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CMS Issues Final Rule on EHR Certification Flexibility, MU Stage 2 Extension, and MU Stage 3 Timeline

Posted on August 29, 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.

I can’t figure out what government process leads to final rules being regularly published at the end of the day on Friday. I know that Neil Versel from Meaningful Health IT News has hypothesized that they release it late on Friday when they want to bury the news. Maybe that’s the case, but the EHR certification flexibility doesn’t seem like something they’d want to bury. Regardless of the odd timing, CMS has just published the final rule that provides flexibility around EHR certification in the meaningful use program.

In their announcement, I’m not noticing any changes from what was in the proposed rule, but with some time we’ll know for sure if there’s any gotchas hidden in the final rule. No doubt many a meaningful use expert have just had their Labor Day weekend ruined by the announcement of this final rule.

Unfortunately, after the proposed rule was published most people loved the flexibility, but decided that it was too late for them to really benefit from the changes. I’ll be interested to see how many organizations will really benefit from these changes.

More importantly, the rule still includes the nebulous asterisk, “Only providers that could not fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability.” For EHR vendors that are already 2014 certified, this little asterisk feels like ONC is letting all the EHR vendors who didn’t perform well off the hook. It’s basically rewarding EHR vendors who can’t or have chosen not to keep up. Maybe that’s why the rule was published late on a Friday.

One could make the case that ONC was more worried about the doctors/hospitals whose EHR vendors failed to become 2014 certified, than the EHR vendors themselves. However, that part of the story is not likely to be told. Plus, it doesn’t take into account how a doctor/hospital whose EHR vendor is 2014 Certified will feel having to do the substantially harder MU stage 2 while their colleagues only have to do MU stage 1. (UPDATE: This EHR Certification Tool that CMS created seems to say that even if you’re on a 2014 Certified EHR and scheduled to do MU stage 2, that you can do Stage 1 or stage 2 objectives with 2014 CQMs. The chart linked at the bottom of this post says it as well. Seems like they’re being pretty open in their interpretation of “due to delays in 2014 Edition CEHRT availability”. Clear as mud?)

I’ve captured a chart showing the EHR Certification flexibility that this final rule provides:
EHR Certification Flexibility - 2014 Certified EHR

Plus, here’s the latest chart showing the meaningful use timelines:
Updated Meaningful Use Stage 3 Timeline

Other Resources and Responses:
CMS Official Press Release
CHIME’s Response
CMS’ EHR Certification Rule Tool
CMS HITECH 2014 CEHRT Flexibility Chart

We’ll keep adding other responses and commentary on the final rule as we find them.

Has Epic Fostered Any Real Healthcare Innovation?

Posted on August 13, 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.

I saw the following tweet and was really struck by the question.

I think we could broaden the question even more and ask if any EHR vendor has really fostered healthcare innovation. I’m sorry to say that I can’t think of any real major innovation from any of the top hospital EHR companies. They all seem very incremental in their process and focused on replicating previous processes in the digital world.

Considering the balance sheets of these companies, that seems to have been a really smart business decision. However, I think it’s missing out on the real opportunity of what technology can do to help healthcare.

I’ve said before that I think that the current EHR crop was possibly the baseline that would be needed to really innovate healthcare. I hope that’s right. Although, I’m scared that these closed EHR systems are going to try and lock in the status quo as opposed to enabling the future healthcare innovation.

Of course, I’ll also round out this conversation with a mention of meaningful use. The past 3-5 years meaningful use has defined the development roadmap for EHR companies. Show me the last press release from an EHR company about some innovation they achieved. Unfortunately, I haven’t found any and that’s because all of the press releases have been about EHR certification and meaningful use. Meaningful use has sucked the innovation opportunity out of EHR software. We’ll see if that changes in a post-meaningful use era.

A Hospital CFO Perspective on EHR Expense

Posted on June 25, 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.

The past couple days I’ve been able to enjoy a couple days sitting down with hospital CFO’s at HFMA’s ANI conference in Las Vegas. I think this is the third time I’ve attended the event and it’s always a really interesting conference since hospital CFOs have a great financial perspective into the running of a hospital.

While at the big dinner celebration they had last night at the event, I asked a hospital CFO what she thought of the event and what she’d learned. She responded:

The sessions really helped me feel good about the small investments we’ve been making in population health and analytics. I think were going in the right direction.

Then she added this after thought that was telling:

Not to mention justifying the insane amount of money we’re spending on our EHR.

I think we’ve done a really poor job of explaining why the EHR is worth the investment. Let’s be honest though. Most of the EHR implementations haven’t been about leveraging the EHR to improve the organization. They’ve been focused on the meaningful use regulatory requirements, getting the EHR incentive money, and avoiding the EHR penalties.

Going forward we’re going to have to shift our thinking. We’re going to have to do a much better job justifying the EHR expense by showing the benefits an EHR provides a hospital organization.

AHA urges agencies to speed up EMR choice expansion

Posted on June 23, 2014 I Written By

Anne Zieger is veteran healthcare editor and analyst with 25 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. She can be reached at @ziegerhealth or www.ziegerhealthcare.com.

In a move that shouldn’t surprise anybody, the American Hospital Association is urging CMS and the ONC to hurry up and finalize new rules which would expand choice for certified EMRs.

The AHA letter argues that its members are on the verge of walking away from Meaningful Use. But if CMS and the ONC speed ahead with with the new proposed rules — which would offer more choice in specific meaningful use requirements they must meet this year — hospitals will be much better equipped to proceed.

Why the rush? Well, for one thing, the letter argues, time is of the essence for hospitals, which have to decide their meaningful use strategy for fiscal 2014. If they must make choices before the new rule is finalized, it could cause them “significant financial and operational harm,” the AHA contends.

Meanwhile, if the agencies don’t push these rules through quickly, “many providers are likely to conclude that they cannot meet meaningful use this year and abandon the program,” wrote Linda Fishman, AHA senior vice president of public policy analysis and development, in a letter to CMS Administrator Marilyn Tavenner and National Coordinator Karen DeSalvo, MD.

The letter also takes on other issues. It asks that CMS and ONC clarify the rules implementation, offer more flexibility in the reporting of clinical quality measures, shorten the MU reporting period for 2015 in analyze lessons learned from Stage 2 before finalizing Stage 3’s start date, according to HealthcareITNews.

The AHA’s letter comes at a challenging time for the meaningful use program generally, which has of late attracted broader attention than it has in the past.

Not only are industry groups pressuring ONC, legislators are too. For example, at a recent health IT conference, U.S. Rep Tom Price, MD, R-GA, argued that meaningful use is “maybe not even doing what needs to be done as it relates to patients and physicians.”

In his remarks, Price argued that meaningful use could be improved by keeping the patient front and center, making sure patients know they own their health data and establishing an interoperability standard.  But he suggests that because the MU program roadmap was laid out in the HITECH Act, it’s not as fluid as it should be and doesn’t accommodate such concerns.

The reality, however, is that there is no simple way to get interoperability; right now, we’re lucky if individual EMRs meet providers’ needs.  Despite the demands from other stakeholders, health IT vendors still have a lot more to gain by creating islands rather than interoperable products.

CDS Technology: A Value Proposition for MU

Posted on June 19, 2014 I Written By

The following is a guest blog post by Bonnie Briggs, Director of Product Management for Wolters Kluwer Health.

As the industry turns towards Stage 2 Meaningful Use (MU) attestation with greater urgency and anticipates the forthcoming criteria for Stage 3 and beyond, healthcare providers are increasingly looking for effective ways to streamline compliance and best position for the future. With so many initiatives competing for limited dollars, the value proposition of any health IT investment is critical to meeting current and future regulatory objectives—and qualifying for attractive incentive payments that can deliver a whopping $7 million to the average 200-bed hospital for Stage 2 alone (based on the current Medicare share and transition factor).

As MU moves past the Stage 1 focus of basic data capture within an EHR, healthcare organizations need to lay a foundation to address the more advanced clinical processes and improved outcomes focus of Stages 2 and 3. Use of clinical decision support (CDS) technology at the point of care is a focal point of compliance as it sets the stage for greater adoption of evidenced-based practices to improve outcomes.

While drug reference and drug interaction data applications are obvious choices for meeting Stage 2 MU CDS requirements for drug-drug, drug-allergy and drug-disease interactions screenings, healthcare organizations need to consider that not all solutions are advanced enough to address other key MU requirements, namely patient education/engagement requirements and HL7 Infobutton capability. Specifically, the industry’s most advanced products can help fill in the gaps by providing appropriate tools for educating and engaging patients and linking clinicians to the most relevant content.

Addressing Patient Education and Limited Health Literacy

Industry research reveals that there is a considerable disconnect between the language of clinicians and the ability of patients to comprehend the relevance and importance of what is being communicated. In fact, nearly half of American adults have some level of limited health literacy when it comes to using and understanding written health information alone, according to the Institute of Medicine (IOM).

One area that has become a focal point of regulatory discussion related to patient education and health literacy is the need to accommodate non-English-speaking patients. The National Standards on Culturally and Linguistically Appropriate Services (CLAS) states that “health care organizations must make available easily understood patient-related materials and post signage in the languages of the commonly encountered groups and/or groups represented in the service areas.”

While Stage 2 MU requirements call for the use of EHRs to identify patient-specific education resources, Stage 3 recommendations released by the HITPC Meaningful Use Workgroup earlier this year point to the potential of this rule being expanded to support language needs. Specifically, the recommendation calls for the “use of CEHRT capability to provide patient-specific educational material in non-English speaking patients’ preferred language.”

When considering the value proposition behind the use of CDS technology in the form of drug reference applications, the availability of consumer-level content that addresses a broad array of foreign languages should be considered to best position for compliance going forward. Industry recommendations also suggest that materials be written on a 5th to 7th grade level, using simple sentence structures and short, bulleted statements for easy reading. Other key considerations for effectively engaging patients include age-appropriate illustrations and the provision of materials in larger fonts for the visually impaired.

The Infobutton Challenge

Compliance with MU patient education standards also means that certified EHRs must support the Health Level 7 International Context-Aware Knowledge Retrieval standard, more commonly referred to as the HL7 Infobutton. This industry standard must be used to access patient-specific education materials based on relevance. It may also provide links to referential CDS as an option.

A widely accepted and adopted standard, the Infobutton essentially enables EHRs to generate a view of a patient encounter based on standard patient and provider information. From that information, an EHR application can gather appropriate patient education materials based on the specific details of that case at the click of a button.

The challenge for healthcare organizations will be identifying CDS applications that are equipped to gather patient data in this way. When advanced drug reference applications can aggregate this information from problem lists, medication lists and laboratory results and support Infobutton contextual parameters for identifying appropriate knowledge resources, the value proposition as it pertains to MU compliance is heightened.

Conclusion

When positioning for effective use of CDS at the point of care to meet current and future MU objectives, healthcare organizations need to be careful of making knee-jerk decisions and consider the best technological foundations for long-term success.

While a number of CDS applications on the market can address the basics of drug-drug, drug-allergy and drug-disease interactions screenings, not all are equipped for the broader patient education focus currently unfolding. Considerations should be made for addressing the bigger picture of health literacy and evolving industry standards such as HL7 Infobutton capability.

Bonnie Briggs, RPh, MBA, is the Director of Product Management for Wolters Kluwer Health. She can be reached at bonnie.briggs@wolterskluwer.com.

Time for Government to Step Out of the Way of EHR and Let the Market Takeover?

Posted on May 22, 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.

The always interesting and insightful John Moore from Chilmark research has a post up that asks a very good question. The question is whether it’s time for the government to get out of the EHR regulation business and let the market forces back in so they can innovate. I love this section of the post which describes our current situation really well:

But as often happens with government initiatives, initial policy to foster adoption of a given technology can have unintended consequences no matter how well meaning the original intent may be.

During my stint at MIT my research focus was diffusion of technology into regulated markets. At the time I was looking at the environmental market and what both the Clean Air Act and Clean Water Act did to foster technology adoption. What my research found was that the policies instituted by these Acts led to rapid adoption of technology to meet specific guidelines and subsequently contributed to a cleaner environment. However, these policies also led to a complete stalling of innovation as the policies were too prescriptive. Innovation did not return to these markets until policies had changed allowing market forces to dictate compliance. In the case of the Clean Air Act, it was the creation of a market for trading of COx, SOx and NOx emissions.

We are beginning to see something similar play-out in the HIT market. Stage one got the adoption ball rolling for EHRs. Again, this is a great victory for federal policy and public health. But we are now at a point where federal policy needs to take a back seat to market forces. The market itself will separate the winners from the losers.

His points highlight another reason why I think that ONC should blow up meaningful use. In my plan, I basically see it as the government getting out of the EHR business. I do disagree with John Moore’s comments that the government should step away from interoperability. If they do, we just won’t have interoperability. I guess he’d make the argument that value based reimbursement will force it, but not in the same way that the rest of the EHR incentive money could force the issue.

I have learned that to really get out of this game or even do what I describe will take an act of congress. HHS can’t do this without their help. Although, they could get pretty close. Plus, maybe they could exert their influence to get congress to act, but I won’t be holding my breathe on that one.

6 Hospitals’ Meaningful Use Payment Numbers

Posted on May 20, 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.

Becker’s Hospital CIO has posted some really interesting data about the meaningful use payments that hospitals have received. They very smartly looked at the first quarter financial reports for 6 hospitals that disclosed their EHR stimulus payments. Check out the data below:

  1. Community Health Systems (Franklin, Tenn.): $40 million, up from $19 million during the first quarter of 2013
  2. IASIS Healthcare (Franklin, Tenn.): $4 million, down from $5 million during the first quarter of 2013
  3. Tenet Healthcare (Dallas): $9 million, up from $5 million during the first quarter of 2013
  4. Hospital Corporation of America (Nashville, Tenn.): $30 million, down from $39 million during the first quarter of 2013.
  5. LifePoint Hospitals (Brentwood, Tenn.): $14 million, up from $6 million during the first quarter of 2013
  6. Universal Health Services (King of Prussia, Pa.): $430,000, down from $4.7 million during the first quarter of 2013

It’s interesting to see some of them have their payments really fall off. We’ll see how this data plays out over time, but I think it’s another data point that meaningful use stage 2 has issues and we should consider blowing up meaningful use.

4 Hospitals Have Achieved Meaningful Use Stage 2 – Yes…4

Posted on May 7, 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.

Yesterday a presentation was done to the HIT Policy Committee. The slide below certainly paints an interesting picture for meaningful use stage 2. There’s still time, but when you consider hospitals rush to get the EHR incentive money under stage 1 this number doesn’t bode well for MU stage 2.

HITPC_CMS_Update_2014-05-06

The Challenge of Clinical Quality Measures – ONC Dashboard

Posted on April 22, 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.

The incomparable Mandi Bishop just pointed out to me an amazing ONC dashboard that’s tracking issues with the clinical quality measures (CQM). I don’t know how I’d never seen this before, but it’s a treasure trove of amazing information. I’m proud of ONC for being this transparent in their efforts to make the clinical quality measures as effective as possible.

It’s also an amazing illustration of how hard it is to get these clinical quality measures correct. As Mandi pointed out to me, Beta-blockers, for example, can’t be tolerated by Asian-Americans, but that’s a required CQM: prescribe beta-blockers within 24 hours of surgery for cardiac patients. That’s scary to think that a clinical quality measure could actually do harm versus improving quality.

We’ve heard this from doctors for a really long time. Medicine is complicated and each patient is unique. This dashboard illustrates many of those challenges.

Personally I think that the clinical quality measures were a step too far in the EHR incentive program. Although, I’ve long wished that all the incentive money would have been focused on establishing a standard for EHR interoperability and then paying organizations that were interoperable. That would do more impact for good on healthcare than these clinical quality measures.

What are your thoughts and experiences with clinical quality measures?

Eyes Wide Shut Meaningful Use Series

Posted on March 6, 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.

For those of you who read Hospital EMR and EHR but don’t read EMR and HIPAA (which from our latest survey is far too many of you), I wanted to highlight a series of blog posts by Mandi Bishop that I believe will be of extreme interest to those reading this site.

In this series called Eyes Wide Shut, Mandi gives some really amazing in the trenches views into how a large organization is dealing with the challenges of meaningful use and meaningful use stage 2 in particular.

Here’s a small sample from the latest entry in the series titled “Eyes Wide Shut: Meaningful Use Stage 2 Incentive Program Hardships“:

In my January update on Meaningful Use Stage 2 readiness, I painted a dismal picture of a large IDN’s journey towards attestation, and expressed concern for patient safety resulting from the rush to implement and adopt what equates to, at best, beta-release health IT. Given the resounding cries for help from the healthcare provider community, including this February 2014 letter to HHS Secretary Kathleen Sebelius, I know my experience isn’t unique. So, when rumors ran rampant at HIMSS 2014 that CMS and the ONC would make a Meaningful Use announcement, I was hopeful that relief may be in sight.

Like AHA , I was disappointed in CMS Administrator Marilyn Tavenner’s announcement. The new Stage 2 hardship exemptions will now include an explicit criteria for “difficulty implementing 2014-certified EHR technology” – a claim which will be evaluated on a case-by-case basis, and may result in a delay of the penalty phase of the Stage 2 mandate. But it does nothing to extend the incentive phase of Stage 2 – without which, many healthcare providers would not have budgeted for participation in the program, at all, including the IDN profiled in this series. So how does this help providers like mine?

In that post, Mandi also tries to not just complain about the challenges they face, but also offer some solutions. You can see her full list of ideas in the post, but I especially like the simplicity of her last line “Consider applying the hardship exemption deadline extension to the incentive program participants.”

We need more in the trenches people like Mandi sharing their stories and solutions for others to see. Otherwise, the regulators sit in their office in DC and don’t know the details of why they should adjust. If you’re someone reading this that would like to tell your story as well, I’d be happy to give you the platform. Just drop me a note on our contact us page.