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.
Remember the Ford Pinto and the AMC Pacer, aka the Pregnant Pinto?
Both serve as reminders of an in era in which the American auto industry lost its way and assumed drivers would buy whatever they put on the lot. Foreign competition, primarily from Japan, filled the void created by American apathy for quality and design, and the industry has never been the same.
Admittedly, the comparison of cars and EHRs is less than apt, but health IT also assumes healthcare will buy what we’re selling because the feds are paying them to. And, like the Pinto, what we’re selling inspires something less than awe. In short, we are failing our clinical users.
Why? Because we’re cramming for the exam, not trying to actually learn anything.
Myopic efforts to meet certification and compliance requirements have added functionality and effort tangential to the care of the patient. Clinicians feel like they are working for the system instead of it working for them. The best EHRs are focused on helping physicians take care of patients, with Meaningful Use and ICD-10 derivative of patient care and documentation.
I recently had dinner with a medical school colleague who gave me insight into what it’s like to practice in the new healthcare era. A urologist in a very busy Massachusetts private practice, he is privileged to use what most consider “the best EHR.”
Arriving from his office for a 7 PM dinner, he looked exhausted, explaining that he changed EHRs last year and it’s killing him. His day starts at 7 AM and he’s in surgery till noon. Often double or triple booked, he sees 24 patients in the afternoon, scribbling notes on paper throughout as he has no time for the EHR. After dinner he spends 1.5 to 2 hours going over patient charts, dictating and entering charges. What used to take 1 hour now requires much more with the need to enter Meaningful Use data and ICD coding into the EHR. He says he is “on a treadmill,” that it should be called “Meaningless Use,” and he can’t imagine what it will be like “when ICD-10 hits.”
My friend’s experience is representative, not anecdotal. A recent survey by the American College of Physicians and American EHR Partners provides insight into perceptions of Meaningful Use among clinicians.
According to the survey, between 2010 and 2012, general user satisfaction fell 12 percent and very dissatisfied users increased by 10 percent.
Over the next few months, Jacob Reider will serve as the interim National Coordinator for Healthcare IT while the search continues for Farzad Mostashari’s permanent replacement.
What advice would I give to the next national coordinator?
David Blumenthal led ONC during a period of remarkable regulatory change and expanding budgets. He was the right person for the “regulatory era.”
Farzad Mostashari led ONC during a period of implementation when resources peaked, grants were spent, and the industry ran marathons every day to keep up with the pace of change. He was the right person for the “implementation era”
The next coordinator will preside over the “consolidate our gains” era. Grants largely run out in January 2014. Budgets are likely to shrink because of sequestration and the impact of fiscal pressures (when the Federal government starts operating again). Many regulatory deadlines converge in the next coordinator’s term.
The right person for this next phase must listen to stakeholder challenges, adjust timelines, polish existing regulations, ensure the combined burden of regulations from many agencies in HHS do not break the camel’s back, and keep Congress informed every step of the way. I did not include parting the Red Sea, so maybe there is a mere human who could do this.
What tools does the coordinator have in an era of shrinking budgets?
At present, Meaningful Use Stage 2, ICD-10, the Affordable Care Act, HIPAA Omnibus Rule, and numerous CMS imperatives have overlapping timelines, making it nearly impossible for provider organizations to maintain operations while complying with all the new requirements.
Now that Labor Day has come and gone, I’ve thought about the months ahead and the major challenges I’ll face.
1. Mergers and Acquisitions
Healthcare in the US is not a system of care, it’s a disconnected collection of hospitals, clinics, pharmacies, labs, and imaging centers. As the Affordable Care Act rolls out, many accountable care organizations are realizing that the only way to survive is to create “systemness” through mergers, acquisitions, and affiliations. The workflow to support systemness may require different IT approaches than we’ve used in the past. We’ve been successful to date by leaving existing applications in place and building bidirectional clinical sharing interfaces via “magic button” viewing and state HIE summary exchange. Interfacing is great for many purposes. Integration is better for others, such as enterprise appointment scheduling and care management. Requirements for systemness have not yet been defined, but there could be significant future work ahead to replace existing systems with a single integrated application.
2. Regulatory uncertainty
Will ICD10 proceed on the October 1, 2014 timeline? All indications in Washington are that deadlines will not be changed. Yet, I’m concerned that payers, providers and government will not be ready to support the workflow changes required for successful ICD10 implementation. Will all aspects of the new HIPAA Omnibus rule be enforced including the “self pay” provision which restricts information flow to payers? Hospitals nationwide are not sure how to comply with the new requirements. Will Meaningful Use Stage 2 proceed on the current aggressive timeline? Products to support MU2 are still being certified yet hospitals are expected to begin attestation reporting periods as early as October 1. With Farzad Mostashari’s departure from ONC, the new national coordinator will have to address these challenging implementation questions against a backdrop of a Congress which wants to see the national HIT program move faster.
3. Meaningful Use Stage 2 challenges
Although attestation criteria are very clear (and achievable), certification is quite complex, especially for a small self development shop like mine. One of my colleagues at a healthcare institution in another state noted that 50 developers and 4 full analysts are hard at work at certification for their self built systems. I have 25 developers and a part time analyst available for the task. I’ve read every script and there are numerous areas in certification which go beyond the functionality needed for attestation. Many EHR vendors have described their certification burden to me. I am hopeful that ONC re-examines the certification process and does two things – removes those sections that add unnecessary complexity and makes certification clinically relevant by using scenarios that demonstrate a real world workflow supporting the functionality needed for attestation.
· 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.
Oh, that clever Center for Public Integrity. Look what they’ve gone and done now! My, oh my. According to the article, doctors are much of the the problem, billing “billions” of Medicare upcharges according to the center.
But what if the medical coding game itself is flawed? Stop for a moment and imagine what it would look like if lawyers billed like doctors. Suddenly, we see how bizarre the world of government billing codes and chart-completion mandates has become.
Not long ago I asked readers what my time is worth on a per-hour basis. Collectively and independently, they settled on a number of about $500/hr (see the comments). Now look for a moment at what Medicare pays, even at its highest level of billing for a physician’s time for evlauation and management of a medical problem: for 40 minutes of a physician’s time, it’s $140 (or $210/hr) before taxes. Again, we see another disconnect as to how doctors are valued in our current system.
Doctors are working long hours to collect these fairly low fees from Medicare while jumping more hoops than ever to do so. They have become pseudo-experts at the coding game, trying to get as much money for their extra efforts as legally possible. But these fees paid by Medicare do not cover payments for time spent on phone calls, e-mails, and working insurance denials. These services are still considered by our system as gratis. To partially counteract this coding problem, doctors realized (and the government insisted) that doctors use electronic medical records.
But when independent doctors set out to implement these records they quickly discovered that the expense and long-term maintenance costs of local office-based EMRs could not compete with more sophisticated systems already in use by their neighboring large health care systems. Because of ever-increasing cost-of-living and overhead costs, not to mention the threats of large fee cuts, doctors have migrated to large health systems faster than ever. With the fancier electronic record at those systems (streamlined for billing, collections, and marketing) fields required for higher billing codes (but not always material to the problem at hand) are completed in less time. So are doctors really the problem?
At HIMSS, I met with many healthcare CIOs as a part of CHIME focus groups to discuss their readiness for ICD-10. One area we explored was the impact of the delay. Most were a bit frustrated by the delay because they had committed the resources and money to an ICD-10 transition plan which was well underway. In some instances CIOs estimated they had expended at least 50 percent of the effort required to meet the compliance deadline. In fact, in one of the focus groups, 10 out of 12 participating CIOs said the delay will be more harmful than helpful. I heard two main reasons for this position:
1. Cost: Hospitals have already committed the resources and budget to transition to ICD-10, and now they will have to continue that effort for a longer period of time.
2. Engagement: It’s harder to engage staff around the importance of clinical documentation and coder education when the media is saying “delay, delay, delay” – it makes it difficult for leaders to convince providers and other stakeholders that it’s a critical priority.
A survey conducted by Edifecs validates this sentiment – 90 percent of healthcare professionals believe that the deadline should not be moved more than a year. Fifty-six percent said that a two-year delay would be “potentially catastrophic.”
However, for smaller physician practices, the delay likely has the opposite impact – more help than harm. Many of these practices were struggling to understand the impact of ICD-10 and find the resources to prepare for the October 2013 deadline. A delay gives them more time to put a plan in place, improve clinical documentation, and ensure they can get reimbursed for services.
There has been a lot of buzz around two pieces of news –in one case, lack of news—in the past week. Last Thursday, HHS Secretary Kathleen Sebelius responded to heavy pressure from the American Medical Association and announced a delay to the ICD-10 implementation deadline, currently set for October 2013.
Meanwhile, the health IT universe continues to wait with baited breath for Sebelius and/or leadership at CMS or ONC to publish the proposed regulations for Stage 2 of the “meaningful use” EHR incentive program. The proposal was supposed to have been out before 35,000 or so health IT industry types descended on Las Vegas for HIMSS12, but it was not to be. As with any major federal rule-making, the White House’s Office of Management and Budget has to vet every word, so it is out of Sebelius’ hands for the moment.
Rumors spreading through the Sands Expo Center and the adjacent Venetian and Palazzo hotels have pegged Wednesday or Thursday for the release date, since national health IT coordinator Dr. Farzad Mostashari is leading a session on Stage 2 meaningful use with other ONC and CMS representatives Wednesday morning, then delivering a keynote address the following day.
In the wake of the ICD-10 bombshell last week, HIMSS itself and other IT-related groups are telling their membership and anyone else who will listen not to slack off when it comes to ICD-10 preparedness. HIMSS CEO Steve Lieber noted in his annual press conference Tuesday that the official HHS statement said the department would “initiate a process to postpone the date by which certain healthcare entities” must meet the requirements. That, to Lieber, suggests the possibility of a delay for physician practices or perhaps small hospitals, but not for larger organizations.Continue reading…
Innovative thinkers and influential healthcare leaders aren’t relying on the decisions coming out of HHS to determine their strategy. Despite the fact that many healthcare organizations were on target to transition from ICD-9 to ICD-10, Health and Human Services (HHS) announced it would initiate a process to postpone the date by which certain healthcare entities have to comply with ICD-10.
The details of the delay have not been revealed, but industry experts are speculating that a one-two year delay is in the works. With only 20 months remaining to the Oct. 1, 2013 deadline, this leaves many organizations in limbo. Do they continue down the path of ICD-10 adoption, revise plans based on speculation about a new timeline or completely put the initiative on hold?
The leaders in healthcare never limited their thinking to a coding mandate. They were aligning their ICD-10 efforts with quality of care initiatives- EMR adoption and improved clinical documentation. They won’t hesitate, they won’t miss a step, and they will focus on providing exceptional care through improved processes, many of which will prepare them for a successful transition to ICD-10 and ICD-11.
The following areas of focus will improve quality of care, reporting and accuracy of reimbursement.
– Lead with purpose- understand the long-term impact of a coding mandate and help providers understand the alignment of greater specificity in coding with quality reporting, improved clinical documentation and clinical decision support.
– Take this time to improve clinical documentation– develop processes and feedback to improve how physicians and other providers document care. This effort will reap financial benefits and directly impact quality of care and reporting.Continue reading…
The case for leapfrogging ICD-10 and holding out for ICD-11 just got a lot more curious. And though it’s not here yet, when ICD-11 is ready, it will be something ICD-10 cannot: A 21st Century classification system.
Now that HHS Secretary Kathleen Sebelius has thrown her department’s hat in the ring, saying late Wednesday that HHS intends to delay ICD-10, the most pertinent question is how long will HHS push back compliance?
“My opinion is that CMS won’t be able to announce three months or six months of delay for ICD-10,” says Mike Arrigo, CEO of consultancy No World Borders (pictured at left). “They will need to announce a delay from October 1, 2013 to at least October 1, 2014 because of CMS fiscal planning calendars.”
Others in the industry are suggesting that even one year is not enough to lighten the burden on physicians, providers and payers enough to make the transition smoother.
“I have a gut feeling they’ll go for two years, who knows?” speculates Steve Sisko, an analyst and technology consultant focused on payers and ICD-10. “Maybe January 2015?”
“We have heard from many in the provider community who have concerns about the administrative burdens they face in the years ahead,” Sebelius said in the statement. “We are committing to work through the rulemaking process, with the provider community, to reexamine the pace at which HHS and the nation implement these important improvements to our healthcare system.”