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ONC Offers Two Interoperability Measures

Posted on July 14, 2016 I Written By

Anne Zieger 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.

For a while now, it’s been unclear how federal regulators would measure whether the U.S. healthcare system was moving toward the “widespread interoperability” MACRA requires. But the wait is over, and after reviewing a bunch of comments, ONC has come through with some proposals that seem fairly reasonable at first glance.

According to a new blog entry from ONC, the agency has gotten almost 100 comments on how to address interoperability. These recommendations, the agency concluded, fell into four broad categories:

  • Don’t create any significant new reporting burdens for providers
  • Broaden the scope of interoperability measurements to include providers and individuals that are not eligible for Medicare and Medicaid EHR incentives
  • Create measures that examine usage and usefulness of exchanged information, as well as the impact on health outcomes, in addition to measuring the exchange itself
  • Recognize that given the complexity of measuring interoperability, it will take multiple data sources, and that more discussions will be necessary to create an effective model for such measurements

In response, ONC has come up with two core measures which address not only the comments, but also its own analysis and MACRA’s specific definitions of “widespread interoperability.”

  • Measure #1: Proportion of healthcare providers electronically engaging in the following core domains of interoperable exchange of health information: sending; receiving; finding (querying); and integrating information received outside sources.
  • Measure #2: Proportion of healthcare providers who report using information electronically received through outside providers and sources for clinical decision-making.

To measure these activities, ONC expects to be able to draw on existing national surveys of hospitals and office-based physicians. These include the American Hospital Association’s AHA Information Technology Supplement Survey and the CDC National Center for Health Statistics’ annual National Electronic Health Record Survey of office-based physicians.

The reasons ONC would like to use these data sources include that they are not limited to Medicare and Medicaid EHR incentive program participants, and that both surveys have relatively high response rates.

I don’t know about you, but I was afraid things would be much worse. Measuring interoperability is quite difficult, given that just about everyone in the healthcare industry seems to have a slightly different take on what true interoperability actually is.

For example, there’s a fairly big gulf between those who feel interoperability only happens when all data flows from provider to provider, and those who feel that sharing a well-defined subset (such as that found in the Continuity of Care Document) would do the trick just fine. There is no way to address both of these models at the same time, much less the thousand shades of gray between the two extremes.

While its measures may not provide the final word on the subject, ONC has done a good job with the problem it was given, creating a model which is likely to be palatable to most of the parties involved. And that’s pretty unusual in the contentious world of health data interoperability. I hope the rollout goes equally well.

First CMS Audits of Meaningful EHR Users – Meaningful Use Monday

Posted on July 2, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In response to the topic I covered in my post on gaming the EHR incentive money, I got the following message:

Although I suppose this is within the letter of the law, it seems like a highly suspect practice, especially when CMS has said on conference calls that people who take the first check and subsequently drop out will be the first in line for audits.

I found this reply quite interesting. I’d never heard CMS say on a conference call that the first meaningful use audits would be those who got the first EHR incentive check and then chose to stop with meaningful use. Are there other readers that have heard this as well or that have heard or read similar things?

I’m a little torn on the idea of meaningful use audits. I’m certain that CMS will be doing meaningful use audits. It’s just a matter of time and how they’ll complete the audits of meaningful use. However, I don’t think they’re tremendously motivated to really clamp down on auditing those that adopt EHR software. I don’t think they want the bad PR of practices that have adopted EHR software getting audited and losing their EHR incentive money. They want doctors to adopt EHR and they want to pay them the EHR incentive money.

I guess the one exception to the above comment is those that really aren’t adopting EHR software and instead are just trying to game the system. CMS will likely be happy to make an example out of those doctors. Add in that Medicaid is done by the states and doesn’t require meaningful use and I’ll be interested to see how many doctors get the first Medicaid EHR incentive check and bypass the rest of the checks. I think there’s a lot of funny business that’s going to happen with the Medicaid EHR incentive money.

What else have you heard about EHR Incentive money audits and Meaningful Use Audits? I’m going to try and get some people familiar with other healthcare audits to share some thoughts on how to prepare to deal with the future meaningful use audits.

Medicaid Doctors and Dentists Gaming the EHR Incentive Program

Posted on June 29, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I guess I should have known that it would only be a matter of time before I’d see something like this come out. As best I can tell, Dentrix has partnered with Henry Schein to offer what they’re calling Dentrix Meaningful Use Access 7.6. Seems like Henry Schein is using the Dentrix names to get Dentists access to the Medicaid EHR incentive money. On face, I don’t see any problem with this.

Although, once you start to dig into it, it appears that Dentrix and Henry Schein are partnering to get Dentists the first Medicaid EHR incentive check without even implementing the EHR. You have to remember that the Medicaid EHR stimulus money doesn’t require you to show meaningful use of the EHR. You just have to acquire the EHR technology.

Look at some of the verbiage from the website for the program:

Definition of Adopt, Implement, or Upgrade:
For Medicaid, the eligible provider must Adopt, Implement, or Upgrade (AIU) certified EHR software. As posted on the CMS website, for AIU, a provider does not have to have installed certified EHR technology. The definition of AIU in 42 CFR 495.302 allows the provider to demonstrate AIU through any of the following:
*Acquiring, purchasing or securing access to certified EHR technology
*Installing or commencing utilization of certified EHR technology capable of meeting meaningful use requirements
or
*Expanding the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site, including staffing, maintenance, and training, or upgrade from existing EHR technology to certified EHR technology per the ONC EHR certification criteria.

Thus, a signed contract indicating that the provider has adopted or upgraded would be sufficient.

To be honest, I’m torn between whether this is genius or filthy. According to the letter of the law, I don’t know of any reason that someone with the right Medicaid population can’t purchase an EHR like this for $2000 and then collect the EHR incentive money. The regulations don’t require them to do any more to collect the money. Although, that’s certainly not the intent of the EHR incentive money and definitely feels like their gaming the system if they do it with no intent to actually implement the EHR.

Another piece from the website:

While Henry Schein currently has no plans to pursue a Meaningful Use solution beyond Stage 1, Year 1 for Dentrix, we continue to monitor healthcare reform to determine what subsequent steps, if any, should be taken regarding Meaningful Use criteria and certification.

At least their up front with the Dentists that they’re not planning to go beyond meaningful use stage 1, but may change their minds. I’m sure this is music to ONC’s ears to hear that they’re only committing to meaningful use stage 1.

If your strategy is to just help these dentists get the first EHR incentive check, then why should you worry about MU stage 2. Wouldn’t you love to be a salesperson for this product? Here’s your pitch: Pay me $2000 for this EHR, go through 5 steps on the government website and you’ll get paid $21,250.00.

I wish I could see something legally wrong with this idea. Someone I talked to mentioned that even for the Medicaid EHR incentive money you have to check some box saying that you comply with the HIPAA requirements. Well, these clinics have to do that anyway. Many don’t, but they’ll check that box anyway thinking that they comply whether they do or not.

The biggest surprise for me might be that Henry Schein is willing to have their name associated with a program like this. I’ll be interested to see who else picks up on this glaring issue with the Medicaid EHR incentive and what ONC/CMS/HHS do to close it up (if they can).

Medicaid State Information for EHR Incentives – Meaningful Use Monday

Posted on October 3, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Today’s Meaningful Use Monday is going to be short and sweet. I’m busy attending the AHIMA conference seeing their perspectives on EHR and meaningful use. However, I found an interesting resource on the CMS website for those wanting to collect the Medicaid EHR incentive money.

In this resource, CMS lists which states have a Medicaid EHR incentive program which is really important since each state governs the Medicaid part of the EHR incentive money. For posterity’s sake, here’s the list of programs that are open according to that website:
CMS registration opens in the following states on September 5, 2011:
Florida
Georgia
Illinois
Oregon
The following states opened for registration prior to September 5, 2011:
Alabama
Alaska
Arizona
Connecticut
Indiana
Iowa
Kentucky
Louisiana
Michigan
Mississippi
Missouri
New Mexico
North Carolina
Ohio
Oklahoma
Pennsylvania
Rhode Island
South Carolina
Tennessee
Texas
Washington
West Virginia
Wisconsin
Other states will launch their Medicaid EHR Incentive Programs during the fall of 2011.

They also have a link to a PDF which lists each state’s expected launch date. Some of them won’t launch into well into 2012. It’s pretty amazing to see the differences in each state.