Guest post by Tom S. Lee, Ph.D., CEO & Founder, SA Ignite.
If the few years since the onset of meaningful use haven’t been proof enough, the speed and unpredictability of regulatory change in the last five months has cemented our field’s status as truly not-for-the-feint-of-heart.
Yesteryear’s glacial rate of change in healthcare IT regulation is nowhere to be seen. May 2014 brought both a CMS reset of the ICD-10 transition deadline to October 1, 2015, and a proposed meaningful use rule to enable the use of 2011 edition certified EHR technology (CEHRT) to meet compliance in 2014. The summer then ended with the August 29th finalization of the 2014 meaningful use final rule, the ensuing disappointment that the mandated start of Stage 2 was not delayed and then the swift Congressional response in the form of the September 15th proposed Flex-IT Act to introduce quarterly meaningful use reporting for 2015; enough to spin heads more than once around.
What’s happened in the field since the publication of the final rule among provider organizations bring the phrase “threading the needle” to mind. To further illustrate, we have culled some sample issues from our client base of more than 8,000 providers, across more than 15 EHR brands, and representing numerous combinations of meaningful use stage, payment year and program. These issues, none of which yet have universal and clean solutions, span three areas for provider organizations as seen in the field: 1) properly adhering to the requirements of the final rule, 2) working within the constraints of what EHR vendors can deliver per the final rule’s timeline, and 3) redirecting or pausing organizational momentum for change on short notice.
Regarding the first consideration, note that the final rule requires that an organization attest that it is “not able to fully implement” 2014 Edition technology because of “delays in 2014 Edition CEHRT availability.” Although the rule outlines what does not meet this eligibility test, provider organizations have a persistent question about what documentation and conditions are sufficient to satisfy the test.
If for no other reason, the following open letter seems worthy of publication. It was sent by HIMSS to HHS’ secretary Sylvia Mathews Burwell on Sept. 30, 2014. The four-page letter, published below for your review, lays out the organization’s professional and political goals for the near term.
HIMSS makes three specific recommendations to HHS, suggesting to the feds where their attention should focus. HIMSS’ recommends immediately pulling three key policy levers: the EHR incentive program, interoperability leading to secure electronic exchange of health information, and electronic reporting of clinical quality measures (CQMs).
HIMSS also makes the strong recommendation for one three-month reporting period in 2015 for meaningful use, as well as publicly reminding HHS that there continues to be support efforts for interoperability. The letter does little than offer a pat on the back to HHS for its efforts, and says that HIMSS offers its support for everything HHS is doing, but the letter also serves as a real reminder that HIMSS is willing to flex a little muscle on behalf of its members if HHS doesn’t listen up or do a little falling in line.
To be clear, I have nothing against HIMSS; if they can get away with telling a federal organization how it is, that’s admirable. However, the letter is soaked with arrogance and bullishness, as if HIMSS is intentionally telling all in healthcare just how big and powerful it is, dammit. No doubt, this is the type of thing that’s gone on for years. I understand how lobbyists work; in fact, I’ve worked with them and understand their game. This is probably just the first time in a while I’ve seen such a blatant outreach effort. After all, it’s not like HHS doesn’t know who or what HIMSS as an organization is, but it seems strong in a nuanced way.
Judge for yourself and read the letter below. Are you a HIMSS member? What do you think of the organization’s power push?
On Sept. 4, 2014, the Centers for Medicare and Medicaid Services (“CMS”) published a final rule that, effective Oct. 1, 2014, implements changes to the Medicare and Medicaid Electronic Health Record Incentive Program in light of industry-wide difficulties in transitioning to EHR technology certified to the 2014 Edition EHR certification criteria (“2014 Edition CEHRT”) during calendar year 2014 for eligible professionals and fiscal year 2014 for eligible hospitals and critical access hospitals. CMS makes no changes to the existing 2014 reporting periods or the requirement in future reporting periods to report for a full year.[1] This final rule also extends Stage 2 for an additional year for those providers first demonstrating meaningful use in 2011 or 2012. Instead of starting Stage 3 in 2016, those providers will now start Stage 3 in 2017. The timeframe for Stage 3 implementation by providers that first demonstrated meaningful use after 2012 is unchanged by this final rule.
Kevin Alonso
Prior to these changes, providers were required to use 2014 Edition CEHRT to demonstrate either Stage 1 or Stage 2 meaningful use in 2014. The shortened 2014 attestation periods implemented in the 2012 final rule were aimed at helping providers make the transition from 2011 Edition CEHRT to 2014 Edition CEHRT, but delays affecting the availability of, and the ability of providers to implement, 2014 Edition CEHRT meant that many providers still might be unable to demonstrate meaningful use, despite their best efforts.
To provide some additional flexibility, CMS will now provide three alternatives routes to demonstrate meaningful use in 2014 for providers facing such difficulties: (1) using 2011 Edition CEHRT only, (2) using a combination of 2011 and 2014 Edition CEHRT, or (3) using 2014 Edition CEHRT for Stage 1 objectives and measures in 2014 for providers scheduled to begin Stage 2. These alternatives will also provide some flexibility in the objectives and measures that providers must meet to demonstrate meaningful use, as summarized in the chart below.[2]
As the Centers for Medicaid and Medicare Services (CMS) and the Office of the National Coordinator for Health IT (ONC) finalized a regulation granting providers additional flexibility in meeting meaningful use (MU) requirements in 2014, the final rule lacked a key provision that would ensure continued EHR adoption and MU participation, according to CHIME.
CHIME issued as statement stating that the organization is “deeply disappointed in the decision made by CMS and ONC to require 365 days of EHR reporting in 2015. This single provision has severely muted the positive impacts of this final rule. Further, it has all but ensured that industry struggles will continue well beyond 2014.”
According to the statement by CHIME, roughly 50 percent of EHs and CAHs were scheduled to meet Stage 2 requirements this year and nearly 85 percent of EHs and CAHs will be required to meet Stage 2 requirements in 2015. Most hospitals who take advantage of new pathways made possible through this final rule will not be in a position to meet Stage 2 requirements beginning October 1, 2014. This means that penalties avoided in 2014 will come in 2015, and millions of dollars will be lost due to misguided government timelines.
Nearly every stakeholder group echoed recommendations made by CHIME to give providers the option of reporting any three-month quarter EHR reporting period in 2015. “This sensible recommendation, if taken, would have assuaged industry concerns over the pace and trajectory of rulemaking; it would have pushed providers to meet a higher bar, without pushing them off the cliff; and it would have ensured the long-term vitality of the program itself. Now, the very future of Meaningful Use is in question,” said CHIME.
Given the tremendous and on-going changes currently taking place in health IT, especially the recent delay in ICD-10, and the ever on-going issues surrounding meaningful use, we remain in a turbulent, yet revolutionary time in the industry. As changes continue to come and behaviors, habits, further reform is activated and enforced, there will only be more of a focus on where we are headed from a technology standpoint.
Given the multiple balls health IT leaders are currently juggling and the rapid changes they are facing from new technology and managing tools that were once thought to be saviors of the sector – patient portals come to mind – I and they are left to wonder what’s next for health IT. With that lingering question, I asked a few folks working directly in the space what they think will occupy the minds of health IT leaders for the short term.
The delay in ICD-10 implementation was met with equal parts relief and frustration. As the healthcare IT industry is evolving, government and regulatory authorities have come up with several certifications to enhance the quality of care for patients. For example, meaningful use incentives have created an artificial market for dozens of immature EHR products. Many EHR vendors have been preoccupied with backlogged implementations and have neglected the usability and innovation of their EHR products. Most concerning to current EHR users are unmet pleas for sophisticated interfaces with other practice programs and complex connectivity, pacing with accountable care progresses and the rapid EHR adoption of mobile devices. Many popular “one size fits all” EHR products have failed to meet the needs of several medical specialties.
Distracted by the process of certifying their EHR products for Stage 2 of meaningful use, not all software vendors have been able to deliver on their Meaningful Use 2 promises to anxious providers; 40 percent of the practices are replacing their EHR systems, as their current systems are cumbersome to use, not integrated, not able to meet regulatory compliance, outdated, have interoperability challenges, inefficient customer support, lacks specialty specific workflow and are not mobile enabled.
Stacy Leidwinger
Stacy Leidwinger, vice president of product marketing, RES Software
A top concern in healthcare right now is securing patient health records. Although the clinical details themselves contain little financial value, the records contain personal patient details that can easily result in stolen identity or credit card information.
In the US, nearly 3 trillion dollars per year is spent on healthcare, which translates to everyone from physicians and pharmacists to well-organized crime syndicates targeting healthcare, usually through the use of stolen patient records and identities.
Two of the weakest points in healthcare security are 1) people tending to underestimate security risks, therefore, becoming vulnerable to social engineering, and 2) the fact that endpoints can’t be physically secured in many cases while continuing to provide needed value. Patients need to take a more serious approach in choosing a healthcare organization by making it clear that they “trust” their provider.
Guest post by John Squire, president and COO, Amazing Charts.
According to the 2014 Exclusive EHR Study conducted by the MPI Group and Medical Economics, 70 percent of clinicians said their EHR investment has not been worth the effort, resources and costs. Widespread dissatisfaction with electronic records systems is casting an unfortunate shadow over the great potential they hold for making today’s medical practices more efficient and for improving healthcare delivery. However, practices can help avoid future disappointment with their EHR decision and save time and resources by understanding how to avoid common implementation pitfalls.
1. Choosing the wrong EHR
The intuitiveness and ease of use of your EHR will affect every area of your practice. If you don’t consider yourself to be technologically savvy, finding an intuitive solution should be at the top of your list. (After all, presumably you’re a clinician, not an IT expert.) Was a clinician was involved with the development of the EHR system? If a clinician wasn’t involved, chances are your idea of “usable” won’t line up with that of the vendor’s.
Another aspect to consider is cost, which can vary across a wide spectrum from free to several thousand dollars a month. Decide on the maximum price that you are willing to pay. This will reduce the list of vendors for consideration. Oh by the way, beware of the word “free.” Your biggest hidden cost is not the dollars spent on software, but the hours of lost productivity from a system that impedes you with banner ads and other annoying distractions.
To be certain that the EHR you choose is the right one for your practice, do everything in your power to expose yourself to the software prior to purchasing. It is worth asking the vendor whether they offer free trials. If not, consider watching video tutorials, attending webinars and shadowing another clinician using the EHR.
2. Underestimating the importance of an implementation plan
To ensure the smoothest transition possible, develop an implementation plan that will introduce you to your new EHR and also help you identify specific questions to ask the vendor. Your EHR vendor will likely have one to give you – just ask.
At a minimum, a useful implementation guide should tell you how to do the following:
Today’s healthcare system is becoming progressively technology dependent. With the need to meet meaningful use requirements, convert to ICD-10, or work with health information exchanges (HIEs), healthcare organizations must have effective IT solutions, but building and implementing one successfully is not an easy task.
Below is a list of 10 fundamentals of successful healthcare IT project implementation, management and execution that will help your organization, whether clinical, business, or IT, design and develop a functional, patient-centered IT solution that fits its needs. It’s easy to let the highly technical elements overwhelm healthcare IT projects, but following these guidelines will help your team focus on the delivery of care.
Plan
Develop your plan with a detailed project introduction, clear scope, deliverables, schedules, project methodology, roles and responsibilities, and change management procedures. Consult ISO 9001/13485/62385 for information on best practices for quality management systems.
Healthcare IT projects involve a lot of moving parts and many people from different professional backgrounds. Setting clear expectations that every project member agrees on will ensure a project runs efficiently. Meeting regulatory requirements, including meaningful use goals, is a crucial aspect of carrying out a successful healthcare IT project.
Set goals and objectives
Early on in the process, involve key players – clinical, business, and IT – in determining the goals and objectives of the project. Ask your team to agree on a definition of success. Depending on the project, involving patients may be valuable. A patient portal project is an ideal situation to solicit feedback from patients.
Adapt to changing objectives
Implement effective change management procedures to your plan to ensure that the project meets the goals on-time and within budget.
Change management is important in every project, in every industry. It is particularly important at this time in healthcare. Healthcare reform and government mandates, such as Meaningful Use, are ever-changing. Recently, the deadline for compliance with ICD10 was pushed back a year. If your organization was close to a switchover, ask your project team how those changing objectives impact your plan and your goals.
Electronic health record (EHR) technology has become truly transformative for the healthcare industry; prepared or not, healthcare teams are increasingly relying on new information technologies to improve the delivery and management of care. EHRs have enabled faster and easier access to patient information, and hold the promises of improved workflows, efficient sharing of information across communities and reduced costs for many physicians and hospitals.
But now that nearly 80 percent of physician practices in the U.S. today have EHR systems in place and the Centers for Medicare & Medicaid Services’ (CMS) meaningful use program is well underway, it is time to look to the next stage of health care technology and innovation. Health care teams must now move beyond the first step of digitizing patient records to transforming this valuable data into meaningful and actionable knowledge that will help care teams make more informed decisions at the point of care and ultimately, improve outcomes.
For this impact to take place at both the individual level and at the population level, care teams need to leverage clinical analytics that will provide visibility into important clinical trends across the entire population. For example, being able to review trends in diabetes care or readmission rates across a population represents an opportunity for specific, meaningful change to improve care delivery and outcomes.
For a practicing clinician, “population health management” means being able to see where an individual patient is within the clinician’s or clinic’s population (e.g., whether the individual’s chronic condition is above or below population benchmarks) and to take action at the point of care, as well as being able to refer to relevant population health metrics.
For a patient, clinical analytics presumes trust, not only in the competency and care of the physician, but also in the security of his or her information. Population health management and analytics tools must ensure that patient information can be gathered, stored, and used in a way that is demonstrably secure.
Care teams should consider four key elements when exploring clinical analytics tools for population health management:
