There is a little  known but potential Stage 1 nightmare for EPs as they prepare for Meaningful Use attestation for the CMS EHR incentives. The attestation process as described in the CMS Attestation User Guide for EPs requires the inputting of numerators and denominators documenting the meaningful use of each percentage based measure.

Where do these numbers come from? If you are lucky your Complete Certified EHR will gather this data for your automatically. If you are not so lucky it is TOTALLY up to the EP to arrive at these numbers. Hard to believe but this is correct for Stage 1 certified EHRs. There is no requirement for the EHR to gather this data. Here it is in black and white from the NIST Test Procedures: “The Vendor-supplied numerator and denominator information may be recorded automatically by the EHR,or recorded by the user in the EHR.”  The only requirement is that there must be input fields for the EP to put in the numbers. No telling what workflow the EP will have to use to gather the data. Without the data they are not eligible for any incentives, period.

Hopefully, Stage 2 will address this issue and require automatic aggregation of this critical data.

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Posted on May 26, 2011 by Jim Tate in HITECH Updates, Meaningful Use

OK, so now we are starting to hear from many sources that Stage 2 MU will be delayed. Just a matter of time they say. So while we are waiting for that shoe to fall we might as well take a look at what will be required for Stage 2.

Although it has not been finalized it is beginning to gel. The HIT Policy Committee has updated the proposed Stage 2 measures for EPs and EHs  based on May 11th comments and there are a few surprises. As expected most of the percentage based measures will require a higher threshold. Clinical quality measures will have to be reported electronically. Some, but perhaps not all, of the Stage 1 menu measures will move to the core column for Stage 2.

They are a few tweaks based on focusing existing measures to make them more relevant. A few new measures are in the mix for Stage 2: “lists of care team members”, “creation of summary and care plan”, and possibly the ability to submit reportable cancer conditions. Some Stage 1 measures look to be on the way out. We have learned that in the world of Meaningful Use nothing is final until it is final. I don’t blame you if you want to wait until the ink dries before you review what is in Stage 2. However, if you are like me and like to watch water boil, you can go to this HHS page on Stage 2 meaningful use and sit by the stove. I’ll see you there.

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Every webinar, conference call, FAQ site, or provider forum I attend these days seems to expose the confusion on what the EP has to meet to obtain the maximum amount of money and what they have to attest to prove they are meaningful users. These are not the same thing and one has nothing to do with the other.

Eligible Professionals (EPs) participating in the Medicare EHR Incentive Program for 2011 can receive a payment based on 75% of their total Medicare allowed charges submitted no later than two months after the end of the 2011 calendar year. In other words, the amount will be calculated from your allowed services billed to Medicare Part B (MPFS) for 2011. You have until the end of February 2012 to bill service dates of 2011. The maximum allowed charges used FOR a 2011 incentive payment is $24,000, which means that the maximum incentive payment an EP can RECEIVE for the first participation year is $18,000. If you begin participation in 2012 the calculation is the same but it will be based on your allowed charges billed to Medicare Part B for 2012.

So that is how you will determine how much money you will receive when participating in the MEDICARE incentive program. It has nothing to do with actually receiving the money. To receive incentive money you must register, achieve meaningful use of a certified technology, and then attest to achieving the meaningful use for a period of 90 consecutive days.

To achieve meaningful use you will implement your certified system and complete objectives that have specific measures for a designated 90 consecutive days. Many of the measures are based on patient encounters. These patient encounters have nothing to do with Medicare patients. The patient encounters are based on all your patients no matter what payer they come from.

To conclude, the dollar amount of the incentive payment is based on a calendar year of allowed billable charges to Medicare Part B. The actual incentive payment can only be received if you attest to being a meaningful user of certified technology during a consecutive 90 days of that calendar year.

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Established in 1976, the Health and Human Services (HHS) Office of the Inspector General (OIG) fights waste, fraud and abuse to over 300 HHS programs including Medicare, Medicaid, CDC, NIH, and FDA. They are currently the largest OIG office in the Federal Government employing 1700 people. Through nationwide audits, investigations, and evaluations this OIG reports and recommends to the department and its programs.

On May 16, the HHS OIG released two audit reports focusing on security of patient health information. The first, Audit of Information Technology Security Included in Health Information Technology Standards reports on the ONC. The audit reviewed the current Final Rule for security controls. The second, Nationwide Rollup Review of the Centers for Medicare & Medicaid Services Health Insurance Portability and Accountability Act of 1996 Oversight reports on CMS. They audited 7 hospitals for vulnerabilities in systems and their controls to protect ePHI.

In the ONC report it was found that the ONC and Standards Final Rule focuses on security of interoperability and exchanging encrypted information between EHRs. They site that there are no HIT standards that include general IT security controls. They define these security controls as the “structure, policies, and procedures that apply to an entity’s overall computer operations, ensure the proper operation of information systems, and create a secure environment for application systems and controls.”  The report recommends which the ONC concurs with:

In the CMS report the audit found 151 vulnerabilities of secure ePHI in the 7 hospitals including open access to records without the hospital’s knowledge. It was found that CMS oversight and enforcement was not sufficient to ensure the covered entity has effectively implemented the HIPAA Security Rule. The report recommends that the Department’s Office for Civil Rights (OCR) continue the compliance review process that CMS began in 2009 and implement procedures for conducting compliance reviews to ensure that Security Rule controls are in place and operating as intended to protect ePHI at covered entities. The OCR defends that it maintains a process for initiating covered entity compliance reviews through complaints or on its own.

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One of my favorite magazines, Harvard Business Review (HBR), in its latest June issue has an article called “The Ambidextrous CEO” that is worth reading because it highlights innovation in healthcare IT (with a good story from Misys), specifically around open source. Here’s a point they made that’s worth repeating:

Our research suggests that firms thrive when senior teams embrace the tension between old and new and foster a state of constant creative conflict at the top. We call this leading ambidextrously. We conducted an in-depth study of 12 top-management teams at major companies and identified three leadership principles that help firms grow their core businesses even as they cultivate new offerings that will reshape their industries: (1) Engage the senior team around a forward-looking strategic aspiration. (2) Explicitly hold the tension between the demands of innovation units and the core business at the top of the organization. (3) Embrace inconsistency by maintaining multiple and often conflicting strategic agendas.

They go on to talk about the value open source brought to Misys and how it goes senior management attention:

At the height of the financial crisis, he gave it an even stronger organizational voice: Open Source was the only Misys health care asset not folded into the core Allscripts unit. This permitted Open Source leaders to sit at the table with Allscripts top executives and compete for resources. Every strategic move involved trade-offs between more-immediate returns from Allscripts and longer-term returns from Open Source. The tensions reflected the power struggle over the firm’s identity and future. For example, the head of Allscripts wanted his proprietary software to dominate, and he saw Open Source as a direct threat. His fears proved well-founded; Open Source soon started to beat out Allscripts for contracts.

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 T-System to Offer Enhanced Diagnosis Decision Support to Emergency Depart. Physicians T-System to Offer Enhanced Diagnosis Decision Support to Emergency Department Physicians ED information system supports fast and accurate diagnoses with integrated decision support

DALLAS  May 31, 2011  As part of a commitment to continuously enhance its solutions, T-System, Inc. today announced it will integrate diagnosis decision support from Isabel Healthcare with its T SystemEV emergency department information system to assist physicians in determining an early and accurate diagnosis. T-System is the industry leader in clinical, business and IT solutions for emergency medicine with solutions in 1,700 U.S. hospitals.

We’re excited to partner with T-System, a company that mirrors our passion to empower providers with advanced intelligence so they can support a higher quality of patient care,? said Don Bauman, chief executive officer, Isabel Healthcare. Efficiency is critical in EDs because of the need to see and diagnose patients expeditiously and quickly admit them to the hospital if necessary. Isabel helps doctors consider all possible diagnoses especially when facing difficult cases or want confirmation of a diagnosis. Mitigating delayed or misdiagnosis is a major contributor to increasing the level of ED patient safety and efficiency and reducing waste and cost.

Physicians and nurses using T SystemEV can enter a patient’s demographics and symptoms and receive a checklist of potential diagnoses. Isabel instantly returns the differential and provides a number of sorting options to further enhance efficiency (most common, by specialty, etc.), as well as flagging high risk ?don?t miss? diagnoses – a feature critically important for EDs often operating with limited information and time.

With one click, providers can access detailed evidenced based clinical content about any medical condition in the checklist. Available at their fingertips is a variety of online resources: peer-reviewed journals; medical textbooks; websites including BMJ Groups Best Practice, PubMed, Minute Consult, etc.; and organizational specific content that they may already have access to or have developed like guidelines or protocols.

Diagnosis decision support is a natural fit with T SystemEV’s clinical workflow in which ED clinicians are documenting their notes about differential diagnoses and medical decision-making,? said Robert Hitchcock, M.D., FACEP, chief medical information officer, T-System. ?Through the integration, doctors have easy access to the latest evidence-based knowledge to make rapid diagnoses in treating a broad spectrum of illnesses and injuries, many deemed severe or life-threatening. This powerful content meets our No. 1 one priority of improving the ED healthcare delivery experience for both patients and clinicians.?

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The Center for Business Innovation (TCBI), run by my friend Satish Kavirajan, is currently organizing the Business Intelligence & Analytics for Healthcare Conference & Exhibition: Managing Data to Drive Quality, Financial Performance & Accountable Care, to be held in San Diego on July 11-12, 2011. I’m an advisor for the conference, will be speaking on several topics, and will be co-chairing. Satish puts together some great conferences because he focuses on specific topics and gives plenty of time for networking and one-on-one learning plus some very decent deep-dive workshops.

We would like this BI and analytics event to delve into how hospitals, health plans, health information exchanges and population health management companies can use business intelligence, analytics, data mining, predictive modeling and decision support to meet Meaningful Use requirements and create sustainable accountable care organizations and patient-centered medical homes. As we all know, MU, ACOs, and PCMHs are not possible without tons of data integration capabilities so this even is very timely.

Key topics to be covered include using BI/analytics to facilitate quality measurement and reporting and pay for performance initiatives, improve clinical outcomes, increase efficiency, reduce costs, increase revenues, deal more effectively with government regulation, increase patient satisfaction, enhance organizational agility and promote greater transparency and organizational information sharing by dismantling the silos of data typically found within healthcare organizations. Providers and payers will face an avalanche of data in the coming years. This conference will provide detailed and practical instruction on how to effectively manage and use this data to provide the right information at the right time to the right people for optimal decision-making. For more information on the conference, including the current agenda, please visit the conference website.

TCBI is currently seeking a few speakers, mainly from hospitals and health plans, with significant experience in BI/analytics. If you are interested in speaking opportunities, please email Satish Kavirajan or call him at 310-265-2570.

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Patricia Walling, a graduate student who has both professional and volunteer experience in a hospital environment, reached out to me via e-mail recently about some of her ideas of how physicians can communicate with their patients through social networking. I liked her ideas and invited her to put together an guest posting on the subject. Most healthcare professionals are already busy doing a hundred things a day and connecting to patients via social networks is probably the last thing on their minds; however, if patients are online they may have no choice but to meet them on the sites they frequent. Not everyone wants to connect to their patients on social networks, but here’s what Patricia advises for physicians and health professionals that can afford the time and resources it takes to connect:

It’s obvious now that a growing number of people (patients and family members alike) are turning to online resources to diagnose their medical problems. Most doctors understand that patients use the Internet to access health information rather than visiting their doctor first. While the Internet and social networks provide quick and easy access to health information (you won’t even need a degree in medical transcription to understand most terms), it is also important to remember that oftentimes much of the information found online is erroneous or can easily be misunderstood. Thus, it may be a good idea to connect to patients directly, rather than risk having them resort to sites like Facebook for their medical decisions and ensure that they are using reputable resources.

Have a Separate Account for Patients
Most social networking sites don’t limit the number of accounts you can create. As such, you should start a separate account for your professional agenda. Patients will appreciate being added and, given the ease of contact, will be more likely to come to you with questions. Since most people check their account regularly, they’ll be less likely to go out of their way to find advice when you can have a solution there waiting for them.

Respond Quickly to Your Contacts
Keeping your patients informed and maintaining regular contact will encourage them not only to come to you first for medical advice, but also to engage with you more often and remember appointments. The half-hour or so a day that you dedicate to maintaining your contacts will do wonders for your ability to help your patients. As they say: out of sight, out of mind.

Be a Part of Your Patient’s Search
Among the many self-styled experts on the Web, some are far more credible than others—especially when it comes to medical information. However, you need not discourage your patients from looking through online health resources if you integrate yourself into their search. This way you can encourage your patients to feel more in charge of their healthcare while at the same time discouraging them from relying on online advice. Not only will this improve your relationship with your patient, but it will also give you insight into your patients’ thought process and better allow you to protect them against poor medical advice.

Be Available for Consultation
Patients should never act on any information until they’ve spoken with you about what they’ve learned. However, patients who are desperate for help may act rashly if they think there is no other option. Be sure to remind your patients often that they can always contact you about any medical issue, and try to respond quickly if you are contacted. If you can, give them a time of day when you are online in case they need person-to-person communication. By being reliable, you can keep your patients better informed and safer from their own devices.

Make Sure They Know You Know Them Best
As your patient’s doctor, you should make it clear that you are much more familiar with their case than someone who’s just an Internet contact. When they get advice from an expert through social media, they should avoid thinking about it as an idea that competes with your opinion, but rather consider it a suggestion that could be useful to them. It could be that what they learned online doesn’t apply to their case, which you should help them understand.
Ultimately getting health information from online sources and social networks isn’t bad. You can provide a wonderful service to your patients, just as they can potentially learn a great deal about their own case. However, this should be balanced by your counsel. Keep involved in their case as they explore it, and respond dutifully to their queries. Online communication can’t replace an exam, but it can help prevent a lot of harm.

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Even a 10 percent increase in the hospital use of electronic medical records could save 16 babies for every 100,000 live births in the U.S. And, making a complete national transition to EHRs could save an estimated 6,400 infants each year nationwide, according to a new study published in the Journal of Political Economy. The study looked at the death rates of infants at hospitals with and without EMRs in more than 2,500 counties nationwide over a 12-year period. The data set permitted the researchers–Amalia Miller of the University of Virginia and RAND, and Catherine Tucker of the Massachusetts Institute of Technology Sloan School of Management–to control for other factors that could impact infant mortality, such as an area’s socioeconomic status. –Read the full post at FierceEMR

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The Council for Affordable Quality Healthcare (CAQH) has launched a transition committee to make recommendations about multi-stakeholder governance of its Committee on Operating Rules for Information Exchange (CORE). The CORE project, which CAQH began in 2005, has created rules for the exchange of information related to healthcare coverage and insurance payments. CORE seeks to enable providers to obtain insurance information before or at the point of service, regardless of the billing system being used.

More than 120 industry organizations participate in CORE, including health plans covering 75 percent of commercial covered lives, plus Medicare, Medicaid, Tricare, the VA system, and agencies of several states. Up until now, health insurers and their trade associations have dominated the organization.

The decision to broaden the governance was made because of “the changing environment in which operating rules are mandatory,” said Linda Fishman, senior vice president for public policy at the American Hospital Association and a member of the transition committee. “This change is critical to the CORE goal of aligning clinical and administrative simplification objectives. Most important though, is that broadening the perspectives at the table will help ensure that the operating rules reduce administrative costs for all and improve the workability of administrative processes for everyone. And the greater the standardization of processing, the easier it will be to achieve interoperability, especially as we move into an era of ever-increasing accountability.”

The HIPAA 4010 transaction set standardized the exchange of administrative data–a process that will be taken further by the 5010 transaction set that goes into effect next year. But because of the myriad differences in provider, clearinghouse, and health plan information systems, the amount of data exchange has been limited and has often required “companion guides” to effectuate. The purpose of CORE is to  standardize the operating rules for information exchange in practice.

Among the members of the transition committee are Allscripts, America’s Health Insurance Plans, the American Hospital Association, the American Medical Association, Blue Cross and Blue Shield of North Carolina, GE Healthcare, J.P. Morgan, Medical Group Management Association, the Minnesota Department of Health, Montefiore Medical Center, the National Governors Association, United Healthcare and WellPoint. 

To learn more:
- read the press release
- see the list of CORE members 

Related Content:
UnitedHealth Group is First to Achieve CAQH Core Certification Using 5010 Testing Platform
Payers setting own rules for sharing health information

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