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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.

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.

The Shifting Patient and Provider Dynamic: Evolution of Patient Care – Breakaway Thinking

Posted on May 21, 2014 I Written By

The following is a guest blog post by Carrie Yasemin Paykoc, Senior Instructional Designer at The Breakaway Group (A Xerox Company). Check out all of the blog posts in the Breakaway Thinking series.
Carrie Yasemin Paykoc
The relationship dynamic between patient and provider is shifting.  Providers are no longer viewed as the sole investigator and lone decision maker. This societal shift is a result of changing social and regulatory pressures: increased self-empowerment, government regulations and incentives aimed at patient-centric care, access to care through the Affordable Care Act, and access to internet and application-based self-diagnostic tools. For many patients, being able to access their own information and results is now an expectation and in some cases a necessity to save lives. There are many applications, search engines, and patient portals that allow patients to quickly evaluate symptoms, learn about possible causes, and find appropriate medical facilities. For a patient with heart attack or stroke symptoms, these tools can reduce complications and potentially save his or her life.

With access to this type of medical information, providers are no longer seen as veiled mystical healers; they need to commiserate with their patients to achieve the best clinical outcomes. Physician leaders are also echoing this sentiment. CT Lin, MD CMIO at the University of Colorado Hospital & Health Sciences Center presented “The Man Behind the Curtain” at the 2013 Breakaway Group’s Healthcare Forum. This event brought together 100 influential healthcare executives for discussions and presentations around optimizing healthcare IT adoption. During CT Lin’s presentation he expressed the importance of sharing real-time results with patients. By sharing health data CT Lin found a direct correlation between improved patient engagement and clinical outcomes.

At the University of Colorado Hospital, CT Lin conducted his own research initiative to demystify the man behind the curtain with a program called, “We Make Mouse Calls.” The study was modeled after a similar research project at Yale University and evaluated patient communication and perception of overall care. Over the course of six months, 300 patients utilized an online messaging system for prescription refills, specialist referrals, and appointments. After six months, patients were surveyed about their experience. Patient satisfaction with providers dramatically improved amongst this group- 86 percent of patients expressed improvement in communication and care. Patients felt very satisfied and empowered with direct access to their providers. In contrast, a control group of patients who were not privy to the online messaging system expressed marginal satisfaction with their provider before and after the six-month period.

Years later, CT Lin took his research a step further by releasing real-time results to patients using the Hospital’s online platform. Patients were provided some guidance on what results would be available and the normal parameters for these results. The implications of this study were quite profound.  By sharing real-time results with their patients, they noted increased patient trust and empowerment, increased understanding of their condition(s), and an increased adherence to their treatment. With the curtain pulled back and the data revealed providers were able to directly improve clinical outcomes.

Healthcare providers must embrace the shifting dynamic of patient care. Access to clinical data is no longer a privilege of earning an esteemed medical degree. It is now a requirement of providing and receiving care in a patient-centric model. Providers and patients that do not adapt may continue to experience lower clinical outcomes than those that evolve. At the risk of becoming extinct, providers have no other option than to adapt this this model.

To view CT Lin’s presentation from the 2013 Healthcare Forum click the following link: http://vimeo.com/67149315.

Xerox is a sponsor of the Breakaway Thinking series of blog posts.

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

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.

Large Health Systems May Miss Stage 2 Deadline

Posted on March 4, 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.

Usually, it’s the small institutions that are having fits when an IT program deadline is approaching. This time around, it’s the big boys that are struggling.

Intermountain Healthcare has announced that the organization will probably not attest to Stage 2 of the Meaningful Use program this year over concerns about patient safety, according to iHealthBeat

In an interview with HealthLeaders Media, CIO Marc Probst said that with the organization transitioning from its own EMR to EMR software from Cerner, all the software will not be running at all of the locations by the end of this year. This isn’t surprising after the relatively recent announcement that Intermountain would be switching to Cerner.

It’s not clear what it says about the success of the Meaningful Use Stage 2 program, other than that Intermountain has other priorities, but it does make you wonder what other large health systems will take a similar posture.

After all, ONC Chief Medical Officer Jacob Rieder (who also spoke with HealthLeaders) said that other large institutions are reporting similar situations. As amazing as it sounds considering the money involved, I won’t be surprised if we see more institutions following similar paths. There are a decent number of hospitals that haven’t even selected an EHR software.

According to Reider, it will be easier for small providers to meet Stage 2 requirements, given that they generally don’t have to plan as far into the future. But when it comes to large health systems, it seems that achieving this year’s Meaningful Use goal is a bridge too far.

Technology and Focusing on the Patient Video

Posted on September 26, 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.

I had a chance to sit down with Dr. Nick van Terheyden, CMIO at Nuance Healthcare, to discuss some of the latest topics in healthcare IT: meaningful use stage 2, ACOs, ICD-10, and patient engagement. Dr. Nick gives a lot of valuable insights into healthcare IT trends and also the shift to a more patient focused healthcare environment. I hope you enjoy the video interview with Dr. Nick embedded below:

You can see a full list of future and past live video interviews on our EHR Video Interview Schedule.

Most US Hospitals Are Ready For Meaningful Use Stage 2

Posted on September 19, 2013 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.

So, it looks like most US hospitals are prepared for Meaningful Use Stage 2. New data from HIMSS suggests that approximately 68 percent of US hospitals have purchased technology from a software vendor that has been certified to the 2014 Edition certification criteria, according to Healthcare IT News.

The HIMSS report, Hospital Readiness to Meet Meaningful Use Stage 2, was released this week during National Health IT Week in Washington, D.C.

Researchers found that at least 60 percent of hospitals in their sample had met requirements for at least nine of the core metrics that define Stage 2 Meaningful Use. They also found that roughly 70 percent of respondents are actively moving toward meeting stage two meaningful use requirements across all metrics, Healthcare IT News reports.

These latest findings from HIMSS fit well with other data from previous reports done by the organization. The 24th Annual HIMSS Leadership Survey, which was released this February, found that 75 percent of respondents expected their organization to qualify for Stage 2 incentives in 2014.

Things aren’t nearly so rosy, however, when it comes to Stage 2 compliance for physicians. Several trade groups have written to HHS asking the agency to postpone or even put on hold the requirements of Stage 2.  In August, for example, the MGMA wrote a letter to HHS asking the agency to put Stage 2 requirements on an indefinite moratorium for practices that have successfully nailed Stage 1 Meaningful Use requirements.

The MGMA argues that it’s unfair to expect medical practices to comply with Stage 2 Meaningful Use as of yet, given that at present there are only 75 products and 21 complete EMRs for ambulatory care which are currently certified for Stage 2 criteria. As I see it, they have an excellent point.

This is an untenable situation. It’s all well and good that hospitals are approaching Stage 2 readiness, but if ambulatory care is being left behind, Meaningful Use Stage 2 can’t be said to be accomplishing its true purpose. I believe HHS will grant the request of MGMA and other groups like it – and ease Stage 2 deadlines for ambulatory care providers – or it risks creating a digital divide between hospitals and medical practices which does no one any good.

Will Hospitals Be Penalized If Their EHR Vendor Isn’t 2014 EHR Certified?

Posted on August 30, 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.

Let me state the obvious. An EHR implementation in a hospital is a time consuming and expensive effort. While the idea of switching EMR software is a palpable discussion in the ambulatory space, it is a much more difficult discussion in the hospital EMR space. I heard one hospital CIO whose hospital decided to switch EHR software say it took them 2 years to make this decision. The idea of switching EMR software is not even a discussion point for many hospital CIOs.

With this in mind, I was intrigued by today’s #HITsm chat where we talked about meaningful use stage 2. More than a few people suggested that many EHR vendors are going to fail to meet the meaningful use stage 2 requirements and be 2014 EHR certified. I’ve personally suggested that I don’t think this will be the case. EHR vendors have far too much to lose to not be certified. However, more than a few people disagree with me on this subject, so I started to consider what this would mean for an organization.

For those of you who also read EMR and HIPAA, you might remember my post earlier this year called EHR Penalties after Meaningful Use Failure. In it I discuss how damaging it would be for a hospital that makes a sincere commitment to EHR and meaningful use to then fails to get the EHR incentive money because they fall short of meaningful use or fail an MU audit.

A similar situation could occur if a hospital’s EHR vendor isn’t able to meet the meaningful use stage 2 EHR certification requirements. What does the hospital do in this case? Will they miss out on the EHR incentive money and also suffer the EHR penalties because their EHR vendor wasn’t ready for meaningful use stage 2?

Like I said, I’ll still be surprised (especially in the hospital EHR space) if all the hospital EHR vendors don’t become 2014 EHR certified. However, if they don’t, a lot of hospitals will be put in a precarious position.

My guess is that if this happens, ONC will make an exception in the penalties for not being a meaningful user. I can’t imagine them penalizing a hospital who’s trying to be a meaningful user of an EHR and can’t because of their EHR vendor’s inability to perform. Although this would start a slippery slope of exceptions.

Either way, I want to dig into this topic more. How many EHR vendors won’t have their EHR certified for meaningful use stage 2? What are the timelines for them to complete this certification and then for hospitals to implement everything for MU stage 2?