Meaningful Use Monday | EMR and HIPAA

Meaningful Use Potpourri – Meaningful Use Monday

We’ve been publishing Meaningful Use Monday for exactly two years today. Most of the posts have been written by the wonderful Lynn Scheps from SRSsoft and I think they represent a wonderful asset to those interested in meaningful use. That’s close to hundred posts on the subject of meaningful use and EHR incentive money. Hopefully readers have found it as useful as I have in understanding the complexities of meaningful use.

Considering how much we’ve posted about meaningful use, I think it’s time to move meaningful use out of a featured space on the site. Don’t get me wrong, I’m sure there are many more meaningful use posts to come. In fact, it’s likely a post a week will still be about meaningful use and the EHR incentive money in one way or another. However, I hope that we can also help many doctors move past meaningful use to actually meaningfully using EHR and other healthcare technology. For example, I’m planning a series of posts on the benefits of EHR in the current environment. I expect it to drive some really interesting conversation.

Before I end the Meaningful Use Monday series to a more random assortment of meaningful use posts, I thought I’d provide a potpourri of meaningful use thoughts. I think you’ll find them interesting.

Most Docs Won’t Qualify for EHR ‘Meaningful Use’ @medpagetoday ow.ly/fYclf

— KBIC Practitioners (@NPJobFinders) December 10, 2012

This is an interesting title since the article says that most won’t be able to show meaningful use and then goes on to list the statistics for how many doctors are using EHR. So, they’re using EHR, but they don’t have the capability to show meaningful use? To me EHR adoption is the more important number. I also like that EHR vendors have all applied the same CCD standard for data portability. I’m ok if many doctors forgo meaningful use. Although, we’ll see how that plays out if the penalties indeed go into effect.

Meaningful Use Doesn’t Drive Doctors’ #EHR Selection twb.io/SRrnd0 | #healthIT news via @informationweek

— InfoWeek Healthcare (@IWKHealthcare) December 10, 2012

This is music to my ears. I’ve been preaching this message for a long time. The odd part is that this article references the same studies and data as the first. What is clear from the numbers is that EHR adoption is up. That’s a good thing for healthcare since we need widespread EHR adoption to take the next step to technology adoption in healthcare.

Many docs apply for ‘meaningful use’ of electronic health record payments, but few will pass muster -#wpautosocial

— Medical Apparatus (@MedApparatus) December 10, 2012

I don’t think this is true, depending on how you define “apply.” I know very few doctors who have applied to meaningful use and not gotten paid. If you know of stories that say otherwise, I’d love to hear them. This is particularly true in meaningful use stage 1. We might see more meaningful use payment rejections in stage 2 and 3, but so far the money has basically flowed out. I think this is by design. The worst thing for ONC would be many doctors working towards meaningful use and then not getting paid.

CMS Tweaks Final Stage 2 Meaningful Use Rule – HDM Latest News Article ht.ly/fYyzy

— Iatric Systems (@IatricSystems) December 10, 2012

Yep, meaningful use stage 2 is still getting tweaked. It’s hard to keep up.

$9.2B in Meaningful Use Pay Distributed as of November – bit.ly/TFl35G

— Missy Krasner (@missykras) December 10, 2012

Almost a third of the way there. I love this “shovel ready” part of the ARRA economic stimulus package. Makes me laugh to think about it.

Pediatrics and EHR Incentive – Meaningful Use Monday

Written by: John Lynn

I know that there are a number of pediatric doctors that read EMR and HIPAA along with a number of Pediatric EHR vendors. They could likely speak to the challenge of meaningful use and the EHR incentive money in much more depth than I. In fact, I hope they will chime in with the pediatric perspective on meaningful use and EHR money in the comments. As most of you know, I’ve always seen EMR and HIPAA as a forum for great discussion.

To start the discussion of pediatrics and EHR incentive money, I came across a couple tweets from AMIA 2012 that paint a very sad picture for most pediatricians when it comes to getting government money to help with their EHR implementation.

S80: Lehman – must have 20% pts on Medicaid for MU eligibility, but pts on Medicaid unevenly distributed. Diff for peds to qualify #AMIA2012

— Kim Unertl (@kimunertlphd) November 7, 2012

I wish that I had all the background on this tweet. However, the message is quite clear: it will be difficult for pediatrics to qualify for the EHR incentive money.

This second tweet puts some hard numbers on the pediatricians that could qualify for meaningful use:

Amongst challenges in Peds “Only 54% Pediatricians qualified for MU” because requires 20% Medicaid – Panel on EHR AND MU #AMIA2012

— Martha Adams, MD (@mbadams) November 7, 2012

This isn’t such a surprise since meaningful use has always been so primary care focused. Meaningful Use has come a long way to try and include more medical specialties (see my post on radiology meaningful use), but it’s hard to change something into something it wasn’t ever intended to accomplish.

I look forward to hearing pediatricians’ experience with meaningful use in the comments.

Meaningful Use for Radiologists – Meaningful Use Monday RSNA12 Edition

Written by: John Lynn

This week is the enormous RSNA conference in Chicago. I almost made the trip to the event, but wasn’t able to figure out the logistics. Plus, with a wife and kids the less travel the better. One day I’ll make it to RSNA. Until then, I thought I’d dedicate this edition of Meaningful Use Monday to the radiologists out there.

In short, meaningful use stage 1 was not good for radiologists. Most radiologists saw it as a non-starter for them. In fact, I think it’s safe to say that smaller radiologists couldn’t tell you much of anything about meaningful use stage 1. Meaningful Use stage 2 has made some progress for radiologists, but is unlikely to really get them off the bench and showing meaningful use.

Healthcare IT News has a good article on radiologists and MU where they point out some image centric updates to meaningful useper RSNA:

compliance exemptions for many hospital-based providers who are not involved in their facility’s information technology decisions, a discretionary menu set objective targeted toward diagnostic image accessibility in EHRs, recommendations for radiology-relevant clinical quality measures, more flexible definitions of what constitutes justified EHR, and a consolidation of the eligible hospital and eligible professional technology certification criteria.

Although, the article also points out two other very important points. First, radiology practices will likely forgo participation in the meaningful use program and avoid the EHR financial penalties by way of an exemption. If that exemption ever runs out, then radiologists might change their tune. Although, my guess is that the meaningful use penalties will never be enforced or that there will always be exemptions that radiologists can fall back on.

The second point is even more interesting. Lineage Consulting’s Nakhle suggests that all of the other ordering physicians that are adopting EHR and showing meaningful use might be the real driver for radiologists to get on board meaningful use. I agree that ordering physicians being meaningful users of an EHR is going to change imaging facility requirements. Certainly imaging facilities are going to have to work on new tech workflows, but that doesn’t mean they have to go so far as meet meaningful use. Plus, most imaging facilities are working on these workflows already, so I don’t expect meaningful use will cause much change.

I’m sure this will be a huge topic of discussion at RSNA. If you’re there, we’d love to hear what’s being said on the show floor.

Meaningful Use Stage 3 Timeline – Meaningful Use Monday

Written by: John Lynn

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.

New Opportunities to Avoid ePrescribing Penalty for 2013 – Meaningful Use Monday

Written by: Lynn

According to the 2013 Medicare Final Rule released last week, there are new ways to avoid future payment adjustments under the MIPPA ePrescribing rule for those who have not already taken the necessary steps to avoid them: 1) The exemption request period has been reopened and 2) meaningful use will satisfy the ePrescribing requirements according to specific timetables.

1) CMS is offering a second chance to physicians who missed the June 30 deadline for requesting an exemption to the 2013 ePrescribing penalty (1.5%) under the original 4 categories. Between November 1, 2012 and January 31, 2013, physicians can go to the Quality Reporting Communication Support Page and request an exemption based on one of the following justifications:

Inability to electronically prescribe due to local, State, or Federal law or regulation (i.e., prescribe predominantly controlled substances)
Prescribed fewer than 100 prescriptions between January 1 and June 30, 2012
Insufficient high speed internet access (i.e., rural area)
Insufficient available pharmacies that accept electronic prescribing.

2) In the interest of harmonizing the various government programs that contain ePrescribing components, CMS now will provide two additional ways to avoid the 2013 MIPPA penalties:

Achieve meaningful use during 2013
Demonstrate intent to participate in the EHR Incentive Program and adopt Certified EHR Technology by January 31, 2013

This information will be retrieved by CMS from the information in its EHR Incentive Program’s Registration and Attestation System, rather than by having providers request an exemption as in #1 above.

CMS May Revisit Patient Engagement Rules – Meaningful Use Monday

Written by: John Lynn

Health Data Management has a fascinating quote from Travis Broome, specialist at CMS, during a presentation on meaningful use Stage 2 at MGMA 2012.

Stage 2 electronic health record meaningful use requirements that at least five percent of patients conduct secure messaging with physicians, and view, download, or transmit their ambulatory and inpatient data came at the insistence of HHS Secretary Kathleen Sebelius. And those requirements might not be set in stone.

The patient engagement requirement has long been one of the most talked about challenges with meaningful use stage 2. The problem is easily seen. Doctors EHR incentive is being held hostage by something they don’t control. If patients don’t want to access their health information, are doctors suppose to coerce them into doing so?

An article in Fierce Health IT also has a money quote on what’s wrong with this MU stage 2 provision:

As Jeremy Tucker, medical director of MedStar St. Mary’s Hospital in Leonardtown, Md., told FieceHealthcare, better patient experience comes from cultural change across all levels of the organization. “If the reason for doing patient experience is simply to get a better score on a test, you will fail,” he said. “It only takes one cold meal tray or a roll of the eyes by a staff member to derail the patient experience.”

While I love the intent of patient engagement, I don’t love it as a requirement for EHR incentive money.

Another great comment from Broome from the Health Data Management article above is in regards to meaningful use audits:

Answering a question about meaningful use payment audits, Broome acknowledged that the audits have begun. He declined to give many specifics other than saying that providers falling into certain “risk profiles” might be asked to justify their attestations. One practice, for example, attested to meaningful use and supplied identical statistics across multiple criteria, all but inviting suspicion. When challenged, that practice returned the money, Broome said.

UPDATE: Travis Broome sent me this clarifying tweet:

“@techguy:dlvr.it/2PKQMV” Of course I actually said Sec approved and revisit only if everyone was actually failing the measure

— Travis Broome (@Travis_Broome) October 30, 2012

Of course we know he can’t do anything without the secretary approval. Hopefully the bar is a little more than everyone failing. How about almost everyone failing or most people failing?

OIG to Include Meaningful Use and EHR Incentive Reviews – Meaningful Use Monday

Written by: John Lynn

We all knew that meaningful use audits were on their way. Healthcare IT News is reporting that the Office of the Inspector General (OIG) will undertake a review of ARRA which will include probes into the EHR stimulus program.

“We will review Medicare incentive payments to eligible health care professionals and hospitals for adopting electronic health records (EHR) and the Centers for Medicare & Medicaid Services (CMS) safeguards to prevent erroneous incentive payments, the OIG’s states in its work plan for fiscal year 2013.

In its plan OIG states it will look at incentive payments CMS made beginning in 2011 to identify payments to providers that should not have received incentive payments – those that did not meet the meaningful use criteria.

This shouldn’t come as a surprise to anyone. Considering meaningful use is a self attestation process, then it’s just common sense that the self attestation will receive an audit to help ensure that people attested to meaningful use properly.

Plus, if you’re a regular reader of this site, you might remember that we’ve written about meaningful use audits a few times before. I don’t know anyone that likes audits, but Lynn Scheps provided a good list of suggestions on what documentation you should keep from your meaningful use attestation.

If you’re part of a meaningful use audit or hear about what’s involved in the meaningful use audits, please do let us know in the comments. We’d love to learn from those who have first hand experience with the process.

Meaningful Use the Commodity – Meaningful Use Monday

Written by: John Lynn

I decided to take a step back this week for Meaningful Use Monday to look at where we are in the new world of health IT which includes the commonplace terms of EHR incentive money and meaningful use. Plus, I’m probably waxing a bit nostalgic today as I think about the David Brailer keynote at the Digital Health Conference today (follow my tweets on @ehrandhit for more coverage) where he spoke a bit about the origins of healthcare IT.

At this point it seems that meaningful use has become basically a commodity. There are very few EHR vendors out there now that aren’t certified EHR that can help a physician get to meaningful use (Although there are some non-certified EHR still). Basically, if you are doing EHR, then more than likely you are doing meaningful use. Or at least you’ll have that opportunity if you want. Some would argue that means that this result is a function of the meaningful use bar being set too low.

In fact, that is largely what the congressmen’s argument was in their letter to HHS about halting meaningful use. The real question is whether this is a problem. I personally don’t mind all the EHR competition. I think it would have been worse if the government incentive, meaningful use, and the RECs essentially narrowed the field of EHR vendors down to only a few.

The argument on the other side is around the “paradox of choice.” There’s little doubt that many practices are in a situation where there are so many EHR choices that they make the decision not to choose. However, I see this more as an excuse not to do EHR from people who didn’t really want to do EHR in the first place. I’m not sure these people would have been doing EHR even if there were only a few choices.

This does leave us with a challenging problem going forward. The EHR churn rate is going to go through the roof. David Brailer pointed this out today in his keynote and he’s right that it’s already happening today. Although, the majority of the EHR churn that’s happening now is from those organizations that are going after meaningful use. The major EHR churn rate of the future is going to come from EHR consolidation.

What does this all mean? Now more than ever, an organization needs to do good due diligence on the stability of the EHR software. Notice that I didn’t say EHR vendor. Just because you’re a large EHR vendor that’s financially stable doesn’t mean that the EHR software is safe (see Exhibit A and Exhibit B).

One thing is clear though, meaningful use and EHR are here to stay. There’s no escaping EHR. We’re finally back to the point where doctors are no longer asking if they should do EHR. Instead, they’re asking how, when and which EHR they should do. This is a very good industry trend.

Important Dates in the Life of a Meaningful EHR User – Meaningful Use Monday

Written by: Lynn

Here’s a look at some of the important dates to know for those looking to attest for Meaningful Use:

October 3, 2012: Last date to start the 90-day reporting period to earn an $18,000 EHR incentive payment for 2012, and to be eligible for the maximum total of $44,000. (The potential total drops to $39,000 in 2013.) Physicians do not have to be registered by this date—they can register at any time before they attest.

January 1, 2013: First day of the 365-day, 2013 reporting period for any provider who earned his/her first incentive payment in 2011 or 2012.

February 28, 2013: Last date to register and to attest for the 2012 EHR incentive. (Happily, no one has to spend New Year’s Eve attesting!) But remember, the entire reporting period has to have occurred within 2012.

October 3, 2013: For EPs whose first EHR payment year will be 2013, last day to start the 90-day reporting period and earn a $15,000 2013 incentive.

2013: EPs who successfully demonstrate meaningful use in 2013 will not be subject to the 2015 payment adjustment.

October 1, 2014: For EPs whose first incentive year is 2014, this is the last date to submit a successful meaningful use attestation and avoid the 2015 payment adjustment.

ONC Health IT Dashboard – Meaningful Use Monday

Written by: John Lynn

As many of you know, I’m spending this Monday traveling to the AHIMA conference in Chicago. It’s my first time to Chicago, but my second time to AHIMA. I have a full schedule of meetings and I’m really excited for the event. Also, we’re holding a tweetup Monday night if any readers are at the event or live in Chicago. Watch @ehrandhit and @HealthITMKTG for more details.

Since I’ll be traveling, I thought it would be fun to do a little bit of open source/crowd source style discussion on meaningful use. Instead of me pointing out the various aspects of meaningful use and other trends, I’m interested to hear your thoughts.

I’d also challenge readers to take a look at the ONC Health IT Dashboard. Browse through the data and then come back and share with us any interesting data that you find in the reports.

Leave your thoughts in the comments of this post, or if you’re too shy for that feel free to share your thoughts on the EMR and HIPAA contact us page. We always love hearing our readers perspectives. Anything is fair game. I look forward to reading your comments and responses.

Meaningful Use Potpourri – Meaningful Use Monday

Pediatrics and EHR Incentive – Meaningful Use Monday

Meaningful Use for Radiologists – Meaningful Use Monday RSNA12 Edition

Meaningful Use Stage 3 Timeline – Meaningful Use Monday

New Opportunities to Avoid ePrescribing Penalty for 2013 – Meaningful Use Monday

CMS May Revisit Patient Engagement Rules – Meaningful Use Monday

OIG to Include Meaningful Use and EHR Incentive Reviews – Meaningful Use Monday

Meaningful Use the Commodity – Meaningful Use Monday

Important Dates in the Life of a Meaningful EHR User – Meaningful Use Monday

ONC Health IT Dashboard – Meaningful Use Monday

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