The meaningful use criteria for use of Electronic Health Records are coming into focus

I got a tip to subscribe to the free Becker newsletters that focus on Ambulatory Surgical Centers (ASC’s), and I see that they are also covering EHR meaningful use criterion. The rubber is starting to hit the road as the Federal definitions are of sufficient fine-granularity to be operationalized. Is that a mixed metaphor? Anyway:

The march towards meaningful use (MU) has created a sense of urgency within the physician community to adopt EHRs for their offices — as it should. Hospitals and eligible professionals (EPs), which include physicians, began attestation for MU incentive payments on April 18, and the first payments were issued in May.

 

Central to physicians qualifying for stimulus payments is the use of certified EHR technology. Vendors began applying for certification in July of 2010, and physicians have begun the process of either choosing appropriate technology or making needed changes to existing systems in order to qualify.

 

With $27 billion in incentives up for grabs over the next five years and the potential for penalties hanging in the balance for providers who do not meet criteria, the stakes are high. But like any rush to a deadline, it’s important that providers and ambulatory surgery centers understand the full picture and take a careful, thoughtful approach to choosing systems that align with both workflow needs and future expectations to avoid the potential for costly mistakes.

 

ASCs are becoming increasingly aware of the MU provisions — specifically as they relate to the perceived need to deploy a certified EHR as opposed to a system that may be more appropriately aligned to their environment. Since ASCs are not eligible for stimulus payments, and MU certification criteria for ASCs were never developed, there has been no real incentive or benefit for them to invest in certified systems. However, some ASCs are now feeling pressure to purchase a certified EHR and make costly technology decisions in order to satisfy the needs of their physician base.

 

This pressure is the result of a little-known clause in the meaningful use regulations, referred to as the 50 percent rule. A clear understanding of the 50 percent rule and four other aspects of MU is imperative for ASCs and EPs as they weigh their responses to the mounting external pressures to deploy certified EHR technology.

 

1. 50 percent rule. According to CMS, ”any eligible professional demonstrating meaningful use must have at least 50 percent of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the meaningful use objectives.”

 

The latest guidance from CMS is that, when they refer to a “practice/location,” ASCs are included in that definition. Additionally, CMS has commented that “equipped” means that the technology needs to be available in such a way that the EP can use a certified EHR to accomplish all of their MU objectives.

 

This clause can potentially have the unintended consequence of leading ASCs to believe that they need to adopt certified technology that is not designed for their environment, and for which they receive no stimulus payments, unlike EPs and hospitals.

 

2. Potential solutions. ASCs under pressure to adopt a certified EHR product should first have their physicians determine where their encounters occur. If at least half occur at an office or offices equipped with certified EHR technology, then there is no need for that physician to be concerned about the 50 percent rule.

 

In cases where a physician does have more than 50 percent of patient encounters occurring at an ASC, there are two options that exist for the center: 1) significantly change the workflow within the ASC and the physician’s office to capture data associated with MU objectives, or 2) encourage physicians to carefully review the CMS definition of an encounter and potentially change the way in which they schedule their patient activity to avoid falling short of the 50 percent rule.

 

According to CMS, for the purpose of calculating this 50 percent threshold, any encounter where medical treatment and/or evaluation and management services are provided should be considered a “patient encounter.”

 

3. Workflow challenges. MU criteria were designed to address longitudinal patient care and a move towards the efficient electronic capture of patient data over time. To meet this need, EHR vendors have designed products to capture patient information over the course of many encounters.

 

It is a workflow that fits well in a physician office environment. But an ASC is much different. To efficiently address the workflow needs of an ASC, products need to be designed around procedures. That is, data capture needs to address the specific needs of a particular procedure being performed. This will not typically require the extensive evaluation that may occur in a physician office.

 

There are numerous examples of MU objectives that do not fit well within an ASC’s workflow. For example, a meaningful user must use a certified system for the following types of workflows, many of which do not translate well into the ASC environment:

• Computerized provider order entry
• Drug/drug interaction checking
• Drug formulary checking
• Prescribing electronically
• Reconciling medications
• Incorporating clinical lab results into the EHR
• Calculating and reporting clinical quality measures to CMS
• Providing clinical summaries to patients
• Submitting data to immunization registries and public health agencies
• Keeping problem lists, medication lists and medication allergy lists updated

 

How quickly are EHR’s being adopted, and what are the barriers to success?

Lots of good stuff and analysis over at Information Week Healthcare: This site has been my go-to resource for an at-a-glance representation of what is going on in the various healthcare IT and informatics “silos”. Good job guys! Really interesting survey data, but I don’t share the optimism that genomics is going to play such a significant role anytime soon. It might be that building in access to genomics and pharmacogenomics data is good for EHR vendors to do, because it will be clinically useful in 2025 or such, and the systems should be forward-looking with a lifetime of value-add and ROI. But don’t expect the addition of gene sequencing to improve patient care in the short to mid-term. Anyway, on to the survey highlights and analysis:

There’s a big problem with how the vast majority of healthcare providers—let’s say, practices with fewer than 10 docs—are dealing with federal requirements for meaningful use, which they must meet to get subsidies. Most of them aren’t dealing with the real requirements at all. And they’re so focused on meeting deadlines, they risk picking the wrong electronic medical record software.
While hospitals have IT departments and some level of resources to throw at the meaningful use program, most docs are heads down seeing patient after patient, with little interest in poring over pages of requirements, let alone figuring out how to meet and then report on them.

Nearly six in 10 healthcare organizations still need to buy an EHR system or upgrade an existing one to qualify for the federal funds, according the InformationWeek Analytics’ Healthcare IT Priorities Survey of 357 business technology professionals at healthcare providers. And 62% of respondents who have EHRs or are planning them say they’ll spend more than 20% of their annual IT budget on EHR projects this year. In other words, there’s still a lot of heavy lifting for U.S. hospitals and doctors’ practices to deploy systems that comply with federal guidelines.

Qualifying for the funds isn’t easy. Health-care providers must be using certified EHR systems that meet federal requirements, and they have to demonstrate that they’re making “meaningful use” of those systems, complying with a laundry list of 20 requirements for medical practices and 19 for hospitals. And they have to do all this for 90 consecutive days before the end of next year.

Despite the complicated process, a surprising

83% of respondents who are evaluating, deploying, or have deployed EHRs are confident they’ll meet the federal government’s deadlines and qualify for incentive funds. Specifically, 52% of them say they’re “very confident” and 31% are “somewhat confident”

A quarter of respondents anticipate no problems with EHR adoption in their organizations. That’s a high number considering the potential issues that can come up when deploying an EHR system, such as negative reactions from physicians and staff, disruption to patient care, security and privacy mistakes, and shortages of technical expertise. It could very well be that providers underestimate how challenging meaningful use compliance is.

Among respondents, an eyebrow-raising 31% of healthcare providers say their EHR systems already comply with the government’s meaningful use requirements. What they likely mean is that their systems have been certified as meaningful use compliant.

However, certification ensures only that products have the features and functionality needed to accomplish meaningful use. Additional programming and workflow adjustments often are needed to integrate with other systems and processes in a healthcare organization. Significant staff training is commonly required.
Healthcare providers also must ensure that their EHR systems are collecting the data needed to demonstrate that they’re using the systems in a meaningful way—to show that a certain percentage of patients have drugs ordered electronically and have lists of their allergies and medical problems in the system, for instance.
It’s not uncommon for healthcare providers to think they’re making great progress meeting meaningful use requirements, only to discover they’re missing the mark, says Dana Sellers, CEO of Encore Health Resources, a health IT consulting firm.

Cloud Challenged
Healthcare has been slow to embrace cloud computing. Only 14% of respondents to InformationWeek Analytics 2011 Healthcare IT Priorities Survey are using public cloud services, while 47% have no plans to use either public or private clouds.

Thirty percent of companies across all industries use some public cloud services and just 33% have no plans to use cloud computing, according to InformationWeek Analytics’ State Of Cloud Computing Survey.

Electronic healthcare records are the most common application being hosted. More than 30% of survey respondents using public or private clouds are using it for this, followed by storage (28%) and financial apps (25%).

Clinical decision support, chronic disease management, business intelligence, and giving patients Web access to personal health records will get significant attention in the next 12 months, even though they aren’t connected directly to the first round of meaningful use requirements. Having technology in place for any
of these areas could help providers comply with later stages of meaningful use, however.
At Cleveland Clinic, the development of BI dashboards is a priority this year. The medical center has developed 20 dashboards over the past several years that are used by executives, nurse managers, and others to analyze financial, operations, clinical, quality-of-care, and other data, says Andrew Procter, administrative director of medical operations at Cleveland Clinic Innovations, the facility’s technology commercialization arm. The medical center has a “queue of requests” from clinicians throughout the organization, Procter says. “It’s a big part of what we do. It’s a big part of the culture” to use analysis that aligns clinical, financial, operations, and quality-of-care data to shape better decisions.

Mobile computing is another area getting attention. University General Surgeons, in Knoxville, Tenn., is evaluating whether to provide its six surgeons with tablet PCs with a hosted billing application. The tablet and app would make it easier for the physicians to document treatment information needed for billing while at a patient’s hospital bedside, rather than writing notes on paper and entering the charges later in the office, says practice administrator Michael Poulsen.

Health and Human Services rules for 2011: Insurance companies will be required to spend 80 to 85 percent of premium dollars on medical care and improvements, not administrative costs

from http://www.hhs.gov/ociio/regulations/index.html

The US Department of Health and Human Services (HHS) has announced medical-loss ratio rules that will go into effect in 2011. Of course, an awful lot of administrative activity is required to implement improvements: quality assessment, management, and improvement iterations, so it remains to be seen how much money will really be shifted away from “administration”. One can hope costs do go down from this, yet fear administrative growth will simply follow the money and shift over to quality assurance, which should not be attempted on the cheap. The cult of movement towards “continual process improvement” can mean endless bonanzas of new management opportunities. Yet cutting back on quality assurance budgets is problematic. Having worked on a quality-assurance project for Texas Medical Liability Trust involving testing patient data extracted into new and modern relational databases, I have some sense of the overhead and expense associated with quality assurance work. It’s not easy or trivial work, and skimping on overhead can result in bugs, HIPAA violations, and for all I know increased mortality! Still…

Beginning in 2011, the law requires that insurance companies publicly report how they spend premium dollars, providing meaningful information to consumers. Also beginning in 2011, insurers are required to spend at least 80 percent of the premium dollars they collect on medical care and quality improvement activities. Insurance companies that are not meeting the medical loss ratio standard will be required to provide rebates to their consumers. Insurers will be required to make the first round of rebates to consumers in 2012.

Thanks to the Affordable Care Act, consumers will receive more value for their premium dollar because insurance companies will be required to spend 80 to 85 percent of premium dollars on medical care and health care quality improvement, rather than on administrative costs, starting in 2011. If they don’t, the insurance companies will be required to provide a rebate to their customers starting in 2012.

In 2011, the new rules will protect up to 74.8 million insured Americans and estimates indicate that up to 9 million Americans could be eligible for rebates starting in 2012 worth up to $1.4 billion. Average rebates per person could total $164 in the individual market. Important details regarding the new regulation are included below.

The medical loss ratio regulation outlines disclosure and reporting requirements, how insurance companies will calculate their medical loss ratio and provide rebates, and how adjustments could be made to the medical loss ratio standard to guard against market destabilization.

A poll on adoption of EHR’s

We are at the stage now where Federal writ must be interpreted and scrutinized by those planning budgets and personnel decisions. Institutions and organizations such as Regional Extension Centers face serious financial and logistical challenges concerning EHR’s. While these challenges certainly present opportunities for those of us in the healthcare informatics/healthcare IT world, the history of implementing complex upgrades to institutions that must provide mission-critical services during the upgrade is daunting. Healthcare CIO’s and CTO’s and directors must proceed with caution as the Feds operationalize the logistics of the ARRA EHR meaningful use provisions.

Houston Neal from www.softwareadvice.com/ passed along a note that they are running a poll on an important issue concerning the adoption of EHR’s and how the Feds are structuring incentives to do so.

One of the major components of the the American Recovery and Reinvestment Act of 2009 (ARRA) was the allocation of $19 billion to jump start the adoption of electronic health records (EHRs). One of the major uses of those funds was the establishment of Regional Extension Centers (RECs) to support EHR adoption by primary care physicians.

The entity spearheading this effort, the Office of the National Coordinator for Health IT (ONC), is specifically charged with helping 100,000 priority primary care providers become “meaningful users” of EHRs in 24 months. Eight months have passed since the ONC began funding RECs, and we’re skeptical that they will deliver.

Don’t get us wrong. We’re big advocates of EHRs. We’re glad to see such an energized EHR market. We’re just skeptical that throwing money at the problem will lead to efficient and successful adoption of this important technology.

In our opinion, there are five fundamental flaws with RECs:

1 Doctor’s aren’t moving as fast as the money is flowing
2 The market already delivers on what RECs promise
3 “Preferred vendor lists” limit choice and free markets
4 RECs won’t get doctors to “meaningful use” fast enough
5 The REC model leads to under-staffed, ephemeral entities“

What do you think about how electronic health records (EHRs) will be imlemented in the key category of Regional Extension Centers ? Take the poll at : http://www.softwareadvice.com/articles/medical/five-reasons-we-think-recs-are-reckless-1092310/#survey#ixzz10rpWUNdV

Physicians to receive incentives for EHR, penalties

from www.healthcarefinancenews.com/news/physicians-receive-incentives-ehr-use

The American Recovery and Reinvestment Act of 2009 provides financial incentives to physicians who adopt and use Electronic Health Record (EHR) technology. However, physicians who haven’t adopted certified EHR systems by 2014 will have their Medicare reimbursements reduced by up to 3 percent beginning in 2015.

The act provides $20 billion in health information technology funding, divided between $2 billion in discretionary funds and $18 billion in investments and incentives through Medicare and Medicaid, to ensure widespread adoption and use of interoperable healthcare IT systems.

“In one stroke, Congress has all but removed the biggest stumbling block to EHR adoption – cost,” said James R. Morrow, MD, a physician at North Fulton Family Medicine in Alpharetta, Ga., who was named “Physician IT Leader of the Year” by the Health Information and Management Systems Society (HIMSS). “It’s time for doctors to stop complaining about the cost of an EHR and take the ball and run with it toward the goal of better medicine with better records and information sharing across the healthcare team.”

With the stimulus, the Centers for Medicare and Medicaid Services will pay physicians $44,000 to $64,000 over five years, beginning in 2011, for deploying and using a certified EHR. The stimulus package is expected to ignite significant job growth in the information technology sector and, according to a Congressional Budget Office review, drive up to 90 percent of U.S. physicians to EHRs in the next decade.

A recent Allscripts survey of 1,888 healthcare professionals revealed that 98 percent of physician practices would take advantage of the incentives or would be closely evaluating the opportunity.

hat-tip-www.fiercehealthcare.com