then asks the patient to go into the portal’s message center, to send a test communication to the provider. The patient completes the required fields, and the MA prompts him with a generic health-related question to type into the body of the message. Once the patient hits “Send”, the event is recorded, and the “secure messaging” measure is met.

For all patients, whether portal-users or not, a new process begins when the MA finishes, the provider enters the room and begins her evaluation of each of the 100 patients required to meet the education measure. As the patient talks, the provider is clicking through EMR workflow screens, recording the encounter data. The EMR occasionally prompts with a dialogue box indicating educational materials are available for patients with this diagnosis code, or this lab result. Each dialogue box prompt is recorded by the EMR; the “patient-specific education” measure is met, whether the provider acts on the prompt and discusses or distributes the educational information or not.

To put it simply: the patient never has to log in to a portal to meet the 50% online availability requirement, they don’t have to actually view their records to meet the 5% view requirement, they don’t have to have an actual message exchange with their provider to meet the 5% communication requirement, and they don’t have to receive any tailored materials to meet the 10% education requirement. Once those clicks have been recorded, the actions never have to be repeated; meaningful and ongoing patient engagement is not needed to meet the attestation requirements and receive the incentive dollars.

In a previous post, I introduced my interpretation of the difference between the spirit and letter of the Meaningful Use “law”. By teaching to the test, we’re addressing the letter of the law, only, in its narrowest interpretation. When will we incent vendors and providers to go above and beyond and find ways to truly engage patients in meaningful ways, empowering them with accurate, timely data access and tools to analyze it?

4 Things You Should Do to Make Sure You’re Compliant with Meaningful Use

Posted on September 26, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of 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 following is a guest post by Beth Houck, Vice President of Client Services at SA Ignite.

As we near the last quarter of 2013, many providers will have earned over half of their Meaningful Use (MU) incentive dollars and will be adept at following the workflows required to meet the Stage 1 measures.  With two years (or more) of following MU under their belts, it’s really just old hat, right?  Maybe, but not so fast.

For small practices with no turnover and no upgrades to their EHR, practice managers can follow many of the same checklists that got them through the first year:  verification that all non-percentage based measures have been met (e.g., a completed security risk audit, evidence of enabled features in the EHR such as Clinical Decision Support and Formulary Checks, completion of an immunization test) and a secure copy of the report that was generated from the EHR that supports percentage-based measure compliance and CQM submission.  Practice managers may find themselves nudging providers to stay on track, but a small, stable practice has far less moving parts from year-to-year.

This is in significant contrast to large practices and Federally Qualified Health Centers (FQHCs) that experience significant turnover.  It’s September 2013 and a new provider started with your organization.  Do you know what payment year he is in?  Are you allowed to attest for him or did his previous practice lay claim on these dollars?  It’s July 2013, and a new provider brings her report from the certified EHR she was using in the first part of the year.  What do you do with this information?  How does this impact this provider’s attestation?

As larger provider organizations advance beyond the earliest stages of MU reporting, they realize that a once manageable process quickly becomes complicated, and the risk that incentive dollars will be lost drastically increases. Ensuring compliance means knowing what rules apply to these providers. Through our work monitoring more than 5,000 providers, we’ve worked to automate the attestation process. Here’s our list of four key best practices to ensure you’re on track to MU compliance.

  1. The first step is to determine the provider’s Payment Year and under which program(s) they’ve received incentive dollars. You can look this up using the same login to attest for providers.
  2. Then if they are in payment year 2 for Medicare, never having switched from Medicaid, they will need to meet MU for the entire 365 days. This means that MU data from any previous practices’ EHRs will need to be added to their current MU data. CMS has published a list of frequently asked questions on how to calculate these numbers. On a positive note, you will not be required to have your Clinical Quality Measures (CQMs) align with the previous practice’s EHR. If they don’t match, you can just use the CQMs from the system where you had more visits.
  3. The next step is to determine which of the non-percentage based measures need to be repeated for this provider. For example, if you don’t have any record of an immunization test being completed at the previous practice, one will need to be completed.
  4. Finally don’t forget that the EHR Certification ID that you used when you originally attested for your providers won’t necessarily apply to subsequently hired providers. If the new hire is bringing data from their old practice that needs to be merged with their new practice, you will need to obtain a new Certification ID from the Certified Health IT Product list. Following the sites instructions, you will need to add both the provider’s previous EHR and your EHR to the “basket” to obtain a new, unique Certification ID produced for this combination of EHRs.

It’s clear that there is so much more to MU compliance than double checking if you printed Visit Summaries for more than 50 percent of your patients.  As we move into 2014, there are multiple payment years, programs and stages to track, so you will need to be certain that you have a system in place to ensure that you can manage the cases mentioned above to maximize the EHR incentive dollars for your organization.