Meaningful Use Stage 2
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”
Filed Under: Uncategorized
Tagged: Accountable Care Act, HIPAA Omnibus Rule, HIT, ICD-10, John Halamka, Meaningful Use Stage 2, National Health IT Timeline
Nov 20, 2013
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″
Filed Under: THCB
Tagged: HIT, John Halamka, Meaningful Use, Meaningful Use Stage 2, Quality measurement
Nov 6, 2013
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”
Filed Under: Tech, THCB
Tagged: Adrian Gropper, Blue Button, HHS, HIPAA, HIT, HITECH Act, independent decision support, Meaningful Consent, Meaningful Use Stage 2, National Health IT Week
Sep 19, 2013
In 2013, I’m focused on five major work streams:
· Meaningful Use Stage 2, including Electronic Medication Administration Records
· ICD10, including clinical documentation improvement and computer assisted coding
· Replacement of all Laboratory Information Systems
· Compliance/Regulatory priorities, including security program maturity
·Supporting the IT needs of our evolving Accountable Care Organization including analytics for care management
I’ve written about some of these themes in previous posts and each has their uncharted territory.
One component that crosses several of my goals is how electronic documentation should support structured data capture for ICD10 and ACO quality metrics.
How are most inpatient progress notes documented in hospitals today? The intern writes a note that is often copied by the resident which is often copied by the attending which informs the consultants who may not agree with content. The chart is a largely unreadable and sometimes questionably useful document created via individual contributions and not by the consensus of the care team. The content is sometimes typed, sometimes dictated, sometimes templated, and sometimes cut/pasted. There must be a better way.
Continue reading “Brainstorming About the Future of Clinical Documentation”
Filed Under: Uncategorized
Tagged: ACO, Clinical Documentation, CMS, Geisinger, ICD-10, John Halamka, Kaiser, Mayo, Meaningful Use Stage 2, Physicians, quality metrics, SNOMED-CT
Dec 18, 2012
Today I’m speaking at the ONC annual meeting as part of panel discussing interoperability.
For years, patients, providers and payers have complained that EHRs “do not talk to each other.”
By 2014, I expect this issue to disappear.
Do I expect that every state and territory will have a robust, sustainable healthcare information exchange by 2014? No
Do I expect that every provider will be connected to a Nationwide Health Information Network by 2014? No
Do I expect that a single vendor will create a centrally hosted method to share data by 2014 just as Sabre did for the airline industry in the 1960′s? No
What I expect is that Meaningful Use Stage 2 will provide the technology, policy, and incentives to make interoperability real.
Stage 2 requires that providers demonstrate, in production, the exchange of clinical care summaries for 10% of their patient encounters during the reporting period. The application and infrastructure investment necessary to support 10% is not much different than 100%. The 10% requirement will bring most professionals and hospitals to the tipping point where information exchange will be implemented at scale, rapidly accelerating data liquidity.
Continue reading “Are We Finally Seeing the Dawn of the Golden Age of Interoperability?”
Filed Under: Uncategorized
Tagged: Blue Button initiative, Care coordination, EHR, health information exchange, Interoperability, John Halamka, Meaningful Use Stage 2, ONC, Policy
Dec 12, 2012
In a time of EHR naysayers, mean-spirited election year politics, and press misinterpretation (ONC and CMS do not intend to relax patient engagement provisions), it’s important that we all send a unified message about our progress on the national priorities we’ve developed by consensus.
1. Query-based exchange – every country in the world that I’ve advised (Japan, China, New Zealand, Scotland/UK, Norway, Sweden, Canada, and Singapore) has started with push-based exchange,replacing paper and fax machines with standards-based technology and policy. Once “push” is done and builds confidence with stakeholders, “pull” or query-response exchange is the obvious next step. Although there are gaps to be filled, we can and should make progress on this next phase of exchange. The naysayers need to realize that there is a process for advancing interoperability and we’ll all working as fast as we can. Query-based exchange will be built on top of the foundation created by Meaningful Use Stage 1 and 2.
2. Billing - although several reports have linked EHRs to billing fraud/abuse and the recent OIG survey seeks to explore the connection between EHR implementation and increased reimbursement, the real issue is that EHRs, when implemented properly, can enhance clinical documentation. The work of the next two years as we prepare for ICD-10 is to embrace emerging natural language processing technologies and structured data entry to create highly reproducible/auditable clinical documentation that supports the billing process. Meaningful Use Stage 1 and 2 have added content and vocabulary standards that will ensure future documentation is much more codified.
3. Safety – some have argued that electronic health records introduce new errors and safety concerns. Although it is true that bad software implemented badly can cause harm, the vast majority of certified EHR technology enhances workflow and reduces error. Meaningful Use Stage 1 and 2 enhance medication accuracy and create a foundation for improved decision support. The HealtheDecisions initiative will bring us guidelines/protocols that add substantial safety to today’s EHRs.
Continue reading “State of the EHR Nation”
Filed Under: Electronic Health Records
Tagged: Meaningful Use Stage 2, Medicare, ONC, Patient Safety, Privacy, Query-based Exchange
Nov 6, 2012
2012 has been a challenging year for me.
On the personal side, my wife had cancer. Together we moved two households, relocated her studio, and closed her gallery. This week my mother broke her hip in Los Angeles and I’m writing from her hospital room as we finalize her discharge and home care plan before I fly back to Boston.
On the business side, the IT community around me has worked hard on Meaningful Use Stage 2, the Massachusetts State Health Information Exchange, improvements in data security, groundbreaking new applications, and complex projects like ICD10 with enormous scope.
We did all this with boundless energy and optimism, knowing that every day we’re creating a foundation that will improve the future for our country, communities, and families.
My personal life has never been better – Kathy’s cancer is in remission, our farm is thriving, and our daughter is maturing into a fine young woman at Tufts University.
My business life has never been better – Meaningful Use Stage 2 provides new rigorous standards for content/vocabulary/transport at a time when EHR use has doubled since 2008, the State HIE goes live in one week, and BIDMC was voted the number #1 IT organization the country.
It’s clear that many have discounted the amazing accomplishments that we’ve all made, overcoming technology and political barriers with questions such as “how can we?” and “why not?” rather than “why is it taking so long?” They would rather pursue their own goals – be they election year politics, academic recognition, or readership traffic on a website.
As many have seen, this letter from the Ways and Means Committee makes comments about standards that clearly have no other purpose than election year politics. These House members are very smart people and I have great respect for their staff. I’m happy to walk them through the Standards and Certification Regulations (MU stage 1 and stage 2) so they understand that the majority of their letter is simply not true – it ignores the work of hundreds of people over thousands of hours to close the standards gaps via open, transparent, and bipartisan harmonization in both the Bush and Obama administrations.
Continue reading “A Time for Boundless Energy and Optimism”
Filed Under: OP-ED, THCB
Tagged: 2012 Election, BIDMC, Bush, Cancer, Cerner, Costs, Donald Berwick, EHR, Epic, HIT, House Ways and Means Committee, IHI, John Halamka, Massachusetts State Health Information Exchange, Meaningful Use Stage 2, Medicare, MEDITECH, NYT, Obama, Standards and Certifications Regulation, The States, Upcoding, WSJ
Oct 9, 2012
Six months to the day after the Centers for Medicare and Medicaid Services (CMS) released the “preliminary rules” for Meaningful Use, the final rules are in. For clinicians and policymakers who want to see Electronic Health Records (EHRs) play a key role in driving improvements in the healthcare system, there’s a lot to like here.
For the Office of the National Coordinator (ONC), the agency that oversees the federal health information technology incentive program, the Meaningful Use rules are a balancing act. On one hand, ONC wants to get as many clinicians and hospitals on board with simply adopting EHRs (and thus, the need to set a low bar). On the other hand, they want to ensure that once people start using EHRs, they are using them in a “meaningful” way to drive improvements in care (and thus, the need to set a high bar). I think ONC got that balance just about right.
Let me begin with a little background. In 2009, Congress passed the Health Information Technology for Economic and Clinical Health (HITECH) Act, setting aside about $30 billion for incentives for ambulatory care providers and acute-care hospitals to adopt and “meaningfully use” EHRs. Congress specified that the executive branch would define Meaningful Use (MU) and would do so in three stages. The first stage was finalized in 2010 and its goals were simple – start getting doctors and hospitals on board with the use of EHRs. By most metrics, stage 1 was quite successful. The proportion of doctors and hospitals using EHRs jumped in 2011, and all signs suggested continued progress in 2012. Through July 2012, approximately 117,000 eligible professionals and 3,600 hospitals have received some sort of incentive payment.
Continue reading “The EHR “Final Rule” (Finally)”
Filed Under: THCB
Tagged: ACOs, Ashish Jha, CMS, EHR, EHR incentives, Health Data, HITECH Act, Meaningful Use, Meaningful Use Stage 2, ONC, regional extension centers
Aug 27, 2012
Yesterday, Meaningful Use Stage 2 was released.
You can read the final rule here and you can read the announcement here.
As we read and parse the 900 or so pages of government-issued goodness, you can expect lots of commentary and discussion. Geek Doctor already has a summary and Motorcycle Guy can be expected to help us all parse the various health IT standards that have been newly blessed. Expect Brian Ahier to also be worth reading over the next couple of days.
I just wanted to highlight one thing about the newly released rules. As suspected, the actual use of the Direct Project will be a requirement. That means certified electronic health record (EHR) systems will have to implement it, and doctors and hospitals will have to exchange data with it. Awesome.
More importantly, this will be the first health IT interoperability standard with teeth. The National Institute of Standards and Technology (NIST) will be setting up an interoperability test server. It will not be enough to say that you support Direct. People will have to prove it. I love it. This has been the problem with Health Level 7 et al for years. No central standard for testing always means an unreliable and weak standard. Make no mistake, this is a critical and important move from the Office of the National Coordinator for Health Information Technology (ONC).
Continue reading “The Direct Project Has Teeth, but It Needs Pseudonymity”
Filed Under: Uncategorized
Tagged: Direct Project, EHR, Fred Trotter, Meaningful Use, Meaningful Use Stage 2, NIST
Aug 24, 2012
Over the past decade, I’ve seen a number of studies asking people whom they trust among various health care stakeholders. Nurses, pharmacists, and doctors always come out at the top. Beyond that:
·Trust of hospitals tends to be high (60–80%)
·Trust of health plans is at the bottom of the heap (10–20%)
Is this written in stone for the future? I don’t think so…and the dynamics for change are in motion. Please read on.
Here’s the emerging picture I’m seeing:
·Hospitals are dragging their feet in connecting you with your electronic health information.
·Health plans are highly motivated to connect you with your health information.
Hospitals Keeping You from Your Health Records
Yesterday the American Hospital Association released a 68 page letter commenting on proposed regs for Meaningful Use Stage 2. Putting aside my usual analytic tendencies, I’ll simply describe the letter as whiny, snivelly, “can’t do”, mean, and thick-headed.
Continue reading “Hospitals or Health Plans: Who Do You Trust to “Connect” You with Your Health Records?”
Filed Under: THCB, The Business of Health Care
Tagged: AHA, Boston Consulting Group, e-Patient Dave, electronic health information, HIPAA, Meaningful Use Stage 2, Regina Holiday, Smart Medicine, trust
May 10, 2012