Guest Column by Val Van’t Hul, Meaningful Use Project Manager, DocuTAP.
Val Van’t Hul
Providers at urgent care centers around the country are preparing to attest for either Stage 1 or Stage 2 meaningful use this year, and knowing the differences in reporting periods can make a huge difference in the process. Reporting periods vary depending on which stage an eligible professional (EP) is in, and whether a provider is attesting through the Medicaid or Medicare EHR incentive program.
To further explain this process, here are the reporting periods for 2014 indicated by the Centers for Medicare & Medicaid Services (CMS):
Medicaid
An EP must select any 90-day reporting period that falls within the 2014 calendar year. Since Medicaid is state government-based, urgent care centers are tasked with researching any particular rules and regulations that pertain to their location, as these vary from state to state.
Medicare
An EP participating in the first year of meaningful use (Stage 1, year 1) must select any 90-day reporting period. However, to avoid the 2015 payment adjustment the EP must begin the reporting period by July 1 and submit attestation data by October 1, 2014. This grace period is designed to help clinics that are still working out best practices and processes for attestation.
Medicare – An EP who is beyond their first year of Meaningful Use (Stage 1, year 2 or beyond) must select a three-month reporting period that is fixed to the quarter of the calendar year (i.e. July to September or October to December). There is not one quarter that is better than others for reporting, but clinics should keep in mind that there should be ample time to implement any changes in clinical workflow prior to the start of the reporting period. If an EHR vendor is properly certified for Meaningful Use and the urgent care client can begin the process, they may choose a later reporting period to allow time to properly order their workflow.
Meaningful Use Tracking & Reporting
Urgent care centers should monitor clinical workflow progress often to benchmark the eligible professional’s progress in working toward achieving Meaningful Use objectives. It is wise to run meaningful use reports from the EHR software, as well as conduct a provider analysis every few weeks to find out where and how adjustments need to be made in the progression toward these objectives. If EPs are falling below a preferred threshold in any area, this benchmarking provides ample time to get up-to-speed on clinic initiatives.
In addition to implementing tracking measures, it is necessary to understand the importance of delineating between “yes or no” and numerator/denominator reports. While the former are fairly self-explanatory (i.e. as with drug interaction checks), clinics should take careful documentation measures to prove compliance, including taking regular screenshots of what is happening in a clinic’s EHR software system during the reporting period. For example, when pop-ups of patient medicinal allergies occur, a screenshot of this notification, along with a date/time stamp, should be taken and a copy kept on file for up to six years, as this is the standard amount of time for which CMS may audit the eligible professionals.
What follows is a fascinating graphic from NueMD, which asks a simple, yet provocative question: Is meaningful use helping or hurting EHR adoption?
CMS launched the program to “reward healthcare practitioners for adopting electronic health records and increasing efficiency within their practice.” According to the graphic, and the research complied here, 2013 was a successful year by all accounts as far as EHR adoption is concerned. However, as pointed out by NueMD, attestation of meaningful use is slowing.
Particularly alarming are the figures from the small practice space, with 50 percent or so of these physicians groups implementing the technology, yet only 25 percent or so of this group attesting and receiving incentives for doing so.
Additionally, satisfaction with using EHR technology also has dramatically decreased for those who might be called technology champions while those who might be labeled as EHR “haters” have begun to hate the technology even more.
Finally, of those deciding to make the technology switch to a new system cite lack of system functionality as the primary reason for doing so. So, of the physicians that are not implementing the systems, are they simply deciding to absorb the financial penalties mandated by the feds? If that’s the case, what will the outcome of meaningful use be?
And, if efficiencies are not gained, as promised, are we really any closer to an improved healthcare system where physicians, especially those in small practices, actually get to spend time with the patients they desire to serve?
The College of Healthcare Information Management Executives (CHIME) welcomes today’s announcement from the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC),on a proposed rule that would give healthcare organizations and professionals a greater chance to continue participation in the Meaningful Use program in 2014.
While the proposed changes are complex, CHIME believes the adjustments will ensure broad program participation and will enable providers to continue their meaningfuluUse journey.
“If the government acts quickly to finalize the proposed rule, it will provide the flexibility needed for our members and their organizations to adequately optimize newly deployed technology and ensure success of the program,” said CHIME President and CEO Russell P. Branzell, FCHIME, CHCIO.
According to the proposed rule, eligible professionals, eligible hospitals and critical access hospitals will be allowed to use 2011 Edition Certified EHR Technology (CEHRT), 2014 Edition CEHRT or a combination of the two Editions to meet meaningful use requirements in 2014. Because providers are at various Stages and are scheduled to meet different Stage requirements in 2014, CMS and ONC also have proposed giving providers the option of meeting Stage 1 requirements or Stage 2 requirements.
Guest post by Anil Jain, MD, FACP, chief medical officer, Explorys, and staff, Department of Internal Medicine, Cleveland Clinic.
Nearly every aspect of our lives has been touched by advances in information technology, from searching to shopping and from calling to computing. Given the significant economic implications of spending 18 percent of our GDP, and the lack of a proportional impact on quality, there has been a concerted effort to promote the use of health information technology to drive better care at a lower cost. As part of the 2009 American Reinvestment and Recovery Act (ARRA), the Health Information Technology for Economic and Clinical Health (HITECH) Act incentivized the acquisition and adoption of the “meaningful use” of health IT.
Even prior to the HITECH Act, patient care had been profoundly impacted by the use of health informationtechnology. Over the last decade we had seen significant adoption of electronic health records (EHRs), use of patient portals, creation of clinical data repositories and deployment of population health management (PHM) platforms — this has been accelerated even more over the last several years. These health IT tools have given rise to an environment in which providers, researchers, patients and policy experts are empowered for the first time to make clinically enabled data-driven decisions that not only at the population level but also at the individual person level. Not only did the 2010 Affordable Care Act (ACA) reform insurance, but it also has created incentive structures for payment reform models for participating health systems. The ability to assume risk on reimbursement requires leveraging clinical and claims data to understand the characteristics and needs of the contracted population. With this gradual shift of risk moving from health plans and payers to the provider, the need to empower providers with health IT tools is even more critical.
Many companies such as Explorys, a big data health analytics company spun-out from the Cleveland Clinic in 2009, experienced significant growth because of the need to be able to integrate, aggregate and analyze large amounts of information to make the right decision for the right patient at the right time. While EHRs are the workflow tool of choice at the point-of-care, an organization assuming both the clinical and financial risk for their patients/members needs a platform that can aggregate data from disparate sources. The growth of value-based care arrangements is increasing at a staggering rate – many organizations estimate that by 2017, approximately 15 percent to 20 percent of their patients will be in some form of risk-sharing arrangement, such as an Accountable Care Organization (ACO). Already today, there are currently several hundred commercial and Medicare-based ACOs across the U.S.
There is no doubt that there are operational efficiencies gained in a data-driven health system, such as better documentation, streamlined coding, less manual charting, scheduling and billing, etc. But the advantages of having data exhaust from health IT systems when done with the patient in mind extend to clinical improvements with care as well. We know that data-focused health IT is a necessary component of the “triple-aim.” Coined by Dr. Donald Berwick, former administrator of the Centers for Medicare and Medicaid Services (CMS), the “triple-aim” consists of the following goals: 1) improving health and wellness of the individual; 2) improving the health and wellness of the population and 3) reducing the per-capita health care cost. To achieve these noble objectives providers need to use evidence-based guidelines to do the right thing for the right patient and the right time; provide transparency to reduce unnecessary or wasteful care across patients; provide predictive analytics to prospectively identify patients from the population that need additional resources and finally, use the big data to inform and enhance net new knowledge discovery.
On the first day of HIMSS 2014 in Orlando, I stepped into a bewildering echo chamber. “We’re doing population health,” repeated everyone, be they physicians at a hospital whose EHR system my company implemented, the IT directors of other hospitals looking to update their EHR system or competing EHR experts. Everyone was interested in buying it, and everyone was interested in selling it. On one particular walk of the floor a colleague quipped, “Will there be a prize for the one millionth person to say ‘population health?’”
Despite this obsessive buzz nobody seemed able to define what population health is. It’s the proverbial elephant described by touch rather than sight. Is it a concept of health or a study of the various factors that affect health? Is it a course of action for the treatment of the population in its entirety or individual patients only?
The Affordable Care Act, which cites population health as an essential component of its mandate, aims to expand access to the healthcare delivery system, improve the quality of care, enhance prevention, make healthcare providers responsible for outcomes, and promote disease prevention at the community level.
All of this is commendable, but, in the end, what is population health? What does it look like? Will we recognize it if we achieve it? A friend of mine on the payer side observes that vendors claim it’s everything and providers don’t know exactly what they want it to be. Put those together and the term becomes meaningless.
There are additional questions about population health that remain unanswered. Is it an outcome, as the ACA approach suggests, or is it a foundation built on big data, analytics, ACO tools, bundled payments, systems consolidations or something else? At every HIMSS booth, the answer to these questions was a resounding “Yes.”
With a flourish of congressional shenanigans lifted almost word for word from the teleplay of Netflix’s House of Cards, the HHS-mandated 2014 transition to use of the ICD-10 coding classification was brought to a screeching one year “delay.” We are left, once again, with “at least” another year of collecting healthcare information via ICD-9, an awful but omnipresent healthcare coding system. And more concerning, we are left with the impression that diligent and expensive work to comply with rules in a host of other areas, such as meaningful use of electronic health records, could become abruptly irrelevant. The result of the delay is that not only do we have a significant number of long-time objectors to the change to ICD-10, but they are also joined by a surge of rightfully angry and dubious ‘compliers’ who put in time and investment dollars to meet the deadline. But there are also some additional considerations given the amount of time that has passed as we prepare to make the trip.
Is this trip still worth the aggravation and expense?
The major underlying rationale of moving to ICD-10 remains laudable: to provide greater clarity to our understanding of healthcare practices through the use of better industry standard, diagnosis codes. With more granular, relevant and precise core codes at the foundation, medical quality and effectiveness studies utilizing these codes for analysis and program development were to have benefitted dramatically.
Given that our desire to advance healthcare value and improve outcomes through accountable care practices (‘fee-for-value’) we must acknowledge our dependence on much better information collection for analysis than is possible from ICD-9[1]. Significant questions remain however, as to whether the move to ICD-10, using codes predominantly still entrenched to support fee-for-service billing processes will get us where we want to go. While we can hope the enhanced and detailed nature of ICD-10 might yield greater insight into the real value of our activities, this remains a particularly frail hope in light of the way we use the codes as revenue cycle fuel.
Guest post by Judy Chan, president, HealthPro Consulting.
Burgeoning EHR implementations nationwide attributable to the meaningful use incentive program have created a surge in HIO and electronic health information exchange (eHIE).
Having health information available for electronic exchange is generally accepted as beneficial to patients, providers and payers. Providers can access patient information from other providers when they need it where they need it. Providers are able to avoid duplicating lab tests, scans and x-rays that save the payers dollars. Additionally, patients don’t need to remember what treatments were administered or drugs prescribed and can avoid unnecessary exposure to radiation.
In emergency situations, the benefits of having a patient’s health information available to emergency room staff are obvious. Patients who have experienced referrals in the course of diagnosis and treatment also readily see the advantage of not having to hand-carry all of their medical records from one doctor’s office to the next. The electronic exchange of health information among providers eliminates faxes, paper work and phone calls.
Patient’s perspective
What makes the exchange of health information frightening to patients?
1. Your health information is available to others who have a legitimate need.
2. Consent must be given by the patient to share their information
3. You must trust the distributor of your information
4. You should monitor your data on a regular basis and make corrections when necessary
5. Information could be accidentally released without your permission.
6. Your consent is electronically recorded by multiple systems.
Do these risks sound familiar? They should because they are not very different from the risks that credit rating agencies that have recorded your financial transactions for years.
For physicians’ practices in the 21st century, connectivity is the buzzword. Getting doctors connected to data, patients connected to healthcare providers, and practices connected to networks are just a few of the web-fueled scenarios coming down the pike.
The Health Information Technology for Economic and Clinical Health (HITECH) Act is a game changer and affects just about every aspect of modern medical care. HITECH, part of the American Recovery and Reinvestment Act of 2009, promotes the adoption and meaningful use of health information technology.
As is often the case with a shift this monumental, there are both benefits and challenges of connected healthcare that practice groups will have to address. First, let’s take a look at some of the benefits.
1. Join the Digital Revolution. Just as other industries that went digital years ago, healthcare benefits from the streamlining offered by a networked environment. Clinical interoperability of healthcare IT lowers costs and enhances efficiency by facilitating the comprehensive exchange of health information between care providers, hospitals and patients. The trend is toward innovation in healthcare as the industry as a whole responds to consumer demands and government reforms.
2. Safety in Numbers. As of 2013, more than 323,000 American medical practices and hospitals adopted EHRs and attested as meaningful users, indicating a 266 percent increase over 2012, according to CMS statistics. However, even with this upsurge in participation, those numbers represent only a small percentage of US hospitals that currently keep electronic records and contribute to the health information exchange. So, while the risk of being an early adopter is largely gone, your practice group could still be near the front of the adoption wave.
3. It’s easier. As you can see from the statistics in the previous point, healthcare IT adoption is in an early phase, and for most practices, there is a lack of centralization. To help elucidate the complexity of the system, look no further than the state of Florida, where there are at least 672 EHR vendors. Connecting health information digitally creates a central database that greatly simplifies the process of storing and retrieving all patient data. It’s like finding the needle in the haystack every time.
