Friday, March 16, 2012

Extension of Enforcement Discretion Period for Updated HIPAA transaction standards through June 30, 2012

(March 15, 2012) The Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services (OESS) is announcing that it will not initiate enforcement action for an additional three (3) months, through June 30, 2012, against any covered entity that is required to comply with the updated transactions standards adopted under the Health Insurance Portability and Accountability Act of 1996 (HIPAA): ASC X12 Version 5010 and NCPDP Versions D.0 and 3.0.

On November 17, 2011, OESS announced that, for a 90-day period, it would not initiate enforcement action against any covered entity that was not compliant with the updated versions of the standards by the January 1, 2012 compliance date. This was referred to as enforcement discretion, and during this period, covered entities were encouraged to complete outstanding implementation activities including software installation, testing and training.

Health plans, clearinghouses, providers and software vendors have been making steady progress: the Medicare Fee-for-Service (FFS) program is currently reporting successful receipt and processing of over 70 percent of all Part A claims and over 90 percent of all Part B claims in the Version 5010 format. Commercial plans are reporting similar numbers. State Medicaid agencies are showing progress as well, and some have made a full transition to Version 5010.

Covered entities are making similar progress with Version D.0. At the same time, OESS is aware that there are still a number of outstanding issues and challenges impeding full implementation. OESS believes that these remaining issues warrant an extension of enforcement discretion to ensure that all entities can complete the transition. OESS expects that transition statistics will reach 98 percent industry wide by the end of the enforcement discretion period.

Given that OESS will not initiate enforcement actions through June 30, 2012, industry is urged to collaborate more closely on appropriate strategies to resolve remaining problems. OESS is stepping up its existing outreach to include more technical assistance for covered entities. OESS
is also partnering with several industry groups as well as Medicare FFS and Medicaid to expand technical assistance opportunities and eliminate remaining barriers. Details will be provided in a separate communication.

The Medicare FFS program will continue to host separate provider calls to address outstanding issues related to Medicare programs and systems. The Medicare Administrative Contractors (MAC) will continue to work closely with clearinghouses, billing vendors or health care providers requiring assistance in submitting and receiving Version 5010 compliant transactions. If any entity is experiencing difficulty reaching a MAC, please contact Karen Jackson at Karen.Jackson1@cms.hhs.gov.

The Medicaid program staff at CMS will continue to work with individual States regarding their program readiness. Issues related to implementation problems with the States may be sent to Medicaid5010@cms.hhs.gov.

OESS strongly encourages industry to come together in a collaborative, unified way to identify and resolve all outstanding issues that are impacting full compliance, and looks forward to seeing extensive engagement in the technical assistance initiative to be launched over the next few weeks.

-Centers for Medicare and Medicaid Services

Tuesday, January 10, 2012

From the Chair: Patient Safety


The recently released report by the Institute of Medicine concluded that protecting patient safety in a digital environment is multifactorial, encompassing technological functions, usability of the products, and implementation and use by providers and others.  Ten recommendations were made to establish the nature and extent of issues related to patient safety and health IT, how they could be monitored over time, and how they might be addressed by the public and private sectors.

One of the recommendations gave the Department of Health and Human Services 12 months to contribute to and assess progress in the public and private sectors towards these efforts, after which time the report recommended that the Secretary should make determination regarding the necessity for Food and Drug Administration regulation. If not necessary at that time, the Secretary should reassess this decision on an annual basis.

As these recommendations are considered and variously implemented the question remains on clinicians’ minds as to how they can assess whether or not their own electronic health record (EHR) supports safe care now to the greatest extent possible. While there is no one tool that can be applied to answer that question, there are practical approaches that could be used to assure that the most up-to-date functions and features are present.

A good place to start is malpractice claims.  52% of all paid medical malpractice claims in 2009 were in the ambulatory setting, with two thirds of these involving major injury or death. A recent analysis suggests that most adverse judgments fall into three categories: poor communication, poor documentation, and problems associated with diagnosis and treatment of a patient. It’s worth considering how health IT can better address these issues, and the degree to which they can currently be assessed to do so.

Communication gaps can occur within a practice, among clinicians in different locations, and between clinicians and patients. Does your system allow secure messaging with patients; does it have a patient portal through which you can communicate with your patients? Can you generate and record patient specific instructions as well as educational materials. Does your EHR support concurrent use by multiple staff and can you access, create, and allow modification of jointly managed care plans? What about clinical task assignments and routing, and the ability to co-sign notes? Are verbal, telephone, and electronic messages between users documented, along with discrete data on specified roles of each provider associated with a single patient? Recognizing that interoperability with external provider systems is beyond the scope of a single EHR, do you at least have a directory of external providers and can you capture external documents?

Documentation is the second major area to consider. Does your system support efficient but reliable documentation of your findings and results? Can you incorporate free text? Do your checklists and templates appropriately default to normal findings only when you have actually examined the patient and recorded your positive findings, including those areas not examined? Can you make modifications and corrections? Are consents and authorizations clear and easily retrieved?  How easily and accurately can you manage problem lists, medication lists, and allergy and adverse reaction list as well as clinical documents and notes? As alerts and reminders are brought to your attention, is there some way to document why you may or may not choose to act on them? Lastly, check for back up.  A system that can lose patient data is one with a built in patient safety risk.

Diagnosis and treatment risks can be mitigated to a large extent by good e-prescribing, medication management, and medication reconciliation functions. Alerts should optimally include drug/drug, drug/allergy, drug/diagnoses, and some form of drug/lab information, but should be meaningful to the individual clinician using the system to avoid alert fatigue.  Another area where an EHR can help mitigate patient safety risk is closed loop ordering. This means that the clinician should at least be able to view active orders for a patient, display outstanding orders for multiple patients, see the status of orders, receive notification when new results are received, and link results to the original order. It also means that the clinician is notified when a test result is not returned, or a prescription has not been filled, though few systems function at that level now.  Ways of assuring that patients receive appropriate testing for disease management, medication management, and preventive services should include both reminders inserted into clinical workflows and automatic reminders to patients or their guardians.  The last, and arguably the most important areas in support of appropriate diagnosis and treatment are data integration and presentation. Are you informed whenever new data points enter your patients’ records? Can you easily eliminate or modify duplicative or erroneous data points?  How well does your system aggregate data and present them in usable formats so that you are truly knowledgeable about your patients’ history and progress?

All three areas interdigitate. Good communication requires good documentation requires good data management requires good communication. As CCHIT certification has matured over the years, attention has been paid in all three areas with the recognition that integration of all functions is the foundation on which all other patient safety functions rest. Testing for integration using clinical workflows that support many of the patient safety functions listed here is unique to CCHIT Certified® products, and is not present in ONC certification, as many of the functions are not. As we look to the future, CCHIT will increase its focus on assuring that patient and provider needs for safer, more usable systems are met.


-Karen M. Bell, MD, MMS
Chair, Certification Commission
EHR Decisions 

Tuesday, December 27, 2011

Expect These Unexpected EHR Challenges

We all know the expected challenges of implementing an electronic health record -- not having enough time, money or resources to go around. However, unexpected challenges are more likely to throw a wrench in your EHR implementation timeline and budget. The following four challenges are common, but usually unexpected.

Getting Dictation Data in Discretely. If your providers dictate notes, it’s important to understand how the dictated data is stored. Many organizations print and scan the dictated note into the EHR.

However, scanned data is not stored discretely; you cannot search this data nor can you use it in reports. There are a few companies that specialize in taking the dictation as a Word document and importing it into a template or visit progress note.

Most templates, however, make the text in the dictation searchable but will not actually populate discrete data items. The solution and the challenge is to create templates which format the dictation in such a way that it populates the discrete data elements whenever possible.

Creating Security Access for Smaller Practices. It’s relatively easy to define information security access at large practices, as staff members usually have clearly defined roles. It can be more difficult in smaller clinics that are within a larger organization.

Staff roles may be less defined. Limited staff means fewer people doing more, and many clinic staff members are performing tasks outside of their job scope. Therefore, their roles are not as easily translated into electronic security templates. To make sure the access rights and roles are assigned for the appropriate user, you may also have to conduct additional audits. It may take some tweaking and some extra time to get your security process in place, but if you know about this, you can plan for it.

Defining a Naming Convention. Once everyone in the organization agrees on how the new EHR is going to function, and future workflows have been documented, it’s time to split up the build work and have your build team start building, right?

Wrong. Before you have multiple people building in the system, you need to define how you’re going to name the different elements within the system. How will items be labeled? Should we use ALL CAPS? Do we start with the name of a department or facility? (Not a good idea, by the way.) How will forms be categorized?

These seem like small decisions that each builder could decide along the way, but if you have 10 people building in the system, you will have inconsistencies throughout, making documentation, training, and especially maintenance difficult. It’s worth the time up-front to define these conventions beforehand. If you’re interfacing with other clinical systems or if your data feeds a clinical data repository, make sure you use the same naming nomenclature for labs, procedures, etc. Normalizing the data across the enterprise is a requirement if you’re going to report on clinical quality measures across the organization.

Setting up Master Files that Make Sense. When set up correctly, master files save time and help users avoid errors. However, it’s important to set them up in a consistent matter up-front, similar to defining a naming convention.

If you have multiple lab interfaces, for example, it’s important to be able to tell one result from the other and each lab from the other. Understanding, naming, and configuring the identity for each result component, and having continuity between the components, is critical. You don’t want to set up five separate hemoglobin results in the system, but you do need to get the results from five different labs for each hemoglobin and be able to tell the types of results apart. So how do you set it up? If possible, attach Logical Observation Identifiers Names and Codes (LOINC) to the components so that you can identify, for instance, the body fluid.

Too often you cannot identify the fluid from the name of the component result. If possible, try to have an identifier in the names of components without LOINC codes to enable specimen identification. Providers may want urine results instead of blood results or vice versa, so the ability to identify the correct components saves time and improves accuracy.

There are many reasons to mitigate risks and challenges of an EHR implementation besides the obvious cost of delays and rework. Success in terms of being a meaningful user—and receiving MU incentive dollars-- depends on the ability of your organization’s EHR to provide accurate data in a timely manner.

There’s also a timeline attached to receiving meaningful use funds. User and physician adoption of the EHR is critical to its effectiveness; when something doesn’t work well after implementation, it can impact users’ trust in the system. However, when the EHR does function well, it can be a game changer, in a positive way – improving user and patient satisfaction.

- Tracy Welsh, vice president at Hayes Management Consulting

2011 Best in KLAS


KLAS Research ranked health I.T. vendors in 111 categories based, on performance scores from more than 18,000 provider evaluations conducted in the past 12 months (18 months in some categories). Following is a snapshot of top-ranked vendors in select categories.

Acute Care EMR: No. 1 Rating, Epic EpicCare Inpatient EMR
Ambulatory EMR (over 75 Physicians) Epic Ambulatory Care
Ambulatory EMR (11-75 Physicians): athenaClinicals from athenahealth
Ambulatory EMR (1-10 Physicians): Amazing Charts
Business Intelligence/Reporting: Diver Solution from Dimensional Insights
Cardiology: Digisonics Digiview
Community HIS: Paragon from McKesson Corp.
Document Management and Imaging: ChartMaxx from MedPlus/Quest Diagnostics
Emergency Department: Tie between EPIC ASAP ED and Medhost EDMS
Enterprise Scheduling: RMS from Unibased Systems Architecture
Financial/ERP: Oracle PeopleSoft Enterprise
Homecare: Homecare Homebase
Laboratory: Novius Lab from Siemens
Oncology: Elekta Mosiac
PACS: Unity from DR Systems
Patient Accounting/Patient Management: Resolute Hospital Billing from Epic Systems
Pharamcy: Willow from Epic Systems
Practice Management (over 75 Physicians): Resolute/Prelude/Cadence from Epic Systems
Practice Management (11-75 Physicians): PrimeSuite Practice from Greenway Medical
Practice Management (1-10 Physicians): PrimeSuite Practice from Greenway Medical
Radiology: Radiant from Epic Systems
Speech Recognition: eScription from Nuance Communications
Surgery Management: OpTime from Epic Systems

The full "2011 Best in KLAS" report costs $500 for providers and $2,500 for others, and is available at www.klasresearch.com/reports

- healthdatamanagement.com

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CMS Nears $2 Billion in Meaningful Use Payments

Through November 2011, Medicare and Medicaid have each paid nearly $1 billion in electronic health records meaningful use incentive payments during the first year of the program.

Medicare has paid $920.3 million and Medicaid has chipped in an estimated $916 million, according to figures from the Centers for Medicare and Medicaid Services presented Dec. 7 to the HIT Policy Committee.

Medicare meaningful use payments have gone to 10,155 eligible professionals, 34 Medicare-only hospitals, and 377 Medicare and Medicaid hospitals. Medicaid meaningful use payments have gone to 11,270 eligible professionals and 800 hospitals.

After a start to the meaningful use programs that was slower than CMS anticipated, incentive payments took off in September for hospitals and in October for eligible providers, says Robert Anthony, a health insurance specialist in CMS' Office of E-Health Standards and Services. And with eligible providers having until Feb. 29, 2012, to attest to 2011 meaningful use, "we think we'll see a real influx of people coming in," he told the policy committee.

For more information about how the meaningful use program is progressing, click here.

- Joseph Goedert

Meaningful Use Creating a New Role for RIS?

The radiology information system, or RIS, has long been the work horse of the imaging group practice, handling such functions as scheduling, demographics collection, even billing and results reporting. Now, under the meaningful use program, the RIS is taking on a new level of importance: Some radiology groups are using their RIS as the backbone of their participation in the incentive program.

Keith Dreyer, D.O., vice chair of radiology at Massachusetts General Hospital, told attendees at the RSNA 2011 conference in Chicago that the day is soon approaching when RIS vendors will undergo complete certification of their systems, meaning they are capable of upholding all data capture and reporting requirements called for in the MU program. Dreyer said about one-third of RIS vendors had attained complete certification, with another third having attained modular certification. "If your RIS vendor has attained modular certification, you need to ask what their next step will be," he advised attendees.

he meaningful use scenario for private practice radiologists can quickly become complicated, Dreyer noted. Radiologists might read images for multiple hospitals, each with a different system. If the reporting system is the common glue, then it would need to be certified. And even if radiologists gain exclusion from some MU reporting criteria, their practice would still need to have certified system in place capable of performing those functions.

Participating in the MU program need not be an overwhelming task, other speakers said. Steve Fischer, CIO at the Minneapolis-based Center for Diagnostic Imaging, said much of the data capture needed falls naturally on the shoulders of front-desk staff. The center provides management services for a dozen radiology groups, and is participating in the MU program as much to avoid future penalties as to gain incentives, Fischer said. Adding e-prescribing capabilities and a reporting dashboard were among the top I.T. challenges.

- Gary Baldwin

Stage 2 of Meaningful Use Moved to 2014

The Department of Health and Human Services has moved the start date for Stage 2 of the electronic health records meaningful use program from 2013 to 2014.

The initial HHS announcement did not make clear which providers were eligible to wait until 2014. The department clarified its position to Health Data Management.

Federal officials this summer had voiced support for a proposal to delay Stage 2 one year to 2014 for providers who attest to Stage 1 in 2011. The rationale was that Stage 1 pioneers who attest in 2011 should not be penalized by tight timeframes next summer for getting ready for Stage 2. Now, that proposal is adopted, and since providers who begin Stage 1 attestation in 2012 could wait until 2014 to start Stage 2, now everyone will start Stage 2 in 2014. Pioneer providers in 2011, however, can get three years of Stage 1 incentive payments. Following is a statement from HHS explaining the decision:

"Input from the vendor community and the provider community makes clear that the current schedule for compliance with stage 2 meaningful use objectives in 2013 poses a nearly insurmountable timing challenge for those who attest to meaningful use in 2011. With the anticipated release of the final rule for stage 2 in June, 2012, the current timetable would require EHR vendors to design, develop, and release new functionality, and for eligible hospitals to upgrade, implement and begin using the new functionality by the beginning of the reporting year in October of 2012.

"In response to significant input on this matter from multiple stakeholders, expert testimony, and countless hours of review, analysis and deliberation, HHS publicly announced its intention to delay the start of Stage 2 of the Medicare and Medicaid EHR Incentive Programs for a period of one year for those first attesting to meaningful use in 2011. We intend to propose such a delay in the Stage 2 meaningful use Notice of Proposed Rulemaking (NPRM), which is scheduled to be published in February 2012. Not only do we believe that this will give vendors added time to develop certified EHR technologies for Stage 2, we also believe this delay will give providers additional time to implement new software and meet the new challenges of Stage 2. We also intend to propose maintaining the current expectation for those first attesting to meaningful use in 2012, so that all providers attesting to meaningful use in 2011 or 2012 will begin Stage 2 in 2014.

"Perhaps most importantly, we want to provide an added incentive for providers attesting to meaningful use in 2011. We encourage any providers who have been waiting until 2012 to attest to Stage 1 meaningful use now. Under the Medicare and Medicaid EHR Incentive Programs, providers who attest early receive greater incentives. And now those providers who first attest in 2011 can get three payment years for meeting the Stage 1 expectations, while those first attesting in 2012 can only get two payment years under Stage 1 criteria."

American Hospital Association President Rich Umbdenstock applauded the HHS decision:

"America's hospitals welcome today's announcement that HHS intends to delay the start of Stage 2 meaningful use. Hospitals are committed to implementing electronic health records to support high quality patient care, but the rushed timelines and complex regulatory requirements of meaningful use have made the process difficult.  While the flow of meaningful use incentives to date has been slow, the delay will better align EHR adoption policy with market realities, such as limited vendor capacity to work with providers.  Giving hospitals another year to implement these changes before the bar is raised on the meaningful use requirements is good news, especially for small, rural and safety net facilities."

Joseph Goedert

Tuesday, October 25, 2011

Vendors Add Products to Meaningful Use Certified EHR Lists

Three electronic health records vendors recently received federally deemed certification of products meeting one or more Stage 1 meaningful use requirements. They are:

* GE Healthcare's Centricity Patient Online portal, version 12.0, as an EHR Module from Drummond Group;

* IntrinsiQ's IntelliDose oncology CPOE, version 3.9, as an EHR Module from Drummond Group; and

* Surgical Information Systems' SIS Anesthesia information system, Version 5, as an EHR Module from Drummond Group.

The federal government's database of certified inpatient and ambulatory EHR applications is available at http://onc-chpl.force.com/ehrcert.


Joseph Goedert
HDM Breaking News, October 11, 2011

Could Stage 2 of Meaningful Use be a Two-Step Process?

An idea floating around Washington could result in Stage 2 of the electronic health records meaningful use program being different in each of its two years.

That’s what Dan Rode, vice president of advocacy and policy at the American Health Information Management Association, told an audience during the AHIMA 2011 Convention & Exhibit in Salt Lake City.

Stage 2 starts in October 2012 for hospitals and January 2013 for eligible professionals, just when providers will be struggling to meet the ICD-10 deadline in October 2013.

So the scenario could be that Stage 2 starts in January 2013 with minor changes from Stage 1, such as raising meaningful use quality measures a bit. But any major changes or new requirements, such as requiring the use of SNOMED CT in certain parts of the medical record, would wait until 2014, Rode said.

Other regulatory and policy updates from Rode and others on the AHIMA policy team include:

* The association is working with Sen. Sheldon Whitehouse (D-R.I.) to extend meaningful use to long-term care and mental health providers to accommodate accountable care organizations;

* Some degree of data encryption could be in Stage 2 criteria;

* The Office of the National Coordinator wants to begin building Stage 3 requirements in January 2013 to give providers more time to comply by 2015;

* The industry is unlikely to see the omnibus HIPAA privacy/security/breach notification/enforcement rule until late this year or early next year;

* The final accounting of disclosures rule may come out absent provisions that give patients the right to an access report about who has accessed their electronic health records;

* Efforts are moving forward to add the receipt confirmation transaction to the HIPAA set of financial and administrative transactions;

* Medicare will accept all diagnoses codes on claims starting in January 2012 rather than having the number capped, so over time attachment requests should fall;

* AHIMA is working with members of Congress to get the General Accountability Office to do a study on patient identifiers and to get lawmakers to remove the annual prohibition on funding for an identifier;

* Congress is unlikely to adopt a fiscal 2013 federal budget next year with a continuing resolution being passed to keep funding at 2012 levels; and

* Rep. Tom Marino (R-Pa.) is drafting legislation to provide a degree of liability protection for use of certified EHRs, limit e-discovery to an actual event to prevent fishing through an entire EHR system for possible safety issues, and require the reporting of I.T. safety events. AHIMA won’t develop a position of support or opposition until the bill comes out.


Joseph Goedert
HDM Breaking News, October 5, 2011

Friday, September 30, 2011

HIPAA Privacy Rule Changes on the Horizon

The Department of Health and Human Services Office for Civil Rights in 2010 published a proposed rule, mandated under the HITECH Act, to make multiple changes to the HIPAA privacy, security and enforcement rules.

OCR is now in the late stages of finalizing an “omnibus” final rule that would make significant changes to those HIPAA rules, and the breach notification rule. Following are a series of privacy rule changes proposed by the government.

Expanding Associates

The OCR proposes to make requirements under the privacy and security rules applicable to business associates in the same manner they presently apply to covered entities.

In addition, it would expand the definition of “business associate” to include health information exchanges, health information organizations, electronic prescribing gateways, patient safety organizations and vendors selling personal health records for covered entities to offer to patients.

Satisfactory Assurances

The proposed rule would require business associates to obtain "satisfactory assurances" from subcontractors that they will comply with applicable requirements of the privacy and security rules.

Existing contracts between business associates and subcontractors can be grandfathered for up to one year beyond the rule's compliance date. OCR estimates 1.5 million business associates may have to bring subcontractors into compliance.

Redefining 'Marketing'

The OCR would restrict marketing activities by redefining "marketing," which will limit health-related communications that may be considered "health care operations."

The proposed rule would require covered entities receiving payment for making certain communications to obtain authorization from individuals before making the communications.

PHI Authorization
One proposed change is to define uses and disclosures of protected health information for which individual authorization is required, such as the sale of PHI.

In the proposed rule, OCR asks for additional public comment on uses and disclosures of PHI for research purposes.

Firming up Fundraising

OCR proposes to require recipients of fundraising communications be given a clear and conspicuous opportunity to opt out of receiving future communications, making clear that opting out will not affect future treatment of the individual.

Fundraising communications may not be sent to individuals who have not expressly opted to receive them. Privacy notices must include a statement that an organization intends to send such communications and that an individual can opt out

Patient Control

Changes on the table include requiring notice of privacy practices to include a description of the uses and disclosures of protected health information that require an authorization.

In addition, individuals would be allowed to request restriction of disclosures of PHI, unless otherwise required by law, if the restriction applies solely to a service fully paid out-of-pocket.

The proposed changes would also strengthen the right of individuals to obtain their electronic health records

Increasing Financial Penalties

The OCR wants to increase civil money penalties for violations of requirements to ensure the privacy and security of protected health information, with fines of up to $1.5 million in a single calendar year for violations of the same requirement.

-Health Data Management

Meaningful Use Deadline Nears for Eligible Professionals

The Centers for Medicare and Medicaid Services reminds physicians and other non-hospital providers that Oct. 3 is the last day for eligible professionals to begin their 90-day reporting period for the first year of Stage 1 electronic health records meaningful use incentive payments.


The reporting year for eligible professionals ends on Dec. 31, and Feb. 29, 2012, is the last day for eligible professionals to register and attest to receive an incentive payment for calendar year 2011. CMS encourages early registration and not waiting until ready to attest in case problems arise during the registration process.


The hospital meaningful use program runs on the federal fiscal year and Nov. 30 is the last data to register and attest to receive an incentive payment for FY 2011.




Joseph Goedert
HDM Breaking News, September 26, 2011

CHIME: Slow Down on Tying Metadata to Meaningful Use

The College of Healthcare Information Management Executives is urging federal officials to slow down on initiatives to tie use of metadata to electronic health records meaningful use measures.

The Office of National Coordinator for Health Information Technology is moving on a fast track to quickly incorporate use of metadata in EHRs to facilitate health information exchange and give patients more control over the sharing of their data, following recommendations in late 2010 from the President's Council of Advisors on Science and Technology.

ONC, for instance, recently announced it will launch two pilot projects covering the use of metadata to support data exchange, and wants some degree of metadata use in Stage 2 meaningful use measures. But CHIME, which represents health care CIOs and other information technology leaders, says the initiatives aren't ready for prime time.

"Despite the impressive amount of resources put forth on this endeavor, by ONC and others, CHIME simply cannot support the inclusion of metadata standards in the next notice of proposed rulemaking to support meaningful use Stage 2," according to a comment letter to ONC. "We do not believe enough progress has been made, or evidence gathered, to support the technologies and strategies needed to include metadata standards as part of meaningful use Stage 2. We do not believe that the meaningful use regulatory schema is the appropriate venue to mandate unproven standards or incomplete protocols."

CHIME recommends ONC move forward with metadata initiatives "to fully vet the range of possible standards and assemble the needed implementation processes." The comment letter is available here.

Joseph Goedert
HDM Breaking News, September 23, 2011

More EHR Meaningful Use Certifications Announced

Four electronic health records products from three vendors in recent days received federally deemed certification for meeting one or more Stage 1 meaningful use requirements. They are:

* Navigating Cancer's Patient Engagement Portal, version 3.9, as an EHR Module from Drummond Group;

* California Medical Systems' Practice Expert EMR, version 2011.100.1.1, as a Complete EHR, from Drummond Group; and

* Iatric Systems' Public Health Reportable Lab Results Interface, version 1.5, as an EHR Module, from the Certification Commission for Health Information Technology. The vendor's Meaningful Use Manager application, previously certified in June, also has received additional EHR Module certification from CCHIT for its Clinical Quality Measures component.


Joseph Goedert
HDM Breaking News, September 19, 2011

Study: CPOE Requirements in MU Stages 2 and 3 May Cut Mortality

A new study published in Health Affairs suggests that Stage 1 meaningful use criteria for use of computerized physician order entry systems is probably too low to significantly lower mortality rates among heart patients, but higher levels of mandated use in Stages 2 and 3 "is more consistently associated with lower mortality."

Stage 1 of meaningful use requires electronic orders for at least 30 percent of eligible patients. The Stage 2 measure likely will be 60 percent with Stage 3 at 80 percent.

Researchers at RAND Corp. studied data from the American Hospital Association Annual Survey database, comparing medication orders written electronically with manual orders. "We relied on self-reported ranges--for example, 26 to 50 percent of patients--of the use of electronic medication ordering and did not have direct measures against which to validate these reports," according to the study. "It was not possible to match our data exactly to the thresholds prescribed in the meaningful use regulations because our data used ranges instead of, for example, a threshold of 30 percent of patients. Therefore, we were not able to simulate the impact of the uptake of electronic medication ordering at the exact thresholds prescribed in the meaningful use regulations. However, our data did provide thresholds that approximate those of the regulations, and we believe that the results of our simulation will be informative to policy makers."

Hospitals that reported any level of use of electronic medication orders had lower mortality rates for three conditions studied. "In unadjusted comparisons, any use at all of electronic medication ordering was associated with significantly lower mortality from heart attack, heart failure and pneumonia," according to the study. "Adjusted comparisons confirmed a statistically significant relationship between the use of electronic medication ordering and mortality rates for heart attack and heart failure, but not for pneumonia."

The study also compared mortality rates among hospitals with different levels of electronic medication order entry. Results showed relationships between the level of electronic ordering and lower mortality from heart attack and heart failure, but not pneumonia. In particular, a relatively lower level of electronic ordering was associated with lower heart attack mortality, while a level of more than 50 percent for heart patients more consistently showed lower mortality for both heart attack and heart failure patients.

The authors hypothesize that failure to find improved mortality rates among patients with pneumonia may be attributable to different patterns of use across conditions, or that different conditions are more or less sensitive to use of electronic ordering. "For instance, the features offered in computerized provider order entry systems may be more useful in safely managing medications for complex chronic conditions such as heart failure than they are for acute conditions such as pneumonia."



Joseph Goedert
HDM Breaking News, September 15, 2011

Privacy, EHR Policy Changes Coming in Federal Health I.T. Plan

More changes to health information privacy rules, and a stronger push for electronic health records interoperability, could be forthcoming under the final Federal Health I.T. Strategic Plan for the next five years from Health and Human Services' Office of the National Coordinator for Health Information Technology.
ONC released a draft plan for comment in May. While the final plan is out, the agency stresses it a "living document" that will be updated as warranted.

Under the final plan, HHS has begun a process of exploring broader privacy and security policies that may be necessary to ensure trust in health information exchange. "One of the major areas being addressed through this process is pursing policy changes that would afford individuals more meaningful choice as to whether their information may be exchanged electronically," according to the plan. "ONC is also assessing technical solutions that could support more granular patient choice and data segmentation that could support a patient's choice to share only certain parts of their record during information exchange."

HHS in the plan reaffirms support for research at the National Institute of Standards and Technology to refine usability testing for electronic health records. The tests would use protocols targeting improved safety and efficiency. "This work will occur in a transparent process, engaging EHR developers, researchers and other stakeholders," according to the strategic plan. "We will also work on greater transparency and better guidance for EHR users and purchasers with regard to EHR usability."

Further, ONC will study ways to improve the ability of providers to change EHR products to better support their needs by improving data portability. "Reducing the cost associated with switching EHR products while increasing data fluidity and choice can help drive market competition to improve the usability of EHR products."

Another component of the strategic plan includes the launching this month of a national campaign to increase consumer awareness of the transition to EHRs, how to access their health information, using I.T. to better manage health, and rights to access and protect their health information.

ONC in the plan also reiterates its support of a recommendation from the HIT Policy Committee to extend by one year Stage 1 of EHR meaningful use for providers attesting in 2011, and notes it has made the recommendation to the Centers for Medicare and Medicaid Services. The strategic plan is available here.


Joseph Goedert
HDM Breaking News, September 13, 2011

Thursday, September 29, 2011

New Patient Access Rights Will Challenge HIM Departments

The HITECH Act gives consumers the right to access their electronic health records in an electronic format. But many security experts believe that under final rules, giving patients the records on a CD or thumb drive won't meet the intent of the law, says Lou Ann Wiedemann, director of professional practice resources at the American Health Information Management Association in Chicago.

She believes 'electronic' will mean access to a particular patient's records in a provider's EHR via a Web portal or a cloud computing application, "and not an electronic version of your EHR," Wiedemann says. "The industry is hoping CD or a thumb drive will be okay, but everyone is waiting on the final rule before they start to plan how to do this."

During an educational session at AHIMA's annual convention, Oct. 1-6 in Salt Lake City, Wiedemann will walk attendees through understanding patient rights to access their electronic records and request amendments to the records, a first step toward compliance following release of a final rule.

With patient demand for electronic copies of health records unknown, providers likely will have to retain their current processes for printing and delivering records on paper. Health information management departments, however, will have to develop an education program for patients getting an electronic version, Wiedemann says. "On paper, progress notes are in yellow and the problem list is in blue, but when printed from an EHR it's a different format and not visually distinct, so be prepared to field questions and engage in consumer education."

Educational session 6423, "Understanding Patient Access and Amendments," is scheduled at 1:00 p.m. on October 4.



Joseph Goedert
HDM Breaking News, September 10, 2011

What's the Best Strategy for Financing EHRs?

When it comes to financing health care operations, Juan Ruiz knows the importance of getting the best deal.

He's the director of finance at St. Patrick's Home, a 264-bed skilled nursing home in the Bronx. The home is mid-way through an EHR implementation, from HealthMedx. The project represents a nearly $250,000 outlay, software, hardware and network infrastructure included.

And that's just one financial ball Ruiz has to juggle. Two years ago, the home replaced its boiler system, which came to $500,000. And looking ahead, the 20-year-old facility will need to upgrade its laundry facilities, install a new generator, renovate its bathrooms, and replace about 100 of its beds.

The beds alone represent a $120,000-plus hit to the checkbook. "We have to project our costs three to four years down the road," says Ruiz. He takes a conservative approach to financing, setting aside money each year to fund depreciation of assets--despite the fact that the state eased such requirements a few years ago in light of the economic downturn. "It is extremely expensive running a nursing home."

In an industry with universally tight margins, Ruiz's financial juggling act typifies what hospitals and group practices must go through to install clinical technology and manage to stay in business.

While the EHR incentive program has enticed providers to spend big on electronic records, financing the purchase is invariably a challenge. First and foremost, the systems are expensive. A lucky few providers can fund EHR implementations out of operations, but they still need to set aside capital budgets and explore external financing vehicles for other outlays.

And bargain hunters often find to their regret that the cheapest software isn't the best deal when considering the total cost of ownership and the investments necessary to qualify for government incentives.

Purchasing an EHR, says Ruiz, is an exercise in patience. St. Patrick's Home did a three-year software search, in which it considered two local and three national vendors, finally settling on the HealthMedx system. It will handle clinical documentation, financial management and patient admissions. The integrated clinical/billing package replaces a standalone billing system.

During the vendor evaluation period, St. Patrick's considered financing options along the way. It could have gone with a much cheaper EHR system-one vendor came in at half the cost of the HealthMedx suite-but that would have been a penny-wise, pound-foolish decision, Ruiz says, since the HealthMedx package includes better service terms.

In addition, the vendor has developed and maintains the entire software package. The cheaper vendor merely bolted on applications from other companies. "We wound up financing more, but we will be better off in the long run," Ruiz says.

St. Patrick's will finance about three-fourths of the cost of the EHR through First American Health Care Finance, a specialized health care lender located in Rochester, N.Y. The rest will come from its capital budget-the facility could have financed all the EHR through its capital budget, but needed to consider its other looming outlays, Ruiz says. There was no shortage of banks willing to work with the nursing facility to finance the EHR purchase, and Ruiz considered two other banks in-depth. Eventually, he settled on American because of its industry expertise and service commitments. "They will have a dedicated project manager to handle the invoices and keep track of any over-runs," he says. "They have experience and they are big on the EHR."

"Capital Punishment," Gary Baldwin's feature story in the September issue of Health Data Management, explores EHR financing options and pitfalls to avoid.


Gary Baldwin
HDM Breaking News, September 9, 2011

Sharing the Lessons of Meaningful Use

On one level, the meaningful use electronic record incentive program is all about the money. Many providers, especially small practices, jumped head first into the program because the financial incentives made it possible to automate at little or no cost-if they got those incentive checks.

Take Springfield (Ohio) Center for Family Medicine, where all six physicians have attested to meaningful use, with four by mid-July having received $18,000 first-year checks from the Medicare incentive program, and the other two awaiting payment.

That money is already flowing downstream at the practice, which purchased a document management and imaging system along with workstations, all integrated with the electronic records and practice management systems of Horsham, Pa.-based NextGen Healthcare Information Systems, says Cindy Brewer, office manager. The EHR and the purchase of ancillary technology would not have been done without the incentive payments, she adds. "We've wanted to do it but didn't know when the finances were going to be there."

The incentives also did the job at 25-bed Hemphill County Hospital in Canadian, Texas. The hospital implemented the core clinical information system of Houston-based Prognosis Health Information Systems in February 2010.

Without the incentive funds attached to the initiative, an EHR would have been a much lower priority and taken a lot longer to come to fruition, "and would not have had strong executive backing that this is where we're going," says Patrick Murfee, information technology director.

The trek to meaningful use has produced numerous technological and workplace lessons for those who have done it, but this is just the first step in a long haul project to revamp processes via EHRs, and the true payoffs, financially and clinically, are further down the road.

Joseph Goedert
HDM Breaking News, September 7, 2011

Athenahealth Dashboard Tracks MU Progress, Issues

Physician software and billing services vendor athenahealth Inc. has introduced an online dashboard that clients using its electronic health records system--and users of other EHR systems--can use to assess the progress athenahealth users are making in meeting EHR meaningful use requirements.

The publicly available dashboard looks at athenahealth's entire national client base against all meaningful use measures for eligible professionals, and is designed to enable clients, prospects, policymakers and others see apples to apples data on how thousands of physicians are doing on each measure, according to the company.

Currently, 11 percent of athenahealth physician clients participating in meaningful use have attested to Medicare requirements, and 63.3 percent are two or fewer measures away from being ready to attest.

The dashboard gives data--updated bi-weekly--on physicians' performance on each meaningful use measure. For instance, the dashboard has found that meeting the measure to provide a clinical summary of an office visit within three business days of the visit is especially difficult to meet because of required behavior and workflow changes.

The dashboard is available at: athenahealth.com/hitech


Joseph Goedert
HDM Breaking News, September 8, 2011

Certifiers Add to List of EHR Products Supporting Meaningful Use

Specific products from four electronic health records vendors recently joined the list of certified applications that support one or more Stage 1 meaningful use criteria. They are:

* Merge Healthcare's OrthoEMR v4.0 for orthopedics, as an ambulatory Complete EHR, from Drummond Group;

* Streamline Health Solutions' AccessAnyWare v5.1 document management system, as an EHR Module, from Drummond Group;

* VitalHealth Software's VitalHealth EHR version 1.8 for small practices, as an ambulatory Complete EHR, from the Certification Commission for Health Information Technology; and

* Tranquilmoney Inc.'s PracticeTracker, version 8.0, as an ambulatory Complete EHR, from Drummond Group.


- Joseph Goedert
HDM Breaking News, September 6, 2011

Providers, Vendors Ramp Up Mobile Apps

A delivery system and three vendors have recently announced new health information technology applications for mobile computing devices. They include:

* Carolinas HealthCare System in Charlotte, N.C., has introduced CMC Health, its first mobile app. It enables consumers to find a location within the delivery system and get contact information and GPS directions, check wait times, and search for a physician by name, specialty, practice, ZIP code and keywords. The delivery system this fall will launch an expanded version to support its women's health program.

* Healthcare Blue Book has a free iPhone app that provides treatment price information to consumers. An enhanced app that employers can purchase lets their employees search for in-network providers who offer the best value. "There is no reason a patient should pay $3,500 for an MRI when you can get the same quality test for $700 at another location," says Jeffrey Rice, M.D., CEO at Healthcare Blue Book. The apps are available at the Apple App Store.

* Greenway Medical Technologies has launched a new PrimeMOBILE app for the iPad and iPad 2 to access the vendor's practice management, electronic health record and health information exchange systems. The company issued an app for the iPhone last year and plans an Android version this fall.

* Intelligent Medical Objects now has its IMO Problem and IMO Procedure terminologies available on iPhone and iPad applications. The company's terminology products have been available as embedded components in electronic health records systems from Allscripts, Cerner, Epic, Greenway and NextGen, among others, as well as via a Web portal. The mobile and EHR-accessed terminologies support ICD-9-CM, CPT, SNOMED CT, HCPCS, RxNorm, ICD-10-CA and ICD-10 WHO. The company in October will release ICD-10-CM for EHRs and mobile devices

Joseph Goedert
HDM Breaking News, September 6, 2011

Thursday, September 1, 2011

CMS Issues Final Medicare E-Prescribing Rule

The Centers for Medicare and Medicaid Services has issued a final rule making changes to Medicare's Electronic Prescribing Incentive program. The rule is available now and will be published in the Federal Register on Sept. 6.

As expected, CMS has finalized a proposal to better align the eRx Incentive program with the electronic health record meaningful use incentive program. Under the final rule, EHRs that have received meaningful use certification are deemed to qualify for the eRx Incentive program.

The new rule also finalizes ways for providers to get a "hardship exemption" from the eRx program to avoid reimbursement penalties for non-participation. For instance, an eligible professional who has registered to participate in the Medicare or Medicaid EHR incentive programs and has adopted certified EHR technology can request a hardship exemption from the eRx program.

Even if an eligible professional practices in a state where the Medicaid EHR incentive program is not yet fully implemented, the EP can still register for the program and then seek an exemption from the eRx program.

The deadline for submitting hardship exemption requests, detailed in the final rule, is Nov. 1, 2011.


Joseph Goedert
HDM Breaking News, August 31, 2011

September 9th Medicare & Medicaid EHR Incentive Programs National Provider Call

Hear the Experts Discuss the EHR Incentive Programs


Date: Friday, September 9

Time: 1:30-3:00 p.m. ET

Agenda: During the call, CMS experts will discuss the following topics:

• Path to Payment
• Highlights of Registration and Attestation Processes
• Third Party Proxy
• Troubleshooting
• Helpful Resources
There will also be a Q&A session where experts will address your questions and concerns.

Registration: Register Now for this informative session. Registration will close at 1:30 p.m. on September 8, or when available space has been filled. No exceptions will be made, so please register early.

Presentation Materials: The presentation will be available prior to the call on the presentation section of the CMS EHR website.

Wednesday, August 31, 2011

HIMSS, CDW Team for Meaningful Use Education

The Healthcare Information and Management Systems Society and CDW Healthcare will host five free educational sessions through the end of 2011 covering the transition to electronic health records and qualifying for federal meaningful use incentive payments.

Each session, targeting ambulatory settings, will include a physician who has adopted EHRs and can give real-life lessons, and Mary Griskewicz, senior director of ambulatory information systems at HIMSS. "Our goal is to provide attendees with practical meaningful use knowledge that they can take back and immediately apply to their health care practices," she says.

Sessions are scheduled for Aug. 31 in Seattle, Sept. 27 in Indianapolis, Oct. 20 in Nashville, Nov. 15 in Dallas and Dec. 6 in San Diego. More information is available at himss.org/cdwevents.


Joseph Goedert
HDM Breaking News, August 29, 2011












EHR Meaningful Use Certifiers Stay Busy

Four more electronic health records vendors have recently received federally deemed certification of products supporting one or more measures under the EHR meaningful use program. They are:

* HealthPort's eSmartlog release of information product, Version 1.1, as an EHR Module from Drummond Group;

* OptumInsight's Axolotl EMR Lite, version 9.2, as an ambulatory Complete EHR from InfoGard Laboratories;

* GE Healthcare's Centricity RIS-IC radiology system, version 10.7, as an EHR Module from Drummond Group; and

* Iatric Systems' Public Health Syndromic Surveillance Interface, version 1.5; and Public Health Immunization Interface, version 1.5; as EHR Modules by the Certification Commission for Health Information Technology.

The official government list of certified inpatient and outpatient Complete EHRs and EHR Modules is available here.


Joseph Goedert
HDM Breaking News, August 22, 2011




 

Four Apps Added to EHR Certification Roster

Four additional specific electronic health records products have received federally deemed certification for meeting Stage 1 meaningful use criteria.

"Complete EHR" certification means a product supports all ambulatory or inpatient meaningful use requirements. "Modular EHR" certification means an ancillary application meets one or more requirements. The newly certified products and the certifying entity are:

* Meridios' healthMATRIX 3.0 health registry application, as an EHR Module, certified by InfoGard Laboratories;

* dbMotion's inpatient electronic health records system, version 4.2, as an EHR Module, certified by the Certification Commission for Health Information Technology;

* Perceptive Software's ImageNow document imaging system, version 6.6, as an EHR Module, certified by the Drummond Group; and

* 4medica's Integrated Electronic Health Record, version 10.11, as an EHR Module, certified by CCHIT.

Joseph Goedert
HDM Breaking News, August 12, 2011





Payer, Provider, Vendors Team for MU

Blues plan Highmark Inc., delivery system West Penn Allegheny Health System, vendor Allscripts and consultancy Accenture have created a package of services to assist physicians in Western Pennsylvania to become meaningful users of electronic health records.

West Penn Allegheny is upgrading the Allscripts' MyWay practice management/EHR software used by its 600 employed physicians to the meaningful use-certified version. It also will offer the certified software to 1,200 affiliated physicians, along with consulting services from Accenture. The delivery system's five hospitals are using or will migrate to Allscripts' Eclipsys hospital clinical information system.

Highmark will use its databases to help identify and channel resources to independent physicians to assist in meeting meaningful use and its own incentive programs.

The MyWay software will be locally hosted, but whether Allscripts or West Penn does the hosting has not been determined. The packaged services do not include explicit discounts for the software for affiliated physicians, but West Penn anticipates making the technology available in volume may reduce costs.


Joseph Goedert
HDM Breaking News, August 11, 2011