At HIMSS 2014, the health information technology’s (HIT) largest annual confab, the bestest-best news we heard from a policy perspective, and maybe even an industry perspective, was the Centers for Medicare & Medicaid Services’ (CMS) dual announcement that there will be no further delays for either Meaningful Use Stage 2 (MU-2) or ICD-10.
Perhaps we should have immediately directed our gaze skyward in search of the second shoe preparing to drop.
As it turns out, CMS de facto back-doored an MU-2 delay by issuing broad “hardship” exemptions from scheduled MU-2 penalties. To wit: any provider whose health IT vendor is unprepared to meet MU-2 deadlines, established lo these many months ago, is eligible for a “hardship” exemption.
Few would disagree with the notion that it’s unproductive to criticize policy without offering constructive ideas to fix the underlying problems.
Here, the underlying problem is easy to define: it is in point of irrefutable fact fundamentally unfair to penalize care providers for their vendors’ failings—especially when the very government proposing to penalize them put its seal of approval on the vendors’ foreheads to begin with.
CMS’s move to exempt providers from those penalties is correctly motivated, but it seeks to ease the provider pain without addressing its cause.
Instead of issuing a blanket exemption for use of unprepared vendors, CMS should:
- Waive penalties only for those providers who take steps to replace their inferior technologies with systems that can meet the demands of the 21st century’s information economy;
- Publish lists of health IT vendors whose systems are the basis for a hardship exemption, along with an accounting of how many of those 21 billion dollars have been paid to subsidize those vendors’ products; and
- Immediately initiate a reevaluation of the MU certification of any vendor whose products form the basis for a hardship exemption.
This proposal might seem bold, but if we’re truly looking to advance health care through the application and use of EHR, then what I’ve outlined above simply represents necessary and sound public policy. Current practice rewards vendors whose products are falling short by perpetuating subsidies for those products.
The federal government should stop paying doctors to implement health IT that cannot meet the standards of the program under which the payments are issued. That’s just a no-brainer.
An EHR should not be a federally-subsidized “hardship.”
Continue reading “Congratulations, Doctor, On Your Federally-Subsidized “Hardship””
Filed Under: Tech, THCB
Tagged: CMS, Dan Haley, EHR, EHR vendors, Hardship Exemption, HIMSS 2014, HIT, Meaningful Use Stage 2, Providers
Mar 13, 2014
The photo says it all.
The green notebook and pen represent the latest and greatest health IT innovations used by the hospital nurse to record my wife’s health information in the hours before her surgery to re-attach a fully torn Achilles tendon.
(Apologies for the cheeky intro and to my wife and anyone else for any HIPAA violations I may have committed in the capturing of this image).
It’s not that the hospital does not have an electronic health record.
They do – from a vendor widely considered a leader in the industry: Meditech. Same goes with the physician practice where she receives all her care and where her surgeon and primary care doctor are based.
They too have an EHR from another leading vendor: NextGen.
The problem? These systems are not connected. Thus, confirming the not so surprising news that health data interoperability has yet to make its debut in our corner of the NYC burbs.
Fortunately for my wife, she is well on her way to recovery (a bit more reluctant to juggle a soccer ball with her son in airport passenger lounges, but nevertheless feeling much better…and mobile). By everyone’s estimation – hers, mine, friends who suffered the same injury and friends who happen to be doctors – she received high quality care.
What’s more, we feel the overall patient experience at our physician practice and the hospital was quite good. That said, I cannot help but ask myself a series of ‘what ifs?’
What if…we forgot to mention a medication she was taking and there was a bad reaction with medication they administered as part of the surgery or afterwards?
What if… the anesthesiologist or surgeon couldn’t read the nurse’s handwriting?
What if the next time we go to the hospital, it is a visit to the emergency room and the attending clinicians have no ability to pull any of my family’s health records and we are not exactly thinking clearly enough to recall details related to medical history?
Continue reading “What A Green Three Ring Binder Says About the State of Meaningful Use and Health Information Exchange”
Filed Under: Uncategorized
Tagged: EHR, health information exchange, HIMSS 2014, HIT, Meaningful Use Stage 2, Rob Cronin
Feb 24, 2014
2014 will see wide-scale production and exchange of Consolidated CDA documents among healthcare providers. Indeed, live production of C-CDAs is already underway for anyone using a Meaningful Use 2014 certified EHR.
C-CDA documents fuel several aspects of meaningful use, including transitions of care and patient-facing download and transmission.
This impending deluge of documents represents a huge potential for interoperability, but it also presents substantial technical challenges.
We forecast these challenges with unusual confidence because of what we learned during the SMART C-CDA Collaborative, an eight-month project conducted with 22 EHR and HIT vendors.
Our effort included analyzing vendor C-CDA documents, scoring them with a C-CDA scorecard tool we developed, and reviewing our results through customized one-on-one sessions with 11 of the vendors.
The problems we uncovered arose for a number of reasons, including:
Filed Under: THCB
Tagged: clinical document exchange, David Kreda, EHR, HIT, Joshua Mandel, Meaningful Use Stage 2, ONC, open data, SMART C-CDA Collaborative, SMART platform
Feb 11, 2014
As Meaningful Use 2014 EHRs come online this winter, clinicians across the country gain access the host of new features included in the MU 2014 Certification Requirements.
In this post, we’ll dig into one of these features: EHR-based secure e-mail capabilities that operate using the “Direct Project” specification. (If you’re new to this world: when you hear “Direct Project,” you should think “secure e-mail for healthcare.”)
It’s a party!
In theory, giving every clinician in the country a secure e-mail inbox ought to enable something amazing (and amazingly familiar, for anyone who has used e-mail outside of healthcare): the ability to converse electronically, back-and-forth, in one-on-one or one-to-many discussions with… well… whomever you choose.
… but not everybody’s invited
Unfortunately, the practice hasn’t caught up to the theory. EHRs provide restricted inboxes that allow messaging to some recipients but not others. Why? It comes down to “trust,” which is a broad topic that we’ll treat only glancingly, where it intersects with the technology.
One of the requirements for Direct Project messaging is security, which means (among other things) that messages must be encrypted as they travel. To properly handle encryption, the sender’s EHR software (or Health Information Service Provider) needs to reliably discover the recipient’s cryptographic certificate, extract a public key from that certificate, and use that public key to encrypt each message before sending it out over the wire.
So far so good.
Continue reading “Teach Your EMR to Do Email? Impossible!!?! Unthinkable??? Maybe Not”
Filed Under: Tech, THCB, The Vault
Tagged: API, Boston Children's Hospital, Direct Project, EHR, HIT, Interoperability, Joshua Mandel, Meaningful Use Stage 2, SMART platform
Feb 1, 2014
We continue to see progress in improving the nation’s health care system, and a key tool to helping achieve that goal is the increased use of electronic health records by the nation’s doctors, hospitals, and other health care providers. These electronic tools serve as the infrastructure to implementing reforms that improve care – many of which are part of the Affordable Care Act.
Doctors and hospitals are using these tools to reduce mistakes and hospital readmissions, provide patients with more information that enable them to stay healthy, and allow for rewarding health care providers for delivering quality, not quantity, of care.
The adoption of those tools is reflected today in a release from the Centers for Disease Control and Prevention’s National Center for Health Statistics which provides a view of the Medicare and Medicaid EHR Incentive Program and indicates the program is healthy and growing steadily.
The 2013 data from the annual National Ambulatory Medical Care Survey are encouraging:
- Nearly 80% of office-based physicians used some type of electronic health record system, an increase of 60 percentage points since 2001 and nearly double the percent in 2008 (42%), the year before the Health Information Technology and Economic and Clinical Health Act passed as part of the Recovery Act in 2009.
- About half of office-based physicians surveyed said they use a system that qualifies as a “basic system,” up from just 11% in 2006.
- Almost 70% of office-based physicians noted their intent to participate in the EHR incentive program.
Figure 1. Percentage of office-based physicians with EHR systems: United States, 2001-2013
The report also noted that 13% of physicians who responded said they both intended to participate in the incentive program and had a system that could support 14 of the Meaningful Use Stage 2 “core set of objectives,” ahead of target dates. This survey was performed in early 2013 – before 2014 certified products were even available.
Continue reading “Survey Says: EHR Incentive Program Is on Track”
Filed Under: Tech, THCB, The Business of Health Care
Tagged: EHR, EHR Incentive Programs, HIT, Karen DeSalvo, Meaningful Use, National Center for Health Statistics, ONC, Physicians
Jan 17, 2014
Besides the importance of physician happiness when using an EHR, using design principles that maximize user intuition and presentation of relevant information, there is one aspect of health care information systems that should never be overlooked…patient safety.
Scot Silverstein, MD, blogging at Health Care Renewal as InformaticsMD, frequently brings to light issues surrounding health care IT implementations that compromise patient safety. Reading his posts should be sobering and concerning to both medical professionals and the public alike. Like I’ve said, health care IT, in my opinion, is still in its infancy despite the number of years computers have been around and the existence of Meaningful Use legislation.
As a practicing physician as well as a software coder, I’ve used a number of EHR’s (and still currently using a well known EHR by my employer of my part time job) to know how some of these appalling user interfaces affect not just workflow and user happiness, but patient safety.
An example of one design element that most physicians may not be able to identify, ironically, is the one that is most harmful when it comes to patient safety. In this well known EHR, you are presented a medication list for a patient. As a physician, you assume that this list is a current medication list and is up to date. However, the reality is that this EHR system automatically removes a medication from the list when it is determined to be expired even if it should be appearing on the current medication list.
When a physician prescribes a medication from this system, it calculates the duration of usage of the medication based on the instructions, quantity of medication prescribed, and the number of refills. Once the duration exceeds the number of days that has elapsed since the prescription was made, the medication is taken off the current list automatically by the EHR. Now, taken at face value, this sounds like the logical approach to manage a medication list and utilizes the computing power that an EHR will gladly show off as a benefit to physicians.
Unfortunately, the EHR programmers failed to understand that medications are not taken regularly by all patients all the time. In fact, no physician assumes that at all. So why should an EHR make that assumption? Furthermore, there are plenty of treatments that are to be taken only as needed so how can an EHR account for that? Absolutely, impossible.
Continue reading “Why EHR Design Matters”
Filed Under: Tech, THCB
Tagged: Design, EHR, Michael Chen, Patient Safety, Physicians
Dec 18, 2013
The Massachusetts Medical Society may be the first to notice that Meaningful Use EHR mandates favor large providers and technology vendors. Control over the Nationwide Health Information Network sets the stage for how physicians refer, receive decision support, report quality, and interact with patients. State health information exchanges and policy makers are caught in the cross-fire over health records interoperability. Are the federal regulations over Stage 2 being manipulated to put physicians and the public at a disadvantage?
On Dec. 7, the Massachusetts Medical Society took what might be the first formal action in the nation. A resolution stating:
“That the Massachusetts Medical Society advocate for a more open, affordable process to meet technology mandates imposed by regulations and mandates; e.g., that all Direct secure email systems, mandated by Meaningful Use stage 2, including health information exchanges and electronic health record systems, allow a licensed physician to designate any specified Direct recipient or sender without interference from any institution, electronic health record vendor, or intermediary transport agent.”
Scott Mace’s column Direct Protocol May Favor Large Providers and Vendors is the first to report on this unusual move by a professional society. Full disclosure: I’m a member of the MMS and the initiator of what became this resolution.
Meaningful Use is intended to support health reform by promoting interoperability and innovation in health service delivery. The Affordable Care Act, Obamacare, is fundamentally a free-enterprise model without single payer or even a public option. Obamacare depends on the market for eventual cost controls and sustainability. Meaningful Use is regulation designed to enable market-driven health reform by reducing interoperability barriers.
Although Meaningful Use regulations have already handed out $17 Billion to drive “voluntary” adoption of interoperable electronic health records, meaningful interoperability is still elusive. Meanwhile, the doctors are chafing about Meaningful Use intrusions and policymakers worry that the regulations will actually increase costs.
Continue reading “It’s Doctors versus Hospitals Over Meaningful Use”
Filed Under: Tech, THCB
Tagged: Adrian Gropper, EHR, EHR vendors, Hospitals, Massachusetts Medical Society, Meaningful Use Stage 2, Physicians
Dec 12, 2013
I want to update you on ComChart EMR’s “Meaningful Use Certification” status.
ComChart EMR will continued to be certified as a Complete EMR for Stage I Meaningful Use. Unfortunately, we will not be able to meet the Stage 2 (or greater) Meaningful Use certification requirements as these requirements are technically extremely difficult to implement.
In addition to the Meaningful Use mandates, there continues to be a never ending stream of new mandates such as ICD-10, PQRI, Meaningful Use 2, Meaningful Use 3, SNOMED, ePrescribing, LOINC, Direct Project, health information exchanges etc. As a result of the mountain of mandates, ComChart EMR and the other small EMR companies will have to choose to implement the mandates or use their resources to add “innovative” features to their EMR. Unfortunately, the small EMR companies do not have the resources to do both.
(I suspect this is also true, to some extent, for all EMR companies.)
While the individual people involved in promulgating these EMR mandates (mostly) have the best of intentions, they clearly do not understand what transpires in the exam room, as many of the mandated features confer little or no benefit to either the patient or the healthcare provider.
In addition to a lack of understanding of what is important during the process of providing healthcare, it has also become apparent to me that the Federal and State health information technology agenda is now largely driven by the strongest HIT companies and health institutions; the individual physician is only an afterthought in the entire process.
Continue reading “Open Letter From a Small EMR Vendor To Our Customers and Our Friends In Washington”
Filed Under: Tech, THCB
Tagged: EHR, Hayward Zwerling, Meaningful Use Stage 2, Physicians
Dec 5, 2013
A common and somewhat unique aspect to EHR vendor contracts is that the EHR vendor lays claim to the data entered into their system. Rob and I, who co-authored this post, have worked in many industries as analysts. Nowhere, in our collective experience, have we seen such a thing. Manufacturers, retailers, financial institutions, etc. would never think of relinquishing their data to their enterprise software vendor of choice.
It confounds us as to why healthcare organizations let their vendors of choice get away with this and frankly, in this day of increasing concerns about patient privacy, why is this practice allowed in the first place?
The Office of the National Coordinator for Health Information Technology (ONC) released a report this summer defining EHR contract terms and lending some advice on what should and should not be in your EHR vendor’s contract.
The ONC recommendations are good but incomplete and come from a legal perspective.
As we approach the 3-5 year anniversary of the beginning of the upsurge in EHR purchasing via the HITECH Act, cracks are beginning to show. Roughly a third of healthcare organizations are now looking to replace their EHR. To assist HCO clients we wrote an article published in our recent October Monthly Update for CAS clients expanding on some of the points made by the ONC, and adding a few more critical considerations for HCOs trying to lower EHR costs and reduce risk.
The one item in many EHR contracts that is most troubling is the notion the patient data HCOs enter into their EHR is becomes the property in whole, or in-part, of the EHR vendor.
It’s Your Data. Act Like it.
Prior to the internet-age the concept that any data input into software either on the desktop, on-premise or in the cloud (AKA hosted or time sharing) was not owned entirely by the users was unheard of. But with the emergence of search engines and social media, the rights to data have slowly eroded away from the user in favor of the software/service provider.
Facebook is notorious for making subtle changes to its data privacy agreements that raise the ire of privacy rights advocates.
Continue reading “Whose Data Is It Anyway?”
Filed Under: Tech, THCB
Tagged: business of healthcare, Chilmark Research, Data, EHR, EHR vendors, John Moore, Privacy, Robert Tholomeier
Nov 20, 2013
So I was at TechfestNW earlier this fall and I had the opportunity to hear James Keller at WalmartLabs speak about the importance of having a minimum valuable (versus viable) product that is tied into the user experience. It is how the user’s emotional response to the application’s interface, which is so important to have, that gives a product meaning.
And this concept (although I admit I completely stumbled upon it) is at the very heart of what makes NOSH ChartingSystem so different. As I have stated on my blogs before and on my Indiegogo campaign site, I wanted to have an EHR that was both intuitive to use AS WELL AS having an interface that was calming and meaningful at the same time. So as an example from the medical world, having a pain scale is pretty good indicator of how user-friendly your application is.
An analogous concept is the OMG-to-WTF scale (see above).
Where does your EMR stand on the scale?
Continue reading “The OMG to WTF? EMR Pain Scale”
Filed Under: Tech
Tagged: Design, EHR, HIT, Michael Chen, Patients, Physicians
Nov 19, 2013