NEW @ THCB PRESS: Surviving Workplace Wellness. Spring 2014. Al Lewis and Vik Khanna. e-book edition. # LIGHTHOUSE Healthcare. Illuminated.

Meaningful Use Stage 2

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:

  1. 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;
  2. 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
  3. 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””

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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”

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SMART C-CDA infographic -- click to enlarge2014 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:

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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”

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Let me concede from the outset that, in this blog post, I lean toward the negative—dire predictions, worst-case scenarios, a bit of doom and gloom, etc.

But I ask you, oh gentle, patient reader, how could I not?

Let’s go to the satellite. You can see warm air from a low-pressure system (Meaningful Use Stage 2, not changed dramatically by the one-year extension) collide with cool, dry air from a high-pressure area (the turmoil of Obamacare) and tropical hurricane moisture (ICD-10). Tell me you don’t see the Perfect Storm yourself.

And here we sit in our little fishing boat, waiting for the mighty ocean to consume us.

Overly dramatic? Certainly, but still not wholly inappropriate, I will argue.

Consider a recent report on the HIMSS/WEDI ICD-10 National Pilot Program collaborative that was created to, “…minimize the guess work related to ICD-10 testing and to learn best practices from early adopter organizations.”

Designed to ascertain the realities of the entire healthcare system adopting and using ICD-10, this pilot included an education and adoption program for all participants, followed by a set of “waves” in which diagnoses for the 100-200 most common medical conditions were actually coded and submitted using ICD-10.

The end-to-end testing approach …

…would encompass a number of medical test cases that mirror actual processing, including situations with multiple “hops” or “steps” between providers, clearinghouses, and health plans; the identification of high-risk medical test cases to help prioritize testing; the identification of available testing partners; and key reporting and sharing of test results. The test environment must mirror production.

And how did this pilot testing go? (Cue dark, foreboding music here …)

The average accuracy was in the 60 percent range with low scores around 30 percent.  Yes, some medical scenarios had nearly 100 percent accuracy, which is great. But very low accuracy accompanied a number of very common conditions. Not so great.

Continue reading “Does ICD-10 Pilot Forecast a Perfect Storm for Healthcare?”

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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”

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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”

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I’ve recently written about healthcare.gov and the lesson that going live too soon creates a very unpleasant memory.

As I work with healthcare leaders in Boston, in New England, and throughout the country, I’m seeing signs that well resourced medical centers will struggle with Meaningful Use stage 2 attestation, ICD-10 go live, HIPAA Omnibus Rule readiness, and Accountable Care Act implementation, all of which have 2013-2014 deadlines.

People are working hard. Priority setting is appropriate. Funding is available.

The problem is that the scope is too big and the timeline is too short.

What are the risks? 

Continue reading “Fine Tuning the National Health IT Timeline”

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I’ve written several posts about the frustrating aspects of Meaningful Use Stage 2 Certification.   The Clinical Quality Measures (CQMs) are certainly one of problem spots, using standards that are not yet mature, and requiring computing of numerators and denominators that are not based on data collected as part of clinical care workflow.

There is a chasm between quality measurement expectations and EHR workflow realities causing pain to all the stakeholders – providers, government, and payers.   Quality measures are often based on data that can only be gathered via manual chart abstraction or prompting clinicians for esoteric data elements by interrupting documentation.

How do we fix CQMs?

1.  Realign quality measurement entity expectations by limiting calculations (call it the CQM developers palette) to data which are likely to exist in EHRs.   Recently, Yale created a consensus document, identifying data elements that are consistently populated and of sufficient reliability to serve in measure computations.   This is a good start.

2.  Add data elements to the EHRs over time and ensure that structured data input fields use value sets from the Value Set Authority Center (VSAC) at NLM.    The National Library of Medicine keeps a Meaningful Use data element catalog that is likely to expand in future stages of Meaningful Use.

Continue reading “Quality Measurement 2.0″

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Health IT Week demonstrated a double barrel strategy to segregate patient information from provider information. Providers already have the power to set prices and health IT plays the central role.

By rebranding HIPAA as “Meaningful Consent” and making patients second-class citizens in Meaningful Use Stage 2 interoperability, providers and regulators are working together to keep it that way.

Essential consumer protections such as price transparency or independent decision support are scarce in the US healthcare system. The journalists are shouting from the rooftops.

There’s  $1 Trillion (yes, $3,000 per person per year) of unwarranted and overpriced health services steering the Federal health IT bus with an information asymmetry strategy. Those of us that want to see universal coverage succeed need the information transparency tools to drive for changes.

Here’s how it works: The department of Health and Human Services (HHS) controls the health IT incentives and regulations. HIPAA applies to most licensed health services providers. Laboratories and devices are regulated by Medicare and the FDA.

Unlicensed services offered directly to patients, such as personal health records, web info sites and apps are regulated by the FTC. Separate regulatory domains facilitate the segregation of information and contribute to the lack of transparency by making patient-directed services use delayed and degraded information. This keeps independent advice from FTC-regulated service providers from illuminating the specific abuses.

The segregation of patient information from “provider” information is the current federal regulatory strategy. It’s even more so in the states. By making patients into second-class citizens, the providers can avoid open scrutiny, transparent pricing, and independent decision support.

Federal regulators then create a parallel system where information is delayed, diluted, and depreciated by lack of “authenticity”. This is promoted as “patient engagement”. For regulators, it’s a win-win solution: the providers support the regulation that enables their price fixing and many patient advocates get to swoon over patient engagement efforts.

The proof of this strategy became clear on the first day of Health IT Week – the Consumer Health IT Summit.

Continue reading “A Troubling Strategy at Health IT Week”

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MASTHEAD


Matthew Holt
Founder & Publisher

John Irvine
Executive Editor

Jonathan Halvorson
Editor

Alex Epstein
Director of Digital Media

Munia Mitra, MD
Chief Medical Officer

Vikram Khanna
Editor-At-Large, Wellness

Maithri Vangala
Associate Editor

Michael Millenson
Contributing Editor










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