Meaningful Use Stage 2
CMS recently announced another change to health IT policy in order to offer healthcare providers greater flexibility. But what will the unintended consequences of this latest change be?
Over the Labor Day weekend, CMS announced that the Meaningful Use Stage 2 deadline will be extended through 2016 in order to offer more options and greater flexibility to providers for the certified use of EHRs. In the interest of full disclosure, I found the timing to be strange— a rule published over a holiday weekend seems an odd choice, particularly when it is being touted as a benefit to the industry and the impact on healthcare provider organizations and clinicians, alike, is monumental.
Unfortunately, I think the additional flexibility allotted by this rule is the latest example of the unintended consequences of health IT regulations. In an effort to make things easier and give healthcare providers more leeway, they have, in fact, made the situation unnecessarily more complex.
Agility is not healthcare’s strong suit
It seems at this point, too many options, or waffling between them (for instance the new ICD-10 transition deadline), can be more crippling than stringent regulations, particularly when there is so much on the line. Healthcare organizations don’t have the wherewithal to vacillate with implementations; they are wrestling with string-tight budgets and constantly shifting rules require large cultural and behavioral changes. As a result, as Dr. John Halamka noted, health IT agendas are being constantly hijacked by regulatory changes, such as Meaningful Use and ICD-10.
It now seems that hospital administrative teams and physicians again must endure constantly shifting rules that they’ve been coping with for years under Meaningful Use. As Dr. Ben Kanter, former CMIO of Palomar Health, so astutely noted “A computer system is a tool, just as a scalpel is a tool. What if a surgeon’s scalpel changed every few weeks? How is it possible to deliver good care if the primary tool you are using keeps changing on an irregular basis?” Continue reading “Sometimes the Best Choice is the Simplest One”
Filed Under: THCB
Tagged: Certification, CMS, EHR, ICD-10, Meaningful Use Stage 2, Washington
Sep 5, 2014
MU stage 2 is making everyone miserable. Patients are decrying lack of access to their records and providers are upset over late updates and poor system usability. Meanwhile, vendors are dealing with testy clients and the MU certification death march. While this may seem like an odd time to be optimistic about the future of HIT, nevertheless, I am.
The EHR incentive programs have succeeded in driving HIT adoption. In doing so, they have raised expectations of what electronic health record systems should do while bringing to the forefront problems that went largely unnoticed when only early adopters used systems. We now live in a time when EHR systems are expected to share information, patients expect access to their information, and providers expect that electronic systems, like their smartphones, should make life easier.
Moving from today’s EHR landscape to fully-interoperable clinical care systems that intimately support clinical work requires solving hard problems in workflow support, interface design, informatics standards, and clinical software architecture. Innovation is ultimately about solving old problems in new ways, and the issues highlighted by the current level of EHR adoption have primed the pump for real innovation. As the saying goes, “Necessity is the mother of invention,” and in the case of HIT, necessity has a few helpers.
Continue reading “Why I Am Still Optimistic About the Future of HIT”
Filed Under: Tech, THCB
Tagged: Cloud, HIT adoption, HITECH, iPhone, Marc Andreesen, Meaningful Use Stage 2
Aug 17, 2014
The Meaningful Use program is at a critical inflection point. On one hand, the payers could jump on the MU bandwagon, follow Medicare’s example and demand provider MU attestation.
On the other hand, they could throw private practice a bone and help them weather the storm until MU goes away or loses its teeth. Let me explain.
Payers could take the easy money and penalize according to the upcoming ACA “adjustment” schedule. Lots of people think this is inevitable. This would certainly provide an easy way to increase payer revenue and is as simple as letting the practices [continue] to do all the work.
However, this would be incredibly short-sighted.
Meaningful use, as things stand in 2014, has not been shown to improve patient care. Indeed, it is common for Stage 1 attesting MDs to abandon the program during Stage 2, with many doctors citing lack of efficacy of the program. Stage 3 MU is projected to have even worse results.
What this tells me is that the stress and time-cost of MDs and their staff is not worth the benefits of Meaningful Use. Don’t get me wrong – there are some great things in the MU guidelines, and we are implementing them in the software we create, but they are overshadowed by the onerous, less-effective 5% and it’s all or nothing. There is no MU wiggle-room. These days you have to have real grit and determination to stay in private practice, no matter your specialty.
Without financial support or legislative reform, Meaningful Use will eventually drive independent doctors out of business.
That’s bad news for payers.
Continue reading “The Case For Payers to Oppose Meaningful Use”
Filed Under: Tech, THCB
Tagged: Adjustment schedule, Meaningful Use, Meaningful Use Stage 2, Meaningful Use Stage 3
Aug 13, 2014
Physicians are lining up against Meaningful Use.
In a detailed letter sent this week to CMS Administrator Marilyn Tavenner and National Coordinator Karen DeSalvo, MD, the American Medical Association presented a long list of ideas to make Meaningful Use better for doctors.
The AMA warned that “unless significant changes are made to the current program and future stages,” doctors will drop out of the meaningful use program, patients will suffer as existing EHRs fail to migrate data for coordinated care, thousands of doctors will incur financial penalties, and new delivery models requiring data will be jeopardized.”
All of which is true. But the AMA didn’t go far enough.
Meaningful use is well intentioned, but like a teacher who “teaches to the test,” the program has created a byzantine system that might pass the test of meaningful use stages, but is not producing meaningful results for patients and clinicians.
A formal study published in the April 2014 issue of JAMA Internal Medicine reveals there’s no correlation between quality of care and meaningful use adherence. This study validates what common sense has told many of us for the last few years.
Meaningful Use Stage 1 was a jump-start for EMR adoption in the industry. That’s a good thing, I suppose, although meaningful use also created a false economic demand for mediocre products. It’s time to put an end to the federal meaningful use program, eliminate the costly administrative overhead of meaningful use, remove the government subsidies that also create perverse incentives, and let “survival of the fittest” play a bigger part in the process.
Let the fruits of EMR utilization go to the organizations that commit, on their own and without government incentives, to maximizing the value of their EMR investments toward quality improvement, cost reduction, and clinical efficiency.
Continue reading “The Case for Dropping MU Stages 2 and 3″
Filed Under: Tech, THCB
Tagged: Dale Sanders, Dashboard, John Glaser, Meaningful Use Stage 2, Meaningful Use Stage 3, Northwestern
May 17, 2014
Why politics, parity and performance requirements mean behavioral health hospitals should adopt now.
Imagine you go to work one day and your boss says all employees will be evaluated based on the performance of a new set of job skills that require additional training and, perhaps, new computer hardware and software. The boss also announces that some employees will be reimbursed for the cost of acquiring these skills and tools. You aren’t among this privileged group.
In government, this is called an unfunded mandate. The unlucky employee in this case is psychiatric hospitals, who aren’t eligible for Meaningful Use incentives even while Congress and the Obama administration have legislated greater accountability:
A precursor to the 2010 Affordable Care Act (ACA), the Mental Health Parity and Addiction Equity Act of 2008 mandated that insurers must make the financial cost of benefits—co-pays, deductibles, out-of-pocket maximums—equal for psychiatric and physical care.
By making behavioral health an Essential Health Benefit, the ACA requires health plans to cover mental health on par with other types of care.
On October 1, 2012, CMS launched the Inpatient Psychiatric Facility Quality Reporting Program (IPFQR), a pay-for-reporting program in which facilities could lose federal dollars by not providing data on Hospital Based Inpatient Psychiatric Services (HBIPS):
- Screening for violence risk, psycho trauma Hx, patient strengths
- Hours of physical restraint use
- Hours of seclusion use
- Patients discharged on multiple antipsychotic medications
- Patients discharged on multiple antipsychotic medications with appropriate justification
- Post discharge continuing care plan created
- Post discharge continuing care plan transmitted to next level of care provider upon discharge
Whether explicit or implicit, these programs amount to unfunded EHR mandates. How so?
Organizations still on paper records will find it expensive and inefficient to capture events and collect results for both reporting to government and submitting claims to insurance companies. Hospitals will need to train clinicians to document post-discharge continuity of care plans.
They will have to train staff to send plans by snail mail or fax to the provider at the next level. Then they will also need to do chart reviews to assure that all these steps took place and the data is recorded in a spreadsheet or database. Any quality improvement process that requires benchmarking and scoreboarding of performance based on these measures will be a tremendous challenge using paper records.
Continue reading “An Unfunded Mandate For Behavioral Health”
Filed Under: Uncategorized
Tagged: Edmund Billings, Helping Families Mental Health Crisis Act, Meaningful Use Stage 2, Mental Illness, Tim Murphy
May 13, 2014
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
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?”
Filed Under: Tech, THCB
Tagged: Edmund Billings, HIT, ICD-10, Meaningful Use Stage 2
Dec 17, 2013