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EHR Certification Flexibility Final Rule Commentary and Analysis

Posted on September 3, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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 news came out late on Friday that the EHR Certification flexibility was published as a final rule. I covered my initial take on the EHR Certification Flexibility on Hospital EMR and EHR. I’ve now had a chance to dig through the delicious 90 pages of government rule making and comments that make up the final rule. For those following along at home, you can skip to page 10 of the document to start the fun read. Although, I’ll also direct you to specific sections that might be of interest to you below.

In this post, I’ll just cover the EHR certification flexibility. You can see the meaningful use extension and delay timelines here. Here’s the important chart when talking about the EHR Certification flexibility (CMS Calls it CEHRT):
2014 EHR Certification Flexibility - CEHRT

The EHR Certification flexibility has a number of major talking points:

  • What Does “unable to fully implement” and “2014 Edition CEHRT availability delays” mean?
  • Fairness of EHR Certification Flexibility
  • 90 Day Reporting Period in 2015 Instead of 365 Days
  • Future Audits

What Does “unable to fully implement” and “2014 Edition CEHRT availability delays” mean?
On page 62 of the rule is the best description of the rule’s intent. It says that if you want to take advantage of this EHR flexibility, then they (Eligible providers or hospitals) “must attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to the meaningful use objectives and measures.” This basically covers the asterisk in the chart above.

This piece of the rule was so unclear that CMS in the final rule used 12 pages (pg. 36-48) to describe when this rule would apply and when it would not apply. CMS tried to make this apply as broadly as possible, but I think they also wanted to encourage as many organizations as possible to not use the exception.

My short summary of these 12 pages is: If you have the 2014 Certified EHR software and can attest to meaningful use stage 2, then you better go ahead and do it. Trying to find a loophole that allows you to avoid meaningful use stage 2 and just do MU stage 1 puts you at risk during a future meaningful use audit.

Of course, if you’re EHR vendor hasn’t provided you the proper software/updates/training, etc that you require to attest to meaningful use stage 2, then this rule will apply. CMS’ intent seems pretty clear. If you can attest to meaningful use stage 2, then you should. However, if your EHR vendor prevents you from being able to attest, then they don’t want to hold the providers accountable for the EHR vendors failure. Although, CMS notes multiple times in the final rule that they don’t want to point blame at the EHR vendors since it could have been other outside issues (ie. final rule was late, ONC-ACB’s were backlogged, etc) that caused the EHR vendors to not be ready.

I wonder if one of the unintended side effects of this rule will be EHR vendors taking their sweet time releasing and rolling out their 2014 Certified EHR product and updates. It’s too late for this in the hospital setting since hospitals have to do a full year of MU 2 on a 2014 Certified EHR starting October 1, 2014. However, the same might not be true on the ambulatory side where they have until the end of the year to start on meaningful use stage 2.

I’ll be interested to see how many organizations are able to take advantage of this delay. Had this rule been finalized in early 2014, it would be a very different story. However, at this late date, I’m not sure that many providers or hospitals will be able to change course.

I mostly feel bad for those organizations that rushed their EHR implementations onto barely-beta-tested 2014 Certified EHR software and will now have no choice but to go forward with meaningful use stage 2. This change in rule makes many of these organizations wish they’d slowed their implementation to make sure they’d done it right and they’d have also only been required to do MU stage 1.

Fairness of EHR Certification Flexibility
The last paragraph above highlights part of the reason why many providers feel that this EHR certification flexibility is unfair. While it’s not a direct penalty on organizations that were on top of things, the change rewards those organizations that didn’t take the risks, push their EHR vendors, and push their implementation timelines to meet the MU stage 2 requirements. The reward an organization gets for going after MU stage 2 is that they have to do a lot more work (Yes, MU2 is A LOT more work) while their procrastinating competitors get to do the much simpler MU1.

This was such an important complaint that CMS addressed these comments in two different places in the final rule (pg. 21-22 and pg. 48-50). CMS tries to argue that in their research they didn’t see providers that were deliberately trying to delay MU stage 2, but found that providers wanted to do MU stage 2, but their EHR vendors weren’t ready. I’d suggest that CMS may want to dig a little deeper.

However, let’s set providers aside for now and assume that they all want to do MU stage 2, but their EHR vendors just aren’t ready for it. This EHR certification flexibility still lets EHR vendors who procrastinated their 2014 EHR certification off the hook. In fact, it rewards them and their users for not performing well. Once again, CMS doesn’t want to point the finger at EHR vendors, but will blame themselves for not finalizing the rule fast enough and ONC-ACB’s for having a backlog. However, if you’re an EHR vendor who’s been 2014 Certified for a while now, no doubt this rule makes you angry since it rewards your competitors in a big way (intended or otherwise).

Certainly there are a lot of reasons why an EHR vendor isn’t yet ready to be 2014 Certified. However, most of them have little to do with the rule making process and the EHR certification backlog. Some freely admit it, and others hide behind excuses. I think CMS realized this EHR Certification flexibility would benefit these EHR vendors, but they didn’t want to punish the providers who use these EHR software.

I still think the simple solution here was to extend this same flexibility to all providers and all EHR vendors. However, in the final rule CMS argues that doing so would reduced the amount of meaningful use stage 2 data that they’d have available to make the adjustments needed to meaningful use stage 3. I understand how a provider doing MU stage 2 this year might feel like the government’s guinea pig. We need you to do MU stage 2 so we can figure out how to make it right in MU stage 3. CMS also argues that they need more people on meaningful use stage 2 in order to push their agenda and the intent of the HITECH act forward. What doesn’t seem aligned to me is the goals of meaningful use and providers’ goals. I think that’s why we see such a disconnect.

90 Day Reporting Period in 2015 Instead of 365 Days
This seems to be one of the most heated discussion points with the final rule. CHIME President and CEO, Russell P. Branzell, even suggested that “Now, the very future of Meaningful Use is in question.”

CMS’ comments about this (pg. 34-36) basically say that a change to the EHR reporting periods was not part of this proposed rule. Then, they offered this reason for why they’re not considering changes to the reporting periods:

We are not considering changes to the EHR reporting periods for 2015 or subsequent years in this final rule for the same reasons we are not considering changing the edition of CEHRT required for 2015 or subsequent years. Changes to the EHR reporting period would put the forward progress of the program at risk, and cause further delay in implementing effective health IT infrastructure. In addition, further changes to the reporting period would create further misalignment with the CMS quality reporting programs like PQRS and IQR, which would increase the reporting burden on providers and negatively impact quality reporting data integrity.

What this comment doesn’t seem to consider is what will happen if almost no organizations choose to attest to meaningful use because of the 365 day reporting period. Talk about killing the “forward progress” of the program. From a financial perspective, maybe that’s great for the MU program. CMS will pay out less incentive money and they’ll make back a bunch more money in the eventual penalties. However, it seems counter to the goal of increasing participation in the program. Personally, I’m not sure that the end of organization’s participation in meaningful use would be such a bad thing for healthcare. It would lead back to a more rationale EHR marketplace.

Future Audits
On page 55-56, the final rule addresses the concerns over audits. We can be sure that some organizations will be audited on whether they were “unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays.” Sadly, the final rule doesn’t give any details on what documentation you should keep to illustrate that you meet these requirements for which you will have to attest. The final rule just says that they’ll provide guidance to the auditors on this final rule and that audit determinations are finalized on a case by case basis that will cover the varied circumstances that will exist.

This wouldn’t give me much comfort if I was going through an audit. Not to mention comfort that the auditors wouldn’t interpret something differently. I’ll defer other audit advice to my auditor friends, since I’m not an audit expert. However, in this case you likely know how far you’re stretching the rule or not. That will likely determine how comfortable you’ll be if an audit comes your way. Now you can see why my advice is still, “If you have the 2014 Certified EHR software and can attest to meaningful use stage 2, then you better go ahead and do it.

Conclusion
I really see the meaningful use program on extremely shaky ground. I don’t think this final rule does much to relieve any of that pressure. In fact, in some ways it will solidify people’s bad feelings towards the program. We’ll see for sure how this plays out once we see the final numbers on how many organizations attest to meaningful use stage 2. I don’t think those numbers are going to be pretty and 2015 could even be worse.

Note: For those following along at home (or work), here’s the final rule that I reference above.

Patient Engagement vs. Patient Education: What’s the Difference?

Posted on June 3, 2014 I Written By

The following is a guest blog post by Jamie Verkamp, Chief Speaking Officer at (e)Merge.
Jamie Verkamp
Healthcare organizations often see attesting to the Measures included in Meaningful Use Stage 2 as a burdensome checklist which results in a massive resource drain in exchange for inadequate financial compensation. MU Stage 2 Measure 7 is one such oft-maligned requirement for attestation. This Measure requires that online access to records is provided to 50% of patients and that 5% of patients execute the viewing, download, or transmission of their online health information.  Organizations should not see Measures regarding patient engagement as intimidating or inconvenient. Instead, these Measures seeking to improve patient engagement should be seen as an opportunity to create more loyal, involved, and empowered patients.  The importance of engaging our patients in their own health shows itself in current statistics relating to personal health.  According to a study by TeleVox, roughly 83% of Americans don’t follow treatment plans as prescribed by their physicians.  Adding to that, 42% of Americans feel they would be more likely to follow their care plan if they received some form of motivation to participate.  By giving patients a channel to monitor and participate in their own health, organizations can develop a more educated population capable of producing greater outcomes.

Understanding the reasoning behind the Measures driving patient engagement is the first step; now, we must educate our patient population on the value of logging in and connecting with their information. While the frequency of patients physically visiting their provider’s office is somewhat inconsistent, this is often the most successful way to encourage electronic patient access. Patient facing staff members should be well educated on electronic patient access and be prepared to answer questions as they arise. Physically walking patients through the engagement process of maneuvering their electronic access, or providing video tutorials with simple instructions in the office lobby can increase patient engagement substantially. Consider setting up a station in the waiting room to allow patients to sign up for the service, thus solving the issue of forgotten motivation.

However, organizations must seek to include in their engagement plan the younger and healthier population who may not enter the physical office space outside of unforeseen emergency visits or more often than their annual checkup requires. Looking online to relate with these patients can be beneficial, as this has been found to be where this demographic spends the majority of their time and communication engaging with brands and services.  Providing information and education on an organization’s website, Facebook, Twitter, or even YouTube page through video promotion can assist in sparking an interest with this patient population.  Many times, those likely to engage in a patient engagement offering remain unaware of its availability due to a lack of communication from the healthcare organization.  From the practice standpoint, we must understand our work is not done once the portal is merely completed; rather this is when the real challenge presents itself.

In today’s society, consumers are bombarded with promotional emails and routinely asked for their contact information so further communication can be established.  With this in mind, consumers are more cautious as to what and how much information they provide to companies.  Unfortunately, for the healthcare industry, this includes a cautious nature toward information shared with healthcare organizations.   With this barrier in place, administrators must actively engage with their patients to educate them on the benefits of becoming involved in electronically managing their care.  Before consumers choose to willingly hand over their personal contact information, they will likely need to understand the reasons for doing so and what advantages they will receive.

Convenience has become one of the most desired aspects of communication and buying behaviors in consumers today.  As a society, we have adopted a “need it now” expectation.  With the ease portable technology has brought to our information search, patients and consumers count on service when they desire it.   This is especially true when it comes to customer service; consumers are becoming less patient and beginning to expect service when they desire.  In a recent study, it was found businesses offering a “Live Chat” option online saw a 15% increase in conversions. Explaining to patients the ease of communication with physicians and key staff members through the portal can be a helpful start in creating buy in.  Communication via the portal includes direct messaging, appointment reminders, and more. Informing patients of potential time saving factors in appointments down the road and quicker access to lab results can also establish and pique interest.  In many instances, finding the optimal moment to address the patient portal can create successful outcomes.  Patients burdened by numerous prescription refill requirements or those frustrated with waiting in line to pay a bill can be directed back to the convenience of a patient portal to handle all of these items at their own computer at home.

As a whole, those looking to meet this Stage 2 requirement must focus their attention on creating personalized communication with patients.  Standardized information will not entice patients and may easily be looked over.  Begin to examine which staff members may be the best fit for providing patient education and focus on educating patients on what they will get out of participating, not just simply meeting your Measure 7 requirements.   Potential touch points can be found within your signage, billing communications, appointment reminders and especially on your practice website and social sites.

According to HealthIT.gov, Meaningful Use Stage 3 will continue with the goal of driving patient engagement and improving outcomes.  This will include, “patient access to self-management tools”. The options for healthcare organizations are clear:

1. An organization can meet the bare minimum for the Stage 2 requirements using a patchwork of initiatives which produce minimally satisfying results while have no significant effect on the patient experience. Then repeat the entire process for the applicable Measures in Stage 3.

2. An organization can have a well-articulated and executable plan. In doing so, the practice, hospital or healthcare organization can commit to utilizing technology for the optimization of patient care, get a full return on investment from the Patient Portal, and simultaneously grow their business through the competitive advantage of a successful online presence. Initiating this push now will further develop readiness for Stage 3 as the implementation date approaches and with productive workflows in place, administrators can free themselves to focus on other Measures for attestation.

So which option will your organization choose? It’s not going to be easy, but change seldom is. Every industry experiences social and digital evolution, now it is healthcare’s turn.

About Jamie Verkamp
This article is a result of a partnership between (e)Merge, a medical growth consulting firm and DataFile Technologies, an outsourced medical records management and compliance company. Jamie Verkamp leads (e)Merge as Managing Partner and Chief Speaking Officer, she works shoulder to shoulder with medical professionals the healthcare industry to improve the patient experience and see measurable growth in clients‘ customer service efforts, referral volumes and bottom lines. DataFile Technologies is led by Janine Akers, CEO. DataFile’s passion for compliance allows them to be thought leaders in HIPAA interpretation while executing innovative medical records workflow solutions on behalf of their clients. Our companies produce white papers, speaking engagements, and videos to keep health professionals up to date on the latest industry topics.

Did Meaningful Use Try to Do Too Much?

Posted on February 12, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

When I was reading Michael Brozino’s post on EMR and EHR about the Value of Meaningful Use, I was hooked in by his comment that meaningful use standards only went halfway. I’m not sure if this was the intent of his comment, but I couldn’t help but sick back and consider if meaningful use missed the mark because it only went half way.

When I think about all of the various features of meaningful use, it really feels to me like ONC and CMS tried to bite off more than they could chew. They tried to be all things to everyone and they ended up being nothing to no one. Ok, that’s not perfectly correct, but is likely pretty close.

Think about all of the meaningful use measures. Which ones go deep enough to really have a deep and lasting impact on healthcare? By having so many measures, they had to water them all down so it wasn’t too much for an organization to adopt. I’m afraid these watered down measures and standards render meaningful use generally meaningless.

Certainly the EHR incentive money has stimulated EHR adoption. However, could this EHR adoption have had even more impact if it would have just focused on two or three major areas instead of dozens of measures with good intentions but little impact?

In many ways, this is just a variation on my wish that EHR incentive money would have focused on EHR interoeprability. As meaningful use stands today, we’ve made steps towards interoperability, but we’re still not there. Could we have achieved interoperability of health records if it had been our sole focus? Instead, we’re collecting smoking status and vital signs which get stored in an EHR and never used by anyone outside of that EHR (and some would argue rarely inside of the EHR).

The good news is we could remedy this situation. ONC and CMS have something called meaningful use stage 3. How amazing would it be if they essentially through out the previous stages and built MU stage 3 on 2-3 major goals? The foundation is there for MU stage 3 to have an enormous impact for good on healthcare, but I don’t think it will have that impact if we keep down the path we’re currently on.

Yes, I realize that a change like this won’t be easy. Yes, I realize that this means that someone’s pet project (or should I say pet measure) is going to get cut. However, wouldn’t we rather have 2-3 really powerful, healthcare changing things implemented than 24 measures that have no little lasting impact? I know I would.

Side Note: Think how we could simplify EHR Certification if there were only 2-3 measures.

What Happened with EMR and Health IT in 2013?

Posted on December 31, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

As we wrap up 2013, I thought I’d take a look back at some of the major things that happened in 2013. They will be topics you’re very familiar with, but hopefully this will tie a nice bow on the top of 2013 as we look towards 2014.

ICD-10 Got Real – There are still many organizations that aren’t focusing on ICD-10 or that are underestimating it, but for the most part I’m seeing a lot of concern around ICD-10. I’ve started a whole series on ICD-10 and as I’ve been preparing posts the impact of ICD-10 is going to be huge. I think people are just starting to realize it and 7-8 months from now there’s going to be a lot of organizations that are going to go into panic mode. Some of the panic they could solve if they started working on ICD-10 today. Some of the panic will likely come from outside vendors who end up not delivering ICD-10 the way they should.

ACO’s Are Still a Mystery – Some of the ACO work from the government is coming into some focus, but that barely feels like an ACO to me. Of course, it’s all how you define an ACO. I mostly see defensive efforts by organizations trying to group and align themselves with other organizations for whatever reimbursement changes come down the pipe. However, I don’t think any of them really know what’s coming (and I don’t claim to know either).

Meaningful Use Stage 2 Hit Us – We got a meaningful use stage 2 extension and a meaningful use stage 3 delay, but we didn’t get what many were hoping would be a meaningful use stage 2 delay. That means organizations have little choice but to proceed with meaningful use stage 2. As I’ve seen more and more organizations get into MU stage 2, I’ve seen two main actions: workarounds and complaints.

I believe the inverse relationship between incentives and requirements is starting to become an issue. It will certainly blow up when the even more challenging meaningful use stage 3 requirements hit and the EHR incentives are gone.

Consolidation (Hospital and Physician Practice) – Everyone tells me private practice acquisition is cyclical and at some point we’ll see a return to independent doctors. However, I haven’t seen that cycle happen yet. All I see our hospitals acquiring practices like crazy. Not to mention hospitals joining together as well. I wonder if the prediction I heard of only 5-10 major health systems will play out.

HIPAA Omnibus Landed (and is mostly forgotten) – HIPAA Omnibus is in place whether a practice likes it or not. Most never realized it went into affect or have forgotten it already. Watch for 2014 to be the year that it starts biting organizations in the backside. Give us 4-5 stories about HIPAA Omnibus making a physician’s life miserable and then we’ll see more people getting HIPAA training, fixing their business associate agreements, and maybe even implementing encryption on their devices. Maybe I should have added this to my 2014 wish list I’ll post tomorrow.

Did I miss anything? Probably. So, let’s hear what I missed in the comments. Also, I made some similar comments with a hospital focus over on Hospital EMR and EHR.

Where Are We At With Meaningful Use?

Posted on December 11, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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 Barry Haitoff, CEO of Medical Management Corporation of America.
Barry Haitoff
It seems like meaningful use is in a constant state of flux with moving deadlines and multiple stages that apply to each organization differently. With meaningful use stage 2 just around the corner for many providers it is worth taking a quick look at where we are on the journey to meaningful use.

Meaningful Use Timelines
The most important thing many organizations need to remember is the various timelines for each meaningful use stage. This can be pretty complex because it changes based on when you first attest to meaningful use. Plus, last Friday CMS announced an extension to meaningful use stage 2 and a delay of meaningful use stage 3 for one year.

Before this recent change, CMS put out the following chart which clearly illustrates how much EHR incentive money a provider will get for showing meaningful use of a certified EHR. Plus, it shows which meaningful use stages you will have to comply with based on the year you started attesting to meaningful use. After the aforementioned announcement, the only change to this chart would be that both meaningful use stage 3’s would become meaningful use stage 2.

Meaningful Use Medicare Incentive Timelines and Stages

The above chart is just for EHR incentive money under Medicare. The chart for Medicaid is much simpler and hasn’t changed much since the EHR incentives were first announced.

Meaningful Use Medicaid Incentive Timelines and Stages

EHR Penalties
While the incentive money for EHR is important for many, it seems like doctors are motivated as much or more by the Medicare adjustments that will be enforced if they aren’t meaningful users of a certified EHR system. Here’s the timeline for the EHR payment adjustments:

Meaningful Use Penalty Schedule

There are a number of hardship exemptions that a provider can claim to avoid the penalties. If you plan to pursue one of these hardship exemptions, you have to apply for one by July 1, 2014. CMS has put out a nice tipsheet covering payment adjustments and hardship exemptions. As you can see, the exemptions are pretty narrow. Although, maybe they’ll create more exemptions over time like they did with the eRX penalties.

Other Notable Meaningful Use Updates
Regardless of what stage of meaningful use you are at or any prior years reporting, all eligible professionals will only have to attest to 90 days of meaningful use in 2014. This change was made to give organizations plenty of time to upgrade to the 2014 certified EHR technology. However, many EHR vendors have taken this extra time into account and are still not 2014 certified because they know eligible providers only have to attest to 90 days in 2014. Anyone attesting to meaningful use regardless of meaningful use stage will have to be on a 2014 certified EHR. The 2011 EHR certification will be expired and not accepted.

It is also worth noting that those who have not begun participation in the Medicare EHR incentive program will need to attest to meaningful use in 2014 if they want to be eligible for any EHR incentive money.

Meaningful Use Audits
If you’ve already attested to meaningful use stage 1, then you better make sure your documentation is in order. Meaningful Use audits have already begun and a number of organizations are getting caught without the proper documentation. This is worth also noting for those planning to attest to meaningful use for the first time. Make sure that you keep all your meaningful use attestation documentation in case you’re ever audited.

The most common audit issue organizations have is with core measure 15 which requires an organization to conduct a security risk analysis. Many organizations checked off this box without actually doing a security risk analysis. That’s a very risky proposition. This is one meaningful use requirement where you can’t rely on your EHR vendor to do it for you. This is not a hard task and many organizations will be happy to come and do one for you. Just make sure you’ve actually done it before you attest.

Medical Management Corporation of America, a leading provider of medical billing services, is a proud sponsor of EMR and HIPAA.

Meaningful Use Stage 2 Extension, MU Stage 3 Delay and New 2015 EHR Edition Certification Proposed

Posted on December 6, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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 big news of the week just came out of CMS at 4 PM EST on a Friday. Feels like they’re trying to bury the news story, but maybe it was just the way the timing worked out. Either way, there’s no way anyone who lives in the EHR and meaningful use would miss the announcement (not to mention I’ve already seen it posted on every major health IT news site). CMS is proposing an extension of meaningful use stage 2 another year through 2016 and so that means a delay in meaningful use stage 3 until 2017.

Here’s how Robert Tagalicod, Director, Office of E-Health Standards and Services, CMS and Jacob Reider, MD, Acting National Coordinator for Health Information Technology, ONC described the change in meaningful use timeline:

Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2. The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.

The phased approach to program participation helps providers move from creating information in Stage 1, to exchanging health information in Stage 2, to focusing on improved outcomes in Stage 3. This approach has allowed us to support an aggressive yet smart transition for providers.

Meaningful Use Stage 2 and 3
This shouldn’t come as a surprise to many. In fact, we’d been discussing the possible meaningful use stage 2 extension in the comments of my post: ICD-10 will be delayed. We thought meaningful use delay was possible, and now it’s happened.

I do like that this delay gives CMS and ONC more breathing room to know what to include in meaningful use stage 3. Plus, maybe they’ll get the MU Stage 3 certification requirements out in plenty of time for EHR vendors to be able to update their software.

One thing that is really interesting about this delay is that meaningful use stage 3 won’t go into effect until after the Medicare EHR incentive money is over. The Medicare EHR incentive money is only scheduled to be paid through 2016. Medicaid wasn’t implementing MU stage 3 until year 6, so I expect there’s no change there. While you won’t have to show MU stage 3 for Medicare EHR incentive money, you will have to attest to meaningful use stage 3 in 2017 if you want to avoid the EHR penalties (Payment Adjustments if you prefer CMS’ terminology). In 2017, those EHR penalties will be at 3%.

Many have called for a delay to meaningful use stage 2 as well, but that didn’t happen today.

2015 Edition EHR Certification
The other part of the CMS announcement is the 2015 Edition EHR certification. They propose having an additional 2015 EHR certification that sounds like it would amount to an update to the 2014 edition. The 2015 edition would fix any issues with the 2014 edition and update any changes to interoperability standards. Sounds like an EHR certification patch.

The catch is that EHR vendors that are 2014 Edition EHR certified wouldn’t have to do 2015 Edition. This is good since we don’t need software vendors having to certify again (as much as certifying bodies would love the new revenue). Although, I won’t be surprised if most EHR vendors take the new standards in the 2015 edition and update their software to those standards. Let’s just hope that if they choose to do so, it doesn’t kill their 2014 Edition EHR certification. We should all be using the latest and greatest standards. Even more important, we need to all be on the same standard.

What do you think of the announcement? I look forward to hearing your thoughts in the comments.

See Also:
HIMSS Response – HIMSS Supports Stage 2 Extension
CHIME Response – Meaningful Use Timeline Shift Does Not Afford Flexibility in 2014

Should We Hit the Pause Button on Meaningful Use?

Posted on August 8, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

I saw this question hit my email this morning: Should We Hit the Pause Button on Meaningful Use?

It’s a controversial question without a really solid answer. A number of organizations have already called for a delay on meaningful use stage 3. They have some reasonable points to be made for why MU stage 3 should be delayed. I won’t be surprised if we see a delay in future stages of meaningful use. ONC won’t want to do it, but I think they’ll be pressured to the point that they see no other option. The government approval process just can’t work fast enough.

However, the idea of pausing meaningful use is a bit different. A delay isn’t necessarily a pause. If you delay MU stage 3, then people are still required to attest to MU stage 2. Some people (including some in congress) are asking if we should pause MU completely. The idea being that we should do an analysis of the impact of MU stage 1 and how we can make MU stage 2 and 3 more effective. The problem with this idea is that many have committed a large investment to their EHR and so pulling out promised EHR incentive money won’t likely happen.

There’s actually a growing voice to stop meaningful use completely. Certainly this will upset plenty of organizations, but I find the discussion of stopping meaningful use incredibly intriguing. Would stopping meaningful use and not paying out any more government money for EHR software have a negative impact on EHR adoption?

That’s a hard question to answer. I imagine there are a few hospitals that have started down the road of EHR adoption that would definitely step on the brakes. I don’t think the same is true in the ambulatory space. Those who’ve started down the path to EHR are already on their way and likely won’t turn back.

I’m sure stopping the meaningful use EHR incentive money would cause quite an uproar. I can’t imagine them doing it, but I think it’s unfortunate that we can’t at least have the conversation. Last I checked we’d spent about $8 billion in EHR incentive money. If the estimated $36 billion is still accurate, that leaves $28 billion of EHR incentive money left. Don’t you think we should at least consider whether we should spend that $28 billion the way we’re doing it?

Meaningful Use Stage 3 Priorities

Posted on March 22, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

In my reading, I came across this message of what the priorities for meaningful use stage 3 should be:

To be considered for Stage 3, objectives must support new models of care, address national health priorities, promote advancement, be achievable and widely adopted by 2016, and be reasonable from a products and organizational perspective.

I thought this was a really interesting statement, because there’s always a lot of discussion about what meaningful use should really accomplish. If you ask someone in healthcare IT what meaningful use is suppose to accomplish, I expect you’d get a different answer from every person that you ask. That’s unfortunate, because if we’re going to spend billions of dollars on this you’d think we’d have a clear vision of what we want to accomplish with that money.

At the end of the day, it’s ONC-CMS-HHS that makes the meaningful use rules and so it doesn’t really matter what we think if they don’t think the same way we do. Plus, unfortunately it’s a really sad minority that actually give feedback during the meaningful use process.

I wonder how many doctors actually gave any sort of feedback to ONC during the meaningful use process. I’m not talking doctors who are now working for some company. I’m talking about practicing doctors who took the time to understand the MU regulations and provided comments on it. The same could be said for hospital C-level executives. I heard of some that copied and pasted their response from their EHR vendor, but how many hospital CIO’s really dug into the regulations and provided comment? The answer is not enough (despite significant effort on ONC’s part to hear from them).

The above statement seems to make ONC’s position clear on what they want to accomplish with meaningful use stage 3. In fact, the priorities listed above seem in line with the actions they’ve taken when it comes to meaningful use and other ONC initiatives. Right, wrong, or otherwise, it’s important to understand where ONC is coming from when they make the final meaningful use rules. Everyone else can say what they want, but they’re not making the rules.

Meaningful Use Stage 3 Retires Measures that Doctors Don’t Do

Posted on February 19, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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 other day I was spending some time going through the proposed meaningful use stage 3 measures. It’s quite an experience if you haven’t done this already.

As I was going through each of the measures I realized something that could be a little troubling. In a number of cases, they are proposing that certain measures should be retired from the meaningful use attestation process because essentially those measures have reached a percentage in meaningful use stage 2 that they’re fully adopted. I think this is generally a good idea. We don’t need clinics and hospitals reporting information just to report information.

Although, I did find a surprising trend when it came to the measures that were being retired in meaningful use stage 3. Almost all of the measures (possibly all, but I didn’t dig that deep) were measures that were done by someone other than the doctor. A few examples were vitals, smoking status, and demographics. I guess in some cases the doctor might enter these, but you can see how the vitals were likely entered by a nurse or MA and not the doctor.

On the one hand this is a really great thing. That means that in the previous meaningful use stages, the biggest burden was placed on someone other than the doctor while the doctor was only required to have a much smaller percentage. Unfortunately this means that the higher percentages required in meaningful use stage 3 put the burden largely on the backs of physicians.

Healthcare Groups Want Meaningful Use Evaluated Before Stage 3

Posted on January 16, 2013 I Written By

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.

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?