Meaningful Use Stage 1 | EMR and HIPAA

Healthcare Groups Want Meaningful Use Evaluated Before Stage 3

Though the final rules for Meaningful Use Stage 3 aren’t due to take effect until 2016, ONC has already made the draft rules available for public comment. And comments, to be sure, the agency is getting.

While various groups have chosen their own details to critique, the general consensus seems to be that ONC is getting ahead of itself and ought to give Meaningful Use Stage 1 and 2 a good hard look first.

Accordng to a nice summary from iHealthBeat, here’s where some of the major healthcare groups stand:

* The American Hospital Association is recommending that ONC fund a comprehensive evaluation of MU generally, and while it does, hold off on finalizing Stage 3 recommendations.

* CHIME, too, is asking ONC to evaluate the existing Meaningful Use program to decide whether achieving stage 3 is realistically possible by 2016.

* The Federation of American Hospitals is also arguing that ONC needs to evaluate current Meaningful Use requirements. Also, in its letter to ONC, the group argues that the existing structure of two years per stage doesn’t cut it.

* The AMA weighed in with its own recommendation that ONC evaluate Meaningful Use as is before moving ahead. It also suggested changing some thresholds to make them more reachable; greater flexibility in program requirements; change the certification process to address usability; and improve HIT’s capability to share patient data.

Personally, I think the idea of doing an extensive Meaningful Use evalulation sounds like a good one, and I hope ONC actually does so. When you’re setting new standards that affect so many providers, why not gather some data on how existing standards work?

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January 16, 2013 I Written By Katherine Rourke

Katherine Rourke is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Tags:AHA AMA CHIME FAH Meaningful Use Stage 1 Meaningful Use Stage 2 Meaningful Use Stage 3 ONC

Meaningful Use Potpourri – Meaningful Use Monday

Written by: John Lynn

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.

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December 10, 2012 I Written By John Lynn

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.

Filed Under: ARRA EHR EHR Stimulus Electronic Health Record Electronic Medical Record EMR HealthCare IT HITECH Meaningful Use

Tags:CMS Lynn Scheps Meaningful Use Monday Meaningful Use Stage 1 Meaningful Use Stage 2 Meaningful Use Stage 3 MU Monday ONC

Final Rule for Stage 2 Brings Some Changes to Stage 1 – Meaningful Use Monday

Written by: Lynn

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.

Although Stage 2 requirements don’t become effective until 2014, the Final Rule for Stage 2 contains some changes that apply—or can apply—to providers before then, and some that will apply to all physicians in 2014, even those still in Stage 1. These changes fall into 3 categories in terms of timing: those that are effective in 2013, those that can be adopted in 2013 at the physician’s discretion, and those that are implemented in 2014.

Effective 2013:

Conducting a test of the EHR’s capability to exchange clinical information (Stage 1 Core Measure 14) will be dropped from the requirements. It will be replaced in Stage 2 by measures that require actual and ongoing exchange of information.
A new exclusion for the ePrescribing requirement is being added for physicians who have no pharmacy within 10 miles that accepts electronic prescriptions.

At Physician’s Discretion in 2013 (and required in 2014):

The Vital Signs measure will be restructured to separate the reporting of height and weight from the reporting of blood pressure. This is good news for those specialists who consider some, but not all 3 of the vital signs, relevant to their practice. Along with this change in the measure are revised minimum ages: blood pressure reporting will be required for patients age 3 and over instead of age 2, and height (or length) and weight will be required for all patients, even those under 2.
An alternate calculation for CPOE will help physicians—again, likely specialists—who do not prescribe frequently enough to meet the Stage 1 (30%) threshold. The denominator will be limited to “medication orders created by the EP during the EHR reporting period,” instead of “unique patients with at least one medication in their medication list.”

Effective 2014:

Currently, in Stage 1, if a provider attests to an exclusion for any menu measures, these measures can be counted towards the menu requirement. In Stage 2, this will no longer be true—excluded measures will not satisfy the menu requirement if there are other measures on which the provider could report instead. This will also apply to providers who are still reporting under Stage 1 in 2014—a change which those providers will likely perceive as inequitable since it did not apply to the earlier attesters. Those physicians who qualify for multiple exclusions—specialists, once again—will find that the menu set is really no longer a menu, as they will be left with few, if any, choices.

So, while physicians do not have to focus on Stage 2 just yet, they should consider whether they might benefit from the 2013 changes described above.

MU Attestation Audits – Meaningful Use Monday

Written by: Lynn

By definition, attestation is based on the honor system—that is, at least until you find yourself the subject of an audit. CMS has launched its anticipated program, and some physicians who have received an EHR incentive payment recently received a letter from the designated auditing firm, Figloiozzi and Company.

Although there is no way to predict which physicians will be audited, providing the information requested should not be too onerous a task for those “lucky” ones who are tapped. Providers are being asked to show proof that they possess a certified EHR and to substantiate the data they reported for the core and menu measures—specifically, via “a report from their EHR system that ties to their attestation.” Since all certified EHRs generate an automated measure calculation report and a clinical quality measure report, that documentation should be readily accessible. It would not surprise me if they are also asked to provide documentation of the security and risk analysis that the practice conducted to ensure HIPAA compliance. For suggestions regarding the type of data to retain to support your attestation, see the Meaningful Use Monday post, MU Attestation: Save Your Documentation.

Based on material published by the auditors and by CMS on its EHR Incentives website, it does not seem that the audits will be so detailed as to require site visits or reviews at the patient chart-level. My sense is that CMS is looking to identify failures to comply with the major requirements—adopting and using a certified EHR to meet the meaningful use measures and reporting accurately on the data generated by that EHR.

(If you have been audited and would like to share your experience, please post a comment.)

Hospital CIO Interview – Will Weider

Written by: John Lynn

When I first started blogging, I came across a hospital CIO blog called Candid CIO that is written by Will Wieder, CIO of Ministry Health Care. Six years later he’s still my favorite hospital CIO blogger out there. My only complaint is that he doesn’t blog enough (understandably so). I’ve never had a chance to meet Will in person, but I hope to one day have that opportunity.

Will recently commented on one of my posts. After seeing his comment I had the genius idea to ask him for an interview. I’m not sure why I hadn’t thought of it before since we go so far back, but when you see the content of the interview you’ll see why I’m planning to reach out to more CIOs. I hope you enjoy Will’s comments as much as I did.

You have a great CIO blog at CandidCIO.com, what made you start blogging and why do you continue blogging today?
Thanks. I originally started the blog for two reasons. Firstly, I follow tech trends and like to try anything that is emerging. So, I started this blog a long time ago. Secondly, I always desired an outlet where I could express my views of healthcare IT. At the time I started the blog a lot of the HIT press was driving me crazy with superficial stories that didn’t explore difficult questions. One would get the impression that every single IT project ever started was a worthwhile success. So, I wanted to be able to challenge conventional wisdom.

Today there are many great blogs and thousands of voices on Twitter.

Do you think other CIO’s should blog?
I hope that they do, because we have a lot to learn from each other. But it does take time, I have found it impossible to post consistently these days. I am big fan of tech blogger, John Gruber. His posts are almost always two or three sentences. I used to always write long posts. Recently I am mostly writing shorter posts that matches what I would like to read, given my attention span.

How do you deal with the challenge of a blog and Twitter account making you “too” accessible as a CIO?
People generally respect boundaries. Part of my life is to ignore cold callers (unless they are serendipitously offering something on my priority list), I would love to get back to every person that wants to meet me for lunch and talk about my organization’s prioirites, but there isn’t enough time in the day to respond – let alone have all those meetings. I have met a lot of great people on Twitter and I have hired a few, all of those have turned out great.

What’s the biggest issue on your plate as a hospital CIO today?
Managing demand. The best part of being a health care CIO is that there are so many great new solutions that solve business problems, especially in the clinical arena. The worst part is that everybody wants those solutions and they want them now. Even if senior management makes some hard decisions about priorities, the managers that submitted projects that didn’t make the priority list are disappointed and frustrated. I would feel the same way (and do feel the same way when my projects don’t make the cut).

What are the top 3 hospital CIO issues you can see on the horizon?
1. Hone project management so projects are done more quickly and successfully (see above)
2. Security
3. IT Operations – as our doctors and nurses become increasingly more dependent on IT we need to improve our processes that drive system availability and response time.
4. Consumerization of enterprise IT (rise of the iPads)

How has meaningful use impacted your hospital for good and bad?
I have heard a lot of people state that Meaningful Use was a clinical project and that they expected the results to be really meaningful. That wasn’t our experience. We were already working on meaningful clinical IT projects. Much of the objectives were things we had done or started. Our focus was to stay the course and make a few modifications so we hit every objective as written.

Our internal customers (our management team, physicians, nurses, etc.) would probably say that Stage 1 Meaningful Use has been a non-event for them. I like to think that is a testament to the many things that we were doing right. For example, our hospital in Weston, WI is all-digital. There are no charts on the floor; there is not even a file room. It is the only Wisconsin hospital (except a Children’s Hospital) recognized by Leapfrog Group as having fully met the CPOE leap. So, Meaningful Use was mostly about taking the time to properly measure everything and create quality measures to the appropriate specification.

Do you follow the All in One or Best of Breed software approach and why?
I would have to describe us as a Best of Breed IT organization. Many of our admissions come from Marshfield Clinic doctors. The Marshfield Clinic developed their own EHR and have been perfecting it over the last 20 years. About 5 years ago we made the decision to use the Marshfield Clinic EHR in our Ministry clinics and to interface that EHR to our hospitals.

Sharing that EHR was in the best interest of our patients. Our primary care doctors, our hospitals and Marshfield Clinic specialists are all contributing to a common patient record. Once we made that decision for our patients, it was no longer possible to have an All in One solution (Marshfield Clinic does not have a Hospital Information System).

If you could snap your fingers and change one thing about healthcare, what would it be?
Reduce costs. Quality improves year over year as medical knowledge increases, processes improve and new technologies (including information technologies) evolve. But the cost here in the US continues to skyrocket (18% of GDP, double that of the second most expensive industrialized nation). Frustratingly, there isn’t even agreement on why the cost is increasing. I want healthcare to be affordable to the working families here in Wisconsin.

Are you seeing and experience an experienced health IT staff shortage? How do you suggest people without healthcare experience get a health IT job?
More so in the technical areas where we are competing with all industries. We are able to recruit and/or develop applications analyst.

What’s your most important IT project today?
Ministry Health Care was traditionally a less consolidated organization that had 7 or 8 different IT departments. As a result of that we still have a lot of fragmented systems, 740 different applications running on 1,500 servers. Our environment is too complex and it makes us too inefficient. We have plans to greatly simplify that environment. But, it will take us several years and scores of projects to get there. This is paramount to our competitiveness.

From a more short-term perspective this ICD-10 thing is a complicated beast that must go well. After looking at the cost for our organization, and then extrapolating that to the entire industry, I don’t see how the money spent will be worth the value received.

Which IT project doesn’t get enough attention and why?
The need to abandon Windows XP by the time Microsoft ends support in April of 2014 is a ticking time bomb and I am not hearing anyone talk about it. We will spend more time and money (about $5M) on this than we spent working on Stage 1 of Meaningful Use.

Any final thoughts?
Two things: Firstly, I have a great job and I work with incredible people in IT and throughout Ministry. Secondly, the Packers are going to win the Super Bowl this year.

John’s Note: I’ll forgive him for his Packer fandom which is understandable for where he lives. Personally I just hope my Dolphins can turn things around.

Multi-Site Providers Who Don’t Have Certified EHR in All Locations – Meaningful Use Monday

Written by: Lynn

A reader asked how a physician meets meaningful use when some of his encounters occur at a nursing home where there is no certified EHR. Specifically, she wanted to know if the physician was expected to bring his own EHR (hardware and software) to the facility to document encounters there. The answer is “no”—he limits his reporting to encounters that take place in the clinic setting.

A somewhat similar situation is faced by physicians who are affiliated with two (or more) different practices, where not all of the practices(s) are equipped with certified ambulatory EHR technology. In this case, the physician reports on the encounters where a certified EHR is available. The only caveat is that to be eligible for an EHR incentive, the physician must have at least 50% of his encounters at location(s) that do have a certified EHR.

If you have other questions you’d like answered about meaningful use or the EHR incentive money. Please send in your question on our contact us page.

Medicare EHR Attestation When Switching Practices Mid-Year – Meaningful Use Monday

Written by: Lynn

This week’s post will answer a Medicare question posed by a reader in response to Jessica’s post last week on Medicaid EHR Attestation with Multiple Practices. The reader asked about a physician who switches from one practice to another in the middle of year 2, but the answer below would also apply to a physician who works part-time at two (or more) practices.

“What about a Medicare EP who successfully attested for year one with her former employer and now works with us. Neither employer has enough information to report a full 12 months of info for her. Do we still attest for year two and fail it all or can we skip a year? And is it ok for the first employer to receive the first payment and we claim the rest? So complicated! Thanks for any input/help!!!”

Although the situation does make it more complex to attest, it does not mean that she cannot earn an EHR incentive this year. Incentives are tied to the physician—not the group—via the physician’s individual NPI number, regardless of whether the payment was made directly to the physician or assigned to the group. Therefore, even if the physician assigned payment to his former group last year, it is perfectly acceptable for her to assign payment to her new group this year.

A physician who successfully attested and earned an EHR incentive in 2011 must report for the full calendar year in 2012 in order to earn the second payment. However, the information does not have to come from just one practice for the entire year. As long as the physician uses a certified EHR at both practices, she would simply have to report on all of the meaningful use requirements with data from both practices, combining the numerators and denominators for each measure when attesting. (For an explanation of how to report, see read CMS’s FAQ #3609.) She would also have to enter both EHRs into the CHPL website and generate a different Certification ID Number.

If for some reason, the physician does not elect to pursue the 2012 incentive, there is no need to attest and fail this year. She can simply forego the second payment and start again with the third year’s incentive next January.

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June 25, 2012 I Written By Lynn

Filed Under: ARRA EHR Electronic Health Record Electronic Medical Record EMR HealthCare IT HITECH

Tags:ARRA CMS EHR Incentive EHR Stimulus EMR Incentive EMR Stimulus HHS HIE HITECH Lynn Scheps Meaningful Use Meaningful Use Monday Meaningful Use Stage 1

Understanding Meaningful Use Stage 1 and Stage 2 Deadlines – Meaningful Use Monday

Written by: John Lynn

The following is a guest blog post by Zubin Emsley, CEO of ChartLogic, Inc. I think readers will find this post by Zubin quite interesting. He brings up some important points, makes some strong assertions, and even makes some daring projections. I look forward to more discussion of the post in the comments. Are we at “the tipping point?”

With all the controversy surrounding the CMS’s proposed Meaningful Use Stage 2 requirements, it is easy to forget that the clock is ticking on the Stage 1 requirements. Physicians who have not yet qualified for the Stage 1 incentives are at risk of leaving $5,000 of incentives on the table if they don’t get started immediately.

The comment period on the proposed Stage 2 rules is now closed and the CMS is expected to incorporate the comments and issue final rules around August 1. The Stage 2 program is currently scheduled to take effect for eligible providers on Jan. 1, 2014; however, there is a good chance this date will be pushed back.

Physicians who want to qualify for the full, five-years’ worth of meaningful use incentives ($44,000 total) must register, adopt a certified EHR system and submit 90-days’ worth of data by Jan. 1, 2013. That means your practice must have incorporated your EHR system into its workflow and be collecting the needed data sets by Oct. 3, 2012.

Since most medical groups need several months to select an EHR vendor, get their new system installed, and get physicians and staff trained, that means time is running out for those who have postponed a decision.

If you miss this year’s deadline, you may still participate in MU Stage 1 next year (2013); however, you will only be eligible for four years of payments ($39,000 total). Those who wait until 2014 to qualify will only be eligible for $24,000 in payments.

We have reached “the tipping point” in terms of EHR adoption. Penalties for failing to e-prescribe began this year, and in 2014 and 2015, physicians will face mounting financial penalties from Medicare and Medicaid if they don’t adopt an EHR. Commercial insurers are also adopting various kinds of accountable care programs that require submission of clinical data. Within five years, the only way a physician practice will be able to operate without an EHR would be if it moved to an all-cash, concierge type model.

Zubin Emsley is chief executive officer of ChartLogic, Inc., a national EHR vendor based in Salt Lake City. For more information see www.chartlogic.com

Meaningful Use Stage 1: What Do the Statistics Show?

Written by: Lynn

CMS recently added a “Data and Reports” section on its website for the EHR Incentive Program, and some interesting information can be found there about meaningful use Stage 1:

Do you want to know whether your competitor(s), or possibly your own personal physician(s), received an EHR incentive for meaningful use? Recipients are listed, alphabetically by state—complete with address and phone number—in a report called Medicare Providers That Have Been Paid Via the EHR Program For Eligible Providers.
As of April, 156,172 EPs have registered for the Medicare EHR Incentives program. Clearly, there’s a big difference between registering and attesting, however. Of these providers, 56,214 (36%) have successfully attested and received incentive payments. Not surprisingly, 43% of these providers are primary care physicians. More detailed data about program participation is available as well.
There are also some raw data files that show how providers performed on each of the individual meaningful use measures. This data—which reveals that EPs often significantly surpassed the required thresholds—is being used as justification for the proposed increases to thresholds for Stage 2. A note of caution: this data comes only from providers who successfully attested, and these first attesters were likely early adopters and therefore experienced users of EHR technology.

CMS updates this data on a regular basis, so if you are interested in the progress of Stage 1 as we wait for the Final Rule on Stage 2, check back to this page periodically.

Comments Submitted on Stage 2: Is the Bar Being Raised Too High? – Meaningful Use Monday

Written by: Lynn

The 60-day comment period on the Proposed Rule for Stage 2 Meaningful Use ends today. If the length and depth of the comments published so far are any indication, CMS will have a lot of reading and thinking to do between now and August, when the Final Rule is expected.

The tone of the comments is somewhat consistent—general support for the direction and spirit of the rule, but concern that the bar is being raised too high, too quickly. One fear is that if providers perceive the requirements to be unachievable or impractical, they could be discouraged from even trying to meet them.

These are some of the common themes that are already emerging:

Although MU Stage 2 was postponed to 2014, the timing is still very challenging. Several groups have already recommended a 90-day reporting period for the first year of MU Stage 2, which would provide for a phasing-in of the increased requirements, similar to MU Stage 1.
Meaningful Use Stage 2 is considerably more complex than Meaningful Use Stage 1, with the introduction of new measures and the addition of sub-components to Stage 1 measures. Many would require physicians and staff to implement new and more complex workflows.
The core and menu structure continues, but the menu options are fewer and would leave many providers with no real choices since several of the menu measures would not apply to their practices.
While increased patient engagement is recognized as an important goal, providers are expressing concern about having their incentives be dependent on actions by patients—actions over which they have no real control. For example, one proposed measure would require that 10% of patients access their information on the physician’s portal, and another that 10% of patients send a secure e-mail message to their physician.
Some measures could have significant cost implications for physicians—for example, there are often costs associated with developing the interfaces necessary to send data to registries and/or HIEs.
Clinical quality measure reporting, described in one set of comments as “daunting,” is eliciting detailed comments. Developing a reasonable set of requirements that are harmonized with other government programs will require a great deal of work.

More to come, as more comments become publicly available.

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May 7, 2012 I Written By Lynn