In a previous Meaningful Use Monday we wrote about a bunch of the Meaningful Use 2011 statistics that were put out by ONC and CMS. I know that my readers love statistics and information about Meaningful Use. Carl Bergman sent me a PDF file that contained some really interesting data on Meaningful Use stage 1 in 2011. The first pages we basically covered in the previous post, but starting on about page 10 or so there are some more detailed numbers.

Take a look at let us know which numbers you find interesting and/or unique.

If you are on of the 355 Eligible Providers who unsuccessfully attested to MU last year, CMS now offers an appeals process for both the Medicare and Medicaid programs. Here’s the section on appeals for EHR Incentive programs:

Starting December 1, 2011, CMS is accepting appeals for eligible professionals and eligible hospitals.

For general questions and for information on how to file an appeal, eligible professionals (EPs), eligible hospitals, critical access hospitals, Medicare Advantage Organizations, and Medicaid eligible hospitals may contact OCSQ’s designated appeal support contractor via the toll free number between 9 a.m. and 5 p.m. EST, Monday through Friday or via email.

1. Toll-free number: 855-796-1515
2. Email: OCSQAppeals@provider-resources.com

The Centers for Medicare & Medicaid Services (CMS), Office of Clinical Standards and Quality (OCSQ) is providing guidance on how to file an appeal.

If you click through to the How to File an Appeal link, it says that the final rule provides guidance and requirements for a Medicaid appeals process, but does not provide an appeals process for the Medicare EHR Incentive program. Although it also says that “CMS is currently implementing an appeals process for the EHR Incentive Program.”

It does also say that Provider Resources, Inc. (PRI) located in Erie, Pennsylvania was awarded the contract to handle the appeals process with the Office of Clinical Standards and Quality (OCSQ) overseeing the EHR incentive appeals process. Otherwise, it’s still pretty vague on the exact details of the appeals process other than the contact info.

I’ve read that beginning in February, appeal decisions will be posted on CMS’s Website under the Office of Clinical Standards and Quality. I hope that there’s some really good transparency in these postings so that those attesting to meaningful use in the future will be able to learn from people’s past mistakes.

If you’re someone that was denied and is going through the appeals process, I’d be interested to hear about your experience so we can share it with others that will need to do the same.

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.

Many physicians will be pursuing EHR incentives in 2012. Because meaningful use is not dependent upon G-codes, providers have been asking whether they need to continue putting “G-8553” on Medicare claims. The answer is YES—keep on G-Coding! 

Even though physicians who receive a Medicare EHR incentive are ineligible for an ePrescribing (MIPPA) incentive, they are still subject to future ePrescribing penalties. These penalties can be avoided by ePrescribing in 2012:

• Prevent the 2013 (1.5%) penalty – CMS is giving providers a second chance. If you failed to ePrescribe on the minimum 25 Medicare encounters in 2011, (which would have already protected you from the 2013 penalty), report G-8553 10 times between January 1 and June 30, 2012 on any Medicare claims. These claims don’t even have to be for the specified CPT “denominator” codes.
• Prevent the 2014 (2%) penalty – Report the G-code 25 times between January 1 and December 31, 2012. These claims must be associated with the specified CPT codes (typically E&M visits). 

If you are not pursuing meaningful use in 2012—or if you are, but for some reason fail to earn the incentive this year—you can still earn a 1% ePrescribing bonus under MIPPA if you report the G-Code on claims with the specified CPT codes 25 times between January and December . 

Like last year, there will be a process for requesting an exemption from the 2013 penalties, but surprisingly, the Proposed Rule did not include earning an EHR incentive as one of the justifications.

HITECH Answers recently posted a great post that gives a run down of the EHR Incentive program’s progress in 2011. Here’s their list with my own analysis and commentary of each point.

123,921 Eligible Professionals have registered for EHR Incentives, 15,255 have successfully attested to meaningful use in the Medicare program.
This seems like such a HUGE difference in numbers. That’s just over 12% of Eligible Professionals that registered attested to meaningful use. Does this mean that we’re going to see a tidal wave of meaningful use attestation in 2012? Possibly.

I believe that we’ll see more eligible professionals attesting to meaningful use in 2012. However, the question is how many of those other 108,666 will attest to meaningful use in 2012 and how many are like the Happy EMR Doctor who just registered to see the MU process. I wonder how many first hand meaningful use experiences by doctors will scare doctors away from MU attestation.

3.077 Eligible Hospitals have registered EHR Incentives and 604 of those have successfully attested to meaningful use.
This is almost 20% of hospitals that have registered that have attested to meaningful use. It’s not surprising that this number is a lot higher than eligible professionals. I still believe that the wave of meaningful use attestation will come from these other 2473 hospitals and probably many more that still haven’t registered. I haven’t seen a good number of how many hospitals are in the US. Does anyone know that number? The EHR incentive money that goes to hospitals will dwarf those of eligible professionals.

$2,533,689,145 has been paid out in Medicare and Medicaid Incentives.
$2.5 billion sent out in 2011. I just went back to the first time I tagged meaningful use on this site on April 3, 2009 (coincidentally I have 19 pages of 10 posts each tagged with Meaningful Use). Amazing to think that it’s taken basically 3 years to spend $2.5 billion on EHR.

277 hospitals have received payments under both Medicare and Medicaid and of those 12 were CAHs.
That’s about half of the hospitals that have attested to meaningful use under Medicare are also getting the Medicaid EHR incentive money as well.

22% of eligible professionals that have been paid EHR incentives are Family Practitioners and 20% are Internal Medicine.
I must admit that I would have thought that the percentage of family doctors that got paid EHR incentive money would have been a lot higher. I guess when you have so many other specialty areas I shouldn’t be that surprised. I also wonder why the internal medicine number is so high. These numbers actually make me believe that a lot of family practice doctors are sitting out when it comes to meaningful use.

41 States Medicaid programs were open for registration. Two additional States launched in January of 2012.
I wonder what’s holding back the other 7 states. From what I’ve seen all the states will eventually get there.

More than 1500 EHR products have been certified by ONC-ATCBs.
That’s a lot of EHR software. I still put the EHR company list at about 300 EHR vendors. 1500 includes multiple versions of the same software, partial EHR certification for products like data warehouses, ePrescribing, etc. The best thing that’s come from the ONC-ATCB program is that it has made EHR certification basically irrelevant in the EHR selection process. Every EHR vendor is certified now. This is much better than the false assurances that EHR certification provided before. I still dislike what EHR certification has done to the industry, but at least it’s not misleading doctors the same way it was before.

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.

Having just experienced the attestation process firsthand as I watched an SRS client successfully attest to meaningful use, I am happy to report that this part of demonstrating meaningful use is relatively easy—a bit tedious if you are attesting for multiple providers, but not at all difficult. CMS has created a user-friendly, web-based attestation system. Assuming that your EHR provides the information you need in a useful format, you have successfully met all the required measures, and you come prepared, there should be no reason to have an unsuccessful attestation.

Here are some tips that will ensure your success:

• Register in advance: Even though you can register as late as at the time of attestation, the combined task would be overwhelming—particularly if you are attesting “on behalf of” a provider. Registering in advance ensures that everything is up-to-date in NPPES and PECOS and that you have all the necessary information.
• Make sure that all measures have been met: If your EHR does not show the percentages for measures that have thresholds, do the math yourself to verify your success on each one. CMS offers a worksheet that you might find helpful for this purpose. Verify that you have also met all other (non-numerical) measures. If you fail to satisfy even one measure, do not attest now—go back and try another reporting period.
• Have documentation for each provider:
  - Registration confirmation page with registration ID#

  - Password

  - EHR certification number

  - Reporting period dates (make sure it covers at least 90 days)

  - Printout of all meaningful use measures: numerators and denominators, exclusions and reasons

    (when there is more than one possible reason)

  - Clinical Quality Measure report: numerators, denominators, exclusions

• Do not hit “Submit” until you have reviewed the “Attestation Summary” page: Double check your data. Make sure that you have said “yes” to all yes/no measures and that your numbers are entered accurately. The summary page does not display percentages, so you have to do the math yourself to be sure that you meet the thresholds.
• Submit attestation and print the “Submission Receipt” as confirmation: If you have done everything correctly it will state that “all measures are accepted and meet MU minimum standards.”

While not necessary, I highly recommend having a second person help you attest. A second set of eyes will shorten the time the process takes and will reduce the potential for errors in posting your data.

A couple quick tweets to welcome your new week. Both tweets stand on their own and link to some good reads for those interested in the topics. The second one is particularly good since it’s John Halamka’s 2011 wrap up across all the various parts of John Halamka’s life. Let me know what you think of both reads.

Very good guidance on accounting and reporting for #EHR incentive payments bit.ly/xuX9Un

— Brian Ahier (@ahier) January 7, 2012

Healthcare CIO on 2011: #EHRs…added features for certification resulting in…lack of #usability & #workflow integration ehr.bz/lv

— Charles Webster, MD (@c_wb) January 2, 2012

I have to admit, I’ve really enjoyed going through and making lists looking back on EMR and Health IT in 2011 and thinking about what is going to happen in EMR and Health IT in 2012. Thanks for everyone who has joined and added to the discussion. It’s been really great!

This next list might actually be the hardest one for me to create. I call it the 2012 EHR and Health IT Noise. You know what I’m talking about. The topics that are going to get talked to death, tweeted everywhere, but won’t really have any major impact on healthcare (at least in 2012). Some would call these distractions.

HIE – Yes, we’re going to hear more and more about HIE’s and their potential. 2012 will still enjoy all that federal grant money that was given to HIE’s. What will we see from it? Maybe a couple books describing lessons learned from all the money spent on trying to set up an HIE. If one or two HIE’s are successful and start sharing patient data with doctors I’ll be really impressed.

EHR Usability – In 2012 I predict we’re going to hear story after story about the lack of usability with EHR software. The complaints will start to pile up, but I don’t think any of that noise will do much to shift the usability of EHR software. It’s a really hard task to dramatically shift the usability of EHR software after the fact. I can’t see many of the legacy EHR accomplishing that shift.

Some new EMR startups may start to come into their own in 2012 with usable EHR software, but they likely won’t be heard above the noise of the other legacy EHR software that’s practically unusable. We’re in a selling spree cycle for EHR software, maybe 2013 will change that.

Mobile Health Apps – This is a little different noise than the others above. This will be noise because there will be so many mobile health apps out there in 2012 and none of them will really consolidate market share yet. I believe that a number of mobile health apps will start to differentiate themselves in 2012, but most people won’t know the difference. They’ll just hear all the noise and try and ignore it.

Meaningful Use – Oh wait, I already wrote about that one here. If you haven’t read the comments of that post, you should. Some good discussion.

Any other things you think will make noise in EMR and Health IT in 2012? I’d love to hear your additions.

As I said in my previous EMR and Health IT in 2012 post, I’m going to create some of my own lists for 2012. I decided to tackle the first one on the list: My 2012 EMR and Health IT Wish List. This was kind of fun to think about. I’m also sure that I’ll come up with other ideas once this is posted, so don’t be surprised if I add things to this list in a future post.

I should also note that I’m not sure any of these things are going to happen in 2012. In fact, I bet that many of them aren’t, but this list isn’t about what is going to happen. This list is about what I wish would happen.

EHR Companies Would Embrace Interoperability – It’s an incredible shame that in 2012 we still don’t have interoperable health records. EHR companies need to get off the stump and make this a reality. The technology is already there and has been there for a while. EHR companies need to start making this dead simple because it’s the right thing to do. Sometimes doing the right thing is more important than the bottom line. Plus, doing the right thing ends up often being the best long term strategy for your bottom line as well.

Start doing what’s right and making your EHR interoperable!

Meaningful Use Would Go Away – I’m actually certain that this one won’t be happening in 2012, but I wish it would. I guess there’s a small chance that it could go away if Republicans take control of Washington and start slashing everything Obama related. However, I have a feeling that even then meaningful use will find its way back into Washington. There’s too much invested in it.

My reasoning for wanting meaningful use gone is clear. It provides a perverse incentive to providers and often incentivizes them to choose an EHR software that doesn’t work well for their practice. As I’ve mentioned in some recent posts, far too many clinics are so focused on meaningful use and EHR incentive money that they’re ignoring the real and tangible business cases for implementing an EHR in their clinic. I think this is a bad thing for healthcare and EHR software in general. The short term bump in EHR adoption won’t be worth the cost of EHR implementations focused on the wrong criteria.

I also really hate how meaningful use has hijacked the software development cycle of pretty much every EHR vendor out there. This is a real travesty since rather than developing for user/customer requirements EHR vendors are developing for a criteria. Talk about a perfect method for destroying innovation. This is a real travesty in my opinion.

Of course, I’m a realist and realize that meaningful use isn’t going away. We have to make the most with what we’re given and live with the realities that exist. However, in this New Year Wish list, I wish that meaningful use would be a past memory.

New Healthcare Model that Provides Care, Not Reimbursement – I’m sure many of you might be thinking that I’m calling for ACO’s in this wish list item. We’ll see how ACO’s evolve, but my gut tells me that the ACO model still won’t make the fundamental change that I wish would happen in healthcare. There’s far too much focus on reimbursement the way our healthcare is structured today. I’m not arguing that doctors and other healthcare professionals not get paid what they deserve. I’m just wishing that there was more focus on care for patients and less worry on maximizing the reimbursement.

How does this have to do with health IT and EHR? I’ve long argued that the biggest bane to EHR systems is the onerous reimbursement requirements. I can’t imagine how much healthcare could benefit from fabulous EHR systems if the energy spent on maximizing reimbursement were spent on improving patient care.

Diabetes Prevention App – I’ll admit that this is a little personal. I come from a long line of diabetes in the genes and I love sweets far too much. I’m pretty much destine to be a diabetic. I think that mHealth apps can have amazing power if done correctly. My wish is for someone to create a Diabetes app that will help me overcome the seeming destiny I have in this regard. The key will probably be illustrating in a profound way the impact of the choices I’m making.

Of course, you could insert hundreds of other chronic illnesses into this wish list too. I’d love to see mobile health work to solve those as well.

A True Patient Identifier – I realize that America is a large place, but we’re also a really creative country that can figure out creative solutions to problems. The lack of a true patient identifier is a challenge and a problem in healthcare. I’d love to see this problem finally resolved. I think every EHR company would rejoice at this as well.

Real EMR Differentiation – My heart absolutely goes out to doctors, practice managers and others who have the unenviable job of trying to sift through the 300+ EMR companies. I’d love for some EMR companies to really do something so innovative to differentiate themselves from the rest of the pack.

No doubt part of this problem is what I stated above about meaningful use. Hard to create innovation and differentiation in EHR when you have to develop for a government list of requirements.

EHR Data Liberation – I’ve wanted EHR data Liberation for a long time, but I think in 2012 this is one thing on the list that could become a reality. It’s a bit of a long shot, but I think there’s potential for this to happen.

My gut tells me that if we can find a way to liberate the data that’s stored in EHR software, then we’d see a dramatic increase in adoption of EHR. One of the major concerns doctors have with selecting an EHR is that once they select an EHR they know they’re locked in with that EHR for the long run. If a doctor knew that they could switch EHR software if they made a bad choice, then they’d be much more likely to pull the trigger on EHR adoption.

We need a wave of EHR vendors that aren’t afraid of liberating their EHR data, because they:
1. Know that their EHR software is so good users won’t leave
2. Know that if someone wants to leave their EHR software it’s better that they find one that’s good for them than the few extra dollars the EHR company will make off an unhappy user.

How’s that for a wish list? I think achieving these things would do an amazing amount of good in healthcare and EHR. Of course, I won’t be holding my breathe on any of them happening any time soon. That doesn’t mean I won’t keep holding out hope.

I was asked by Practice Fusion to provide them some Health IT and EHR predictions for 2012. Here’s what I sent them:

“Next year will be all about Meaningful Use: Meaningful Use, ACOs, Meaningful Use, ICD-10, Meaningful Use, Meaningful Use, 5010, and a little more Meaningful Use covered in Meaningful Use.”

Sadly, I think this is a summary of what we can expect over the next year. Yes, it’s sad for me to predict that we’re going to be so mired in government requirements in 2012 that it is really hard to predict anything else really breaking significantly into the conversation in 2012.

As I ponder this New Year, I think my off the cuff (almost sarcastic) response above is actually going to be a pretty solid 2012 EHR and health IT prediction. However, that doesn’t mean it’s what I want to have happen and that doesn’t mean that other things won’t be happening. As such, over the next week or so I’m going to do a series of posts covering the following areas:

- My 2012 EMR and Health IT Wish List (things I wish would happen)
- Predictions on EHR adoption in 2012
- 2012 EHR and Health IT Noise (things that will make a noise, but have little impact)

If you have other topics you think I should cover, I’d love to hear any other ideas you have. If I have something of value to offer, then I’ll be happy to add it to my list. Should be a fun week prognosticating about the future of EHR and health IT. I hope you’ll join me in the comments with your own commentary on what we should expect and I invite other bloggers to do similar posts around these topics.

Next up in our evaluation of the various end of 2011 Health IT lists series is one that takes a bit of a look back at 2011. In this list, PwC lists what they consider the Top Health Industry Issues of 2011. The list starts with an interesting comment about the health IT spending in 2011:

More than $88.6 billion was spent by providers in 2010 on developing and implementing electronic health records (EHRs), health information exchanges (HIEs) and other initiatives. This surge is a sign of technology’s critical place in health system improvement.

$88.6 billion is a lot of health IT spending and larger than most numbers I’ve seen. Although, most numbers I’ve seen are only the EMR and EHR market and doesn’t include HIE spending and other healthcare IT initiatives. It’s quite clear that the health IT spending is up, and up Big!

Their list of top Health issues isn’t that surprising, except possibly one of them:

Meaningful Use – This has to be topic number one for health IT in 2011. It’s had a trans formative effect on healthcare IT and EMR and EHR as we know them. Pretty much every EHR vendor I’ve talked to basically had to take an entire software development life cycle to meet the meaningful use and certified EHR requirements. This is the dramatic effect of meaningful use on EHR development.

PwC actually focuses on how meaningful use will encourage patient participation in their healthcare or “shared medical decision-making.” To be honest, I’m not sure meaningful use has done much to help this goal, yet(?). Possibly meaningful use stage 2 and meaningful use stage 3 will help to further these goals. MU stage 1 has done little to encourage this. Regardless of the impact of meaningful use, shared medical decision-making is going forward fast and furious.

HIPAA 5010 and ICD-10 – The interesting issue for 5010 and ICD-10 is that they’ve basically been overwhelmed by meaningful use and EHR incentive money. Either of these changes alone would have been a reasonable challenge for a normal year. However, clinical organizations are battling through 5010, ICD-10 and meaningful use all at the same time. Are there any other IT projects going on that don’t involved these three things? I’d say probably very few.

Electronic medical device reporting (eMDR) – I found this point quite interesting. There’s been a lot of movement in 2011 in regards to what constitutes a medical device and who should take care of tracking and collecting the adverse events that occur on these devices. I don’t think we’ve come to a final conclusion on what will be considered a medical device and how we’re going to deal with reporting adverse events, but finally getting electronic reporting of adverse events is a good step in the right direction.

Be sure to read the rest of my Health IT Top 10 as they’re posted.