CHIME Responds to Modified Meaningful Use Rules

Following the release today of the finalized modified rules for the current stage of meaningful use, CHIME released the following statement, summarizing the position of many in healthcare. Overall, the organization supports the modifications, including the adopted 90-day reporting period:

We are pleased that the Centers for Medicare & Medicaid Services today finalized modifications to the current stages of the Meaningful Use program and agreed to extend the comment period on Stage 3. CHIME and its 1,700-plus members agree with CMS that it is time to focus the meaningful use program on adoption of information technology systems that improve both the quality and safety of patient care.

The 752-page rule grants flexibility for providers who are doing their best to not only meet the intent of the federal program, but also ensure the adoption of health information technology that improves patient care.

Importantly, the rule adopts a 90-day reporting period for the current stages of the program, down from 365 days. CHIME has long called for a 90-day reporting period and applauds CMS for adopting this new standard. While several members are positioned to take advantage of this shorter period, others will be challenged to meet it since there are fewer than 90 days remaining in the year. We urge CMS to implement a hardship exemption for those unable to meet this timeframe.

CHIME also applauds the agency for modifying requirements surrounding patient access to electronic records. The rule stipulates that for 2015 and 2016, one patient discharged from a hospital view, download or transmit their electronic record.

With regard to Stage 3, the extra comment period will enable providers, CMS and other stakeholders to ensure that the next stage of Meaningful Use advances interoperability and takes into account new payment models being advanced by Medicare.

Also today, the Office of the National Coordinator for Health Information Technology finalized a rule on certification of electronic health records. CHIME supports key provisions in the rule that should lead to greater transparency regarding vendor products; improved testing and surveillance of health IT, and an improved focus on user-centered design.

We are reviewing the regulations and will have more detailed comments in the coming days.

CMS releases the 2013 PQRS and Electronic Prescribing (e-prescribing) Incentive Program Report

The Centers for Medicare & Medicaid Services (CMS) releases the 2013 Physician Quality Reporting System (PQRS) and Electronic Prescribing (e-prescribing) Incentive Program Experience Report, providing data and trends on participation, incentive eligibility, incentive payments and payment adjustments since the beginning of the programs.

The 2013 report found that there was an increase in participation from eligible professionals and in reporting clinical quality information for both PQRS and the e-prescribing Incentive Program, reflecting both increased use of electronic prescribing as well as increased tracking and reporting of important quality information. The report also indicates progress in CMS’ efforts to improve quality measurements, and to encourage building a national electronic health information infrastructure in the United States.

Report highlights include:

In 2013, 641,654 eligible professionals participated either as individuals or as part of PQRS group practices, through at least one reporting mechanism, a 47 percent increase from the 435,931 who participated in 2012. Approximately 51 percent of the 1.25 million professionals who were eligible to participate in 2013 participated in PQRS. The 2013 PQRS incentive payments totaled $214,551,741.

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CMS Releases First Ever Hospital Compare Star Ratings

The Centers for Medicare & Medicaid Services (CMS) for the first time introduced star ratings on Hospital Compare, the agency’s public information website, to make it easier for consumers to choose a hospital and understand the quality of care they deliver. According to the organization, “This announcement builds on a larger effort across HHS to build a healthcare system that delivers better care, spends healthcare dollars more wisely, and results in healthier people.”

The Hospital Compare star ratings relate to patients’ experience of care at almost 3,500 Medicare-certified acute care hospitals. The ratings are based on data from the Hospital Consumer Assessment of Healthcare Providers and Systems Survey (HCAHPS) measures that are included in Hospital Compare. HCAHPS has been in use since 2006 to measure patients’ perspectives of hospital care, and includes topics like:

“The patient experience Star Ratings will make it easier for consumers to use the information on the Hospital Compare website and spotlight excellence in health care quality,” said Dr. Patrick Conway, acting principal deputy administrator for CMS and deputy administrator for Innovation and Quality. “These star ratings also encourage hospitals and clinicians to strive to continuously improve the patient experience and quality of care delivered to all patients.”

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CMS’ Pioneer ACO Program: Results to Date and Changes Ahead

Ken Perez
Ken Perez

Guest post by Ken Perez, vice president of healthcare policy, Omnicell.

The recent flurry of upsets in college football has caused pundits and fans of the sport to do a mid-season recalibration of their projections for their respective teams. Many of the pre-season favorites — selected just seven or eight weeks ago — are no longer in the running for the national championship, others are plugging along pretty much in line with expectations, and a number of “Cinderella” teams have emerged. All teams, no matter how well they have done thus far, will need to make adjustments in the second half of the season.

In like manner, with recent developments and disclosures about CMS’ Pioneer ACO Model, it’s time to do a kind of mid-season recalibration and speculate a bit about needed adjustments to the program.

In August and September, four hospital systems — Sharp HealthCare, a five-hospital system in San Diego, Calif.; Franciscan Alliance in central Indiana; Genesys PHO in Flint, Mich.; and Renaissance Health Network in Pennsylvania — dropped out of the Pioneer ACO Program. With those departures and nine that were previously announced, the number of Pioneers has dropped by 41 percent, from 32 original participants to 19. It should be noted, however, that the majority of the ACOs that have left the program have transferred to the less challenging Medicare Shared Savings Program (MSSP).

On August 6, CMS posted 879 pages of public comments received in response to the CMS Innovation Center’s December 2013 request for information that solicited input on the Pioneer ACO Model as well as new ACO models.

On October 8, CMS released detailed quality and financial data by ACO for the first two years of the Pioneer Program. With regard to quality performance, average quality scores for the Pioneers improved by 19 percent year-to-year, with improved performance on 28 of 33 measures (85 percent) between the first and second year.

Financially, in year one of the program, 13 of the Pioneers (41 percent) met or beat their expenditure benchmarks, qualifying for shared savings and garnering an average of $5.9 million, with the amounts received ranging widely. One Pioneer had to pay CMS a shared loss of $2.6 million, and the remaining 18 ACOs either did not earn shared savings or did not owe CMS money because of  losses.

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CMS Proposed Rule for the Inpatient Prospective Payment System: Taking a Closer Look at the Numbers

Ken Perez
Ken Perez

Guest post by Ken Perez, vice president of healthcare policy, Omnicell.

On April 30, 2014, the Centers for Medicare & Medicaid Services issued its proposed rule for the Inpatient Prospective Payment System (IPPS), which pays about 3,400 acute care hospitals, and the Long-term Care Hospital Prospective Payment System (LTCH PPS), which pays about 435 LTCHs.

The issuance of this proposed rule is a significant event, as it discloses CMS’s intent regarding the average change (increase or decrease) to the IPPS reimbursement rate, what one might call an “annual inflation adjustment.”

While CMS projects that the payment rate update to general acute care hospitals will be 1.3 percent in FY 2015—which on the face of it doesn’t look too bad—it’s important to understand how CMS arrived at that figure, what is the projected overall impact on hospital payments because of other regulatory changes, and how the proposed update compares with the recommendation of the nonpartisan Medicare Payment Advisory Commission (MedPAC).

How did CMS arrive at the 1.3 percent update (adjustment)?

CMS started with a proposed annual market basket update (inflation projection) from research firm IHS of 2.7 percent. That starting point was then reduced, per the Affordable Care Act, by a multi-factor productivity adjustment of 0.4 percent and a specified reduction to the market basket update of 0.2 percent, yielding 2.1 percent. Then CMS reduced it by a documentation and coding recoupment adjustment (basically to correct for past, unintended documentation and coding over payments) of 0.8 percent, resulting in a net update of 1.3 percent.

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Participation Rises in Medicare Physician Quality Reporting System and Electronic Prescribing Incentive Program

The Centers for Medicare & Medicaid Services (CMS) today released the 2012 Physician Quality Reporting System and Electronic Prescribing (eRx) Experience Report, showing a significant increase in participation in two key programs that allow eligible professionals to earn incentive payments through voluntary participation.

“Our physician and other clinician quality programs reached new records this year with over 430,000 professionals participating in the Physician Quality Reporting System and over 340,000 e-prescribing,” said Patrick Conway, M.D. deputy Administrator for innovation and quality and chief medical officer at CMS. “Clinicians are actively measuring and reporting on quality, and CMS is in the beginning stages of adding this information to the Physician Compare website, which can be viewed by patients. Measuring, transparently sharing, and improving quality performance is key to a better health system.”

The full report can be found at

The Physician Quality Reporting System (PQRS) has been using incentive payments, and will begin to use payment adjustments in 2015, to encourage eligible health care professionals to report on designated quality measures. The Electronic Prescribing (eRx) Incentive Program used a combination of incentive payments and payment adjustments to encourage electronic prescribing by eligible professionals.

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The Importance of Preparing for a Meaningful Use Audit Before Attestation

Kay Jackson
Kay Jackson

Guest post by Kay Jackson of Iatric Systems, Inc.

Hospitals and other healthcare organizations in the midst of the complex meaningful use attestation process often see the attestation itself as the end of the process. It is not. Today, 20 percent of hospitals are being selected for a meaningful use audit after attestation. That’s why it’s important that, while preparing for attestation, hospitals also get prepared to be audited.

Iatric Systems help to longtime customer Memorial Healthcare in their attestation process — and successfully passing their recent audit — as well as our work with other customers, has revealed how important this preparation can be. Not passing an audit results in having to pay back 100 percent of any incentive money already received.

Much of the decisions made and records kept during the process of attestation affect the outcome of an audit, as does careful attention to the details. One hospital being audited had accidently transposed a single number. This simple mistake meant many hours of extra effort to find the error and then straighten it out with the independent auditing agency.

What follows are the components currently included in an audit request to eligible hospitals from the Centers for Medicare and Medicaid Services (CMS):

Part I – General Information:

As proof of use of a Certified Electronic Health Record Technology system, provide a copy of your licensing agreement with the vendor or invoice. Please ensure that the licensing agreement or invoices identify the vendor, product name and product version number of the Certified Electronic Health Record Technology system utilized during your attestation period. If the version number is not present on the invoice/contract, please supply a letter from your vendor attesting to the version number used during your attestation period.

Provide documentation to support the method (Observation Services or All ED Visits) chosen to report Emergency Department (ED) admissions designating how patients admitted to the ED where included in the denominator of certain meaningful use core and menu measures (i.e. an explanation of how the ED admissions were calculated and a summary of ED admissions).

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The Case for Federal Oversight of EHR Vendors to Promote Interoperability and Usability

James Hofert

Guest post by James Hofert, Roy Bossen, Linnea Schramm and Michael Dowell of Hinshaw & Culbertson.

In 2013, healthcare industry stakeholders, including associations, EHR vendors, practitioners and providers, raised significant concerns relating to the implementation timing of meaningful use Stage 2 and 3 criteria, including problems with interoperability, usability and regulatory failure to assess “value added” by implementation of meaningful use criteria to date. On December 6, 2013, federal officials announced that Centers for Medicare and Medicaid Services (“CMS”) were proposing a new timeline for the implementation of meaningful use stage criteria for the Medicare and Medicaid Electronic Health Record (“EHR”) incentive programs. The Office of the National Coordinator for Health Information Technology (“ONC”) further proposed a more regular approach for the update of ONC’s certification regulations.

Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers had completed at least two years in Stage 2. The goal of the proposed changes is twofold; to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2, as well as evaluate data from Stage 1 and Stage 2 compliance, to date, to create and form policy decisions for Stage 3.

Roy Bossen

CMS expects to release proposed rulemaking for Stage 3 in the fall of 2014, which may further define this proposed new timeline. Stage 3 final rules would follow in the first half of 2015.

Despite CMS’s positive response to stakeholders concerns relating to the timeline for implementation of Stage 2 and Stage 3 meaningful use criteria, significant reservations continue to be enunciated, on a monthly basis, by providers at both Health information technology (“HIT”) policy committee and work group meetings. Providers continue to urge rule makers to institute consensus standards that could be adopted broadly across the healthcare industry to ensure both usability and interoperability.

In early 2013, former national coordinate Farzad Mostashar chastised electronic health record vendors for improper behavior in the marketing and sales of systems that continued to frustrate interoperability goals. This frustration with EHR vendors continues to be enunciated in HIT policy committee and work group meetings as recently as January of 2014.

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Centers for Medicare & Medicaid Services Announces Delay of Meaningful Use

The Centers for Medicare & Medicaid Services announces a delay of meaningful use, and on Dec. 6, 2013, proposed an extension of Stage 2 through 2016 and beginning Stage 3 in 2017 for those providers that have competed at least two years in Stage 2.

In a post on its site, Robert Tagalicod, CMS’ director of Office of E-Health Standards and Services and Jacob Reider, MD, acting national coordinator for Health Information Technology of ONC, the goal of the change is two-fold: “First, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.

“The phased approach to program participation helps providers move from creating information in Stage 1, to exchanging health information in Stage 2, to focusing on improved outcomes in Stage 3. This approach has allowed us to support an aggressive yet smart transition for providers.”

The two also point out that the timeline allows for enhanced program analysis of Stage 2 data to inform to the improvements in care delivery outcomes in Stage 3, the primary goal of the extension, to give all involved more time to prepare for the future of the reform.

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Stage 2 Patient Engagement is a Tough Hurdle, and It’s a Toothless, Un-enforceable Mandate

The fact that mandatory Stage 2 patient engagement is considered one of the largest meaningful use hurdles should come as a surprise to no one. If it is, that’s somewhat similar to saying that the day before a presidential election you still haven’t decided who you are going to vote for.

I think at this point it’s pretty short sighted to disregard this fact. Healthcare reform does not (yet) reform patients; it’s still a set of mandates for those in the field, practicing in the field and drawing money from the system.

Meaningful use is meaningless as far as patients are concerned. In almost every case they don’t know what it is nor do they care. They’ll only care when one of two things happen. You can take this to the bank: 1.) they are forced to pay or contribute financially in some way or 2.) you take away their right to care (in other words, you mandate them to do something in some way.)

I speak from experience gained from my time leading communication programs for a mandated statewide health insurance program.

If we want to hold patients responsible for their health outcomes, we need to either take away their right in some regard or tax them for their behavior. This is also commonly known as a sin tax. You smoke and you pay the tax on cigarettes.

I’m being a bit overly dramatic on purpose and I don’t recommend either of the two points above, but we should be fully aware that putting meaningful use in the hands of the patients are going to produce disappointing results for every physician and practice hoping to achieve Stage 2.

Just because a practice implements a patient portal doesn’t mean patients will use it. I have used my doctor’s patient portal. Even as a technology enthusiast and healthcare writer, I don’t particularly find it fun to use nor do I find it really helps me engage with my physician. Sure, I can send some emails and pay some bills through it, but that’s just the case. To me, it’s more of a bill pay system and I’m sure I’m not alone here. How many of you enjoy using your credit card company’s online bill pay system?

The only good news on this front is that Centers for Medicare and Medicaid Services might have finally figured this out and may allow for an exception to the ill-conceived requirement, despite Kathleen Sebelius’ insistence that a measure of patient engagement be included in the Stage 2 requirement.

But, I’m not holding my breath that what’s best for physicians in regard to meaningful use attestation will be upheld, though, when the only response to physician frustration over the requirement because patients are not showing any interest is for physicians to “push” their users to use it.

In principal, that response is a lot like breaking a toothless law. Sure a law is on the books, and you broke it, but there’s nothing that you can do about it.

And, as anyone who works in communications understands, push communications only goes so far in the 21st century and not nearly as far as it may have 15 or 20 years ago.

Push and pull; now that’s the kind of conversations that engage. You give, you take; you speak, you listen.

Anything else is nothing but mandatory arrogance from political forces far from the field of actual care.