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Reply to Dr. Jacob Reider on NIST Dissects Workflow: Is Anyone Biting?

One comment on my latest post, NIST Dissects Workflow: Is Anyone Biting?, deserves a more than casual reply.

Here’s the comment from Jacob Reider (Note: Dr. Reider is ONC’s Acting Principle Deputy National Coordinator and Chief Medical Officer. He has made major contributions to the HIT field and is one of its significant advocates.)

Carl, ONC’s UCD requirement references ISO 9241–11, ISO 13407, ISO 16982, NISTIR 7741, ISO/IEC 62366 and ISO 9241–210 as appropriate UCD processes.

We also require summative testing as defined in NISTIR 7742.

Might “Refuses to incorporate NIST recommendations” be a bit of an overstatement?

We solicited public comment in our proposed rule for 2015 certification and would welcome specific suggestions for how we can/should improve user experience of health IT products for efficiency and safety.

Dr. Reider, thank you for your comment – it certainly falls into the category of you never know who’s reading.

Let’stake a look at your last comment first, “Might ‘Refuses to incorporate NIST recommendations’ be a bit of an overstatement?”

Obviously, I don’t think so, but I am not alone.

I based my comment on ONC’s statement in its rule making that refers to NIST’s usability protocols. It says:

While valid and reliable usability measurements exist, including those specified in NISTIR 7804 “Technical Evaluation, Testing and Validation of the Usability of Electronic Health Records,” (21) we are concerned that it would be inappropriate at this juncture for ONC to seek to measure EHR technology in this way.

Sounds like a rejection to me, however, don’t take my word. Here’s the AMA’s response to this decision. First, they demur and quote ONC:

We disagree with ONC’s assertion in the Version 2014 final rule that, “[w]hile valid and reliable usability measurements exist, including those specified in NISTIR 7804 ‘‘Technical Evaluation, Testing and Validation of the Usability of Electronic Health Records,’’ we expressed that it would be inappropriate for ONC to seek to measure EHR technology in this way.”

It then says:

To the contrary, we believe that it is incumbent upon ONC to include more robust usability criteria in the certification process.  The incentive program has certainly spurred aggressive EHR uptake but has done so through an artificial and non-traditional marketplace.  As a consumer, the physician’s choice of products is limited not only by those EHRs that are certified but also by the constraint that all of these products are driven by federal criteria.  The AMA made several detailed recommendations for improving Version 2014 certification in our Stage 2 comment letter, which were not adopted, but still hold true, and we recommend ONC consider them for the next version.  Testimony of AMA’s Health IT Policy Committee’s Workgroups on Certification/Adoption and Implementation, July 23, 2013, pp. 5-6

I recognize that ONC says that it may consider the protocols in the future. Nevertheless, I think the plain English term rejected fits.

In the first part of his statement, Dr. Reider cites several ISO standards. With the exception of the Summative Testing, all of these have been referred to, but none have been adopted. Reference to a standard is not sufficient for its inclusion under the operation of the federal Administrative Procedure Act, which governs all federal agency rulemaking. In other words, these standards are important, but ONC simply calls them out for attention, nothing more.

I think two factors are at work in ONC’s reluctance to include the NIST usability protocols. The first is that the vendors are adamantly opposed to having them mandated. However, I believe there is a way around that objection.

As I have argued before, ONC could tell vendors that their products will be subject to a TURF based review of their product for compliance and that the results would be made public. That would give users a way to judge a product for suitability to their purpose on a uniform basis. Thus, users looking at the results could determine for themselves whether or not one or more non compliance was important to them, but at least they would have a common way to look at candidate EHRs, something they cannot do now , nor under ONC’s proposed approach.

The other factor is more complex and goes to the nature of ONC’s mission. ONC is both the advocate and the standards maker for HIT. In that, it is similar to the FAA, which is vested with both promoting and regulating US aviation.

It’s well established that the FAA’s dual role is a major problem. It’s hard to be a cheerleader for an industry and make it toe the line.

With the FAA, its dual mandate is exacerbated when the highly respected NTSB investigates an incident and makes recommendations. The FAA, acting as industry friend, often defers NTSB’s authoritative and reasonable recommendations to the public’s determent.

I believe that something similar is going on with ONC. NIST’s relationship to ONC is roughly analogous to that of the NTSB’s to the FAA.

NIST is not an investigative agency, but it is the federal government’s standards and operations authority. It isn’t infallible. However, ONC dismissing NIST’s usability protocols, in one word, inappropriate. It did this without explanation or analysis (at least none that they’ve shared). In my view, that’s really inappropriate.

ONC has a problem. It’s operating the way it was intended, but that’s not what patients and practioners need. To continue the aviation analogy, ONC needs to straighten up and fly right.

March 31, 2014 I Written By

When Carl Bergman’s not rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

The Time Has Finally Come for MU, It Really Is Now or Never

The following is a guest blog post by Lea Chatham.
Lea Chatham

The healthcare industry has been talking about Meaningful Use (MU) for years now. The program started in 2011, but there were discussions and planning going on years before that. It’s become a ubiquitous topic in healthcare publications and blogs. So much so that many providers probably still think that they have time to decide if they are really going to attest or not.

The truth is that 2014 is last year to initiate participation for Medicare to receive incentive payments. To avoid the first adjustment of 1%, providers must attest for Stage 1, Year 1 no later than the third quarter of 2014 (July 1 – September 30, 2014). You can still start MU in future years to avoid additional penalties, but you won’t get any incentives and you will still have the 1% deduction on your Medicare Part B Claims starting in 2015. That penalty doesn’t go away if you start MU in 2015 or 2016.

What this means is that the estimated 40% of America’s physicians who don’t’ have an EHR and haven’t yet begun to attest for MU have a decision to make—now. And there are essentially three options:

  1. Choose an EHR and attest in 2014
  2. Accept the penalty (which increases each year)
  3. Request a hardship exception.

Here is what you need to know about each of these options so you can make the right choice for your practice.

Choose an EHR & Attest

Over $16 billion in incentives has been paid out to providers who have been attesting for MU. If you start in 2014, you’ll still get $24,000 over three years for your efforts. You’ll also avoid the penalties, which start with 1% in 2015 and increase each year for a minimum of three years. The larger your Medicare pool of patients, the more sense this makes financially.

If you are going to adopt an EHR now, be sure to choose the right solution for your needs. Many of the providers who have not yet implemented an EHR, are small practices (10 or fewer providers). According to a survey conducted in January by SK&A, the smaller the practice, the lower the adoption rate. Small, independent practices don’t have staff, time, or money to waste. So it has to be right the first time. Take these factors into consideration:

  1. Cost: There are now free and low cost EHRs that can offer almost any specialty the tools they need to reap the benefits of an EHR.
  2. Cloud-based and Mobile: Its 2014, don’t choose an EHR unless it offers anytime, anywhere access and true mobile connectivity.
  3. 2014 Edition Certified for MU: As of January 1, 2014, you need a 2014 Edition certified EHR to attest for MU. Only about 12% of complete EHRs have this certification, which narrows the field.
  4. Total Integration: You can get more from your EHR if it is fully integrated with your practice management and billing system. You can meet MU and streamline many other functions. As a bonus it can actually increase both charges and collections. A UBM white paper showed that the average increase in revenue was $33,000 per FTE provider per year!

Accept the Penalty

So you are thinking you’ll just take the penalty. This may be because you don’t serve Medicare patients or at least not that many. It could also be that you are planning to retire soon and don’t think you’ll be around in another couple of years. But consider this, with MU, PQRS, and eRx penalties, it reaches over 10% in total adjustments to your Medicare Part B claims in five years. If you do start seeing more Medicare patients (as your patients age) or you don’t retire, 10% is nothing to sneeze at. If you are a solo doc and you generate an average of $30,000 a month and about 30% of your patients have Medicare, that’s $10,000 a month. A 10% cut adds up to $12,000 a year. To make that up, you would have to conduct about 100-120 more patient visits a year (if your average visit reimbursement is around $100-150).

And here is something else to consider. Perhaps you are willing to take that hit, and you are sure that you don’t want to attest for MU. But does that mean you don’t need to implement an EHR? Not these days. Patient expectations are changing, and to stay competitive you need to meet those expectations. A study conducted by the Optum Institute showed that 62% of patients want to correspond with their physician online and 75% are willing to view their medical records online. Another survey conducted by Deloitte showed that two-thirds of patient would consider switching to a physician who offers secure access to medical records online. You need patients to stay in business so take their changing needs seriously or you may struggle to stay competitive in changing times.

Request a Hardship Exception

The first thing that needs to be said here is that not everyone can apply for a hardship exception. If you’d like to attest for MU, but need more time AND you meet one or more of the criteria, then you should definitely consider this option. This is a summary, check the CMS tipsheet to find out more:

  1. Your area lacks the necessary infrastructure (i.e., no broadband)
  2. You’re a new provider
  3. Natural disaster or other unforeseen barrier
  4. Lack of face-to-face interaction with patients
  5. Practice in multiple locations
  6. EHR vendor issues (i.e., your current vendor was unable to certify for 2014 edition)

For most providers who are practicing full time in a single location and have not yet chosen an EHR, these exceptions won’t apply. This leaves you with choices and one and two above. You will still need to decide if you want to attest or not.

If you are still on the fence, consider this… Beyond MU, practices are facing the ICD-10 transition and a changing reimbursement landscape with ongoing reform from of the Affordable Care Act (ACA). Technology can be a very effective tool to help you manage these changes and turn this set of challenges into an opportunity to optimize your practice and position your business for success no matter what comes your way.


About Lea Chatham

Lea Chatham is the Content Expert at Kareo, responsible for developing educational resources to help small medical practices improve their businesses. She joined Kareo after working at a small integrated health system for over five years developing marketing and educational tools and events for patients. Prior to that, Lea was a marketing coordinator for Medical Manager Health Systems, WebMD Practice Services, Emdeon, and Sage Software. She specializes in simplifying information about healthcare and healthcare technology for physicians, practice staff, and patients.

March 27, 2014 I Written By

CMS Adds Vendor Unreadiness To Meaningful Use Hardship Exemptions

After watching providers struggle to get their vendors in line for the next round of attestations, CMS has decided to give hospitals a break where vendor unreadiness is concerned in meeting Stage 2 Meaningful Use requirements.

Until recently, lack of infrastructure and unforeseen or uncontrollable circumstances were the only criteria CMS would consider in granting hardship exemptions to providers struggling with reading Stage 2 requirements.

Now, CMS has taken a new step demonstrating that it understands that EMR vendors are not up to speed many cases. CMS has added “2014 EHR vendor issues” as an acceptable reason to receive a hardship exemption to Stage 2 requirements.

To qualify for this exemption, the hospital’s EHR vendor must have been unable to obtain 2014 certification of the hospital was unable to implement Meaningful  Use due to 2014 EHR certification delays. According to the form required to apply for this exemption, “circumstances must be beyond the Hospital’s control and the Hospital must explicitly outline of the circumstances significantly impaired the Hospital’s ability to meet Meaningful Use.”

CMS has also offered additional hardship exemptions to eligible professionals. Eligible professionals can use “lack of control over the availability of Certified EHR Technology” and “lack of Face-to-Face interaction” as well as EHR vendor issues lack of infrastructure and unforeseen/uncontrollable circumstances.

The expansion of hardship exemptions follows a letter that was sent by six Republican senators last week to CMS requesting clarification of the qualification criteria for the hardship program. The Senators, in their letter, asked CMS how hardship categories might be expanded.

As I see it, it’s good to give providers a break under these circumstances, as they can hardly control whether their vendors have their act together. The question is, how long can CMS continue to give providers and vendors exemptions without undermining their larger policy goals?

March 11, 2014 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @annezieger on Twitter.

Meaningful Use Changes Focus to a To-Do List and Away from Patient Care

I was reading a message from a doctor recently that really struck me. He commented about the impact of meaningful use on his EHR use and said that he’s now “trying to figure out what to do next instead of trying to figure out what is wrong with a patient.”

I’m sure some doctors will come on here and argue why the person experiencing this is a bad doctor and why they should always be focused on patient care and not checking the next box. While there’s always a balance in everything we do, the comment from this doctor really struck me because it describes really well the way so many doctors are being trained to use their EHR. They literally have people auditing and tracking them to make sure that they’re checking the right check boxes so they can meet meaningful use. This type of hyper focus on checking the right boxes and punishment when you don’t changes the way someone practices medicine.

I always love when people comment that many doctors didn’t like the stethoscope when it came out. They use that story to explain that many doctors don’t like EHR software, but that they’ll come around the way they did with the stethoscope.

While there’s some merit in this analogy, I can’t imagine there was anyone watching how a doctor used the stethoscope to ensure that it was used in a specific manner. That’s what we have going on in the EHR world today. Meaningful use is so prescriptive in its requirements that it overwhelms a doctor to the point of affecting the quality of care they provide.

Think about the efforts that are being made by EHR vendors and EHR consultants to take the meaningful use load off of a doctor’s back. Everything from changing the design to meet the MU requirements without a major change to workflow to offloading as much of the meaningful use requirements to someone other than the doctor. If meaningful use really was of value for doctors, why would they have to go to all this effort to avoid doing it?

March 4, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

Meaningful Use Payouts Hit $19 Billion

The pace of meaningful use payouts has stayed strong of late, with CMS disclosing that it has disbursed more than $19 billion in EMR usage incentives. While hospitals have been particularly prone to stay on the meaningful use train, eligible providers are collecting their payouts too, according to Healthcare IT News.

According to CMS data, there were 440,998 registered providers participating in the federal EMR incentive program as of the end of 2013, who have to date received 19.2 billion in incentives.

About 88 percent of all eligible hospitals have been given EMR incentive payment so far, according to CMS officials.  Also, about 60 percent of Medicare eligible providers are meaningful users of EMRs, the agency reports.

And the meaningful use programs for Medicare and Medicaid are both active, with more than 340,000 eligible providers having received an incentive payments to their program. Medicaid eligible providers are distinctly less likely to be involved in the meaningful use program; only 20 percent of Medicaid EP’s are meaningful users.

What the Healthcare IT News article doesn’t discuss, but ought to, is that there is considerable evidence that many doctors are not willing to push beyond Stage 1 of meaningful use. Stats suggest that these doctors have little financial incentive to move ahead with Stage 2, and can’t afford the time or money to push through the MU 2 obstacles.

In other words, before CMS runs a victory lap, it might do well to see what’s happening with the doctors walking away from the program.

February 12, 2014 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @annezieger on Twitter.

Value of Meaningful Use – Perspective from EHR Executive at simplifyMD

The following is a guest blog post by Michael Brozino, in response to the question I posed in my “State of the Meaningful Use” call to action.

If MU were gone (ie. no more EHR incentive money or penalties), which parts of MU would you remove from your EHR immediately and which parts would you keep?

Michael Brozino
Michael Brozino
Michael Brozino, CEO of simplifyMD

If Meaningful Use were no longer a requirement, we would keep our software the same. I say this because there is nothing in our system that was built within the requirements of Meaningful Use that weren’t deployed with the intent of improving patient engagement, enhancing public health, promoting health record portability and improving software interoperability. The fact that 100 percent of our users who have chosen to attest for MU have been successful is certainly a benefit, but we don’t see much reason to remove any functionality unless the user’s benefit diminishes significantly and it becomes too expensive to support and implement.

Rather, if MU disappeared, we would hope that the entire healthcare industry or government would implement centralized, universal healthcare data exchanges and/or hubs to ease interoperability and promote uniformity. Features such as personal health records, electronic delivery of labs and receipt of orders, syndromic surveillance data, state immunization records, clinical decision support rules, secure patient messaging, and many others could have been easily implemented if the government fully committed to putting them in place. By only going halfway, standardization is left to a group of players that by their very nature are opinionated and independent.

ePrescribing, for example, has thrived because a central hub exists to allow competitors to quickly join the network. Competition between these organizations is now about who delivers the best user experience, the best customer support, and who adds the most value to their product. If such a central exchange were created for the interoperability requirements in MU, we would have already surpassed the goals of Stages 2 and 3 by 2014.

See other responses to this question here.

February 11, 2014 I Written By

If Meaningful Use Were Gone – Perspective from EHR Executive at Modernizing Medicine

The following is a guest blog post by Michael Sherling, MD, in response to the question I posed in my “State of the Meaningful Use” call to action.

If MU were gone (ie. no more EHR incentive money or penalties), which parts of MU would you remove from your EHR immediately and which parts would you keep?

Michael Sherling
Michael Sherling, MD, MBA
Chief Medical Officer and Co-Founder, Modernizing Medicine

What a great question! As both the co-founder of Modernizing Medicine, and a practicing dermatologist that uses EMA, I can appreciate the amount of time and effort it goes into developing MU feature sets, as well as inputting the data in to be a “meaningful user.”

The Top 3 Measures I would remove

  1. Clinical Summaries Provided to Patient
  2. Vital Signs
  3. Clinical Quality Measures

I understand the intent for patients to receive clinical summaries of each visit- but this places an incredible burden on the end user (physicians and office staff) to make sure that each patient has access to their clinical summaries.  For instance, even though we live in the digital age, several of my older patients don’t own a computer or have access to one.  Additionally, these summaries lead to more questions by the patients after the visit has been concluded often times regarding details of the summary that are relatively innocuous.

I have a serious beef with government mandating of Vital Signs.  Health care providers know when it is medically necessary to take vital signs and when it is not.  Those who never take vital signs, because it is unrelated to their scope of practice can claim exceptions, but those who take a few are often stuck between their medical responsibilities and getting an incentive.  In the end, these dermatologists and ophthalmologists wind up taking more blood pressures or measuring the height and weight of their patients unnecessarily to achieve the incentive.  This paradoxically is medically meaningless since dermatologists don’t treat blood pressure, and ophthalmologists don’t often dose weight-based drugs (they like eye drops).

Clinical Quality Measures needs to be renamed to Cost Effective Measures.   Clearly, the goal of CQM is to change physician behavior so that physician decisions are more cost effective.  This is needed in our health care system.  What today is an incentive based on pay for reporting, will be transformed to pay for performance tomorrow.  My concern as a physician is how do we know these are the right questions to ask?  If physicians comply with these CQM guidelines, will that result in not just lower costs, but more effective care?  I’d much rather see benchmarking around actual patient clinical outcomes themselves, using tools like static global assessments of disease rather than a questionnaire about whether or not I followed a recipe for how a committee thinks I should treat every patient with condition Y.

The Top 5 Measures I would Keep

  1. Electronic Prescribing
  2. Medication List
  3. Allergy List
  4. Drug-Drug, Drug-Allergy Interaction Checks
  5. Patient Search

All of these measures are critical to patient care and have obvious benefits.  With electronic prescribing, prescription orders are standardized and LEGIBLE! No need for the pharmacist to discern my own poor doctor handwriting anymore.   Keeping the medication and allergy lists updated and the drug-drug and drug-allergy checks enabled makes for great patient care.  No physician wants to prescribe a medication that interacts with another in a negative way, nor do we want to prescribe a medication that could potentially cross-react with a known allergy. Finally, patient search is a really cool feature that allows all of us to search for patients with specific diseases and medications. This is an important first step in getting records to behave more like research databases for clinical studies and less like word-processors for just note taking.

February 3, 2014 I Written By

Interview with ICSA Labs About EHR Certification

After hearing the news about CCHIT shutting down it’s EHR certification business, I thought it would be interesting to interview ICSA Labs, the EHR Certification body that CCHIT recommended to its users. The following is an interview with George Japak, Managing Director at ICSA Labs.

Is there a backlog of EHR vendors that want to schedule test dates with ICSA labs?  

A: There is no backlog. Since ICSA Labs received its ONC authorization, it has been our intent to grow our healthcare programs and offer the best testing and certification program in the industry. Over time we have ramped up our testing team and we have a deep pool of very experienced testers on staff. We have been getting a steady stream of news customers and inquiries and expect the CCHIT announcement will accelerate the pace.  At this point we have the capacity to test applicants as they are prepared to do so.

Is ICSA Labs able to support the onslaught of EHR companies that will come over from CCHIT?  Will that cause any delays on getting EHRs certified?

A: ICSA Labs at this point does not anticipate any delays. The ONC program was designed so that vendors and product developers would have a choice when it came to testing and certification. We were not the first lab to be authorized, but we knew that given the opportunity we would be able to deliver a program where customers would experience high satisfaction.

In my post, I suggested that the economics of EHR certification aren’t all that great.  Especially if you have a legacy cost structure like CCHIT.  Is the secret to ICSA’s success having a broader certification business beyond just EHR?

A: ICSA Labs has been in business since 1989, we have a number of accreditations to support an array of certification and testing programs, such as the IHE USA Certification program which just kicked off its second year at the 2014 IHE North American Connectathon. Our business is diverse and we leverage our capabilities across our business. We are used to doing business in competitive markets, so it has always been important for our programs and cost structure to emphasize efficiency and effectiveness and those benefits are passed onto our customers. Our testing and certification programs have always been competitively priced and efficient yet rigorous and done superior quality.

How much more complex is 2014 EHR certification compared with 2011 from an ONC-ACB perspective? 

A: As any recently certified company can attest to, the 2014 Edition criteria are significantly more complicated than the 2011 Edition. There are more test tools to maintain; more test data sets to review; frequent revisions and updates to the criteria and additional types of attestation to review. The time to complete testing has close to doubled and there are more requirements as they pertain to surveillance. After the 2011 Edition criteria, ICSA Labs asked for ONC to raise the bar, and they did. For ICSA Labs the added complexity was not unexpected.

The timelines for meaningful use stage 2 are starting to get squeezed.  Will the majority of EHR vendors be 2014 certified and ready in time?

A: There will always be stragglers, but I believe a majority of EHR vendors will be 2014 certified and ready in time for Meaningful Use 2. There has been an uptick in the vendors getting certified over the last few months. Providers and hospitals however are a different story, and they may feel the squeeze in terms of the timeline to purchase, implement and begin meaningfully using their EHR system. ONC extended the Stage 2 timeline to relieve some of that pressure.

I’ve heard that in some cases the ONC-CPHL has been slow at putting up newly certified EHRs.  Have you seen this?  Do you have a bunch of 2014 certified EHR vendors that haven’t been listed on ONC-CPHL yet?

A: The ONC-CHPL is generally responsive to our concerns and we work with them as they continue to refine new features like links to the public test results summary.

January 31, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

The State of the Meaningful Use

UPDATE:
If meaningful use were gone (ie. no more EHR incentive money or penalties requiring meaningful use), which parts of meaningful use would you remove from EHR immediately and which parts would you keep?
Responses:
*Michael Sherling, MD – Modernizing Medicine
*Shahid Shah – Influential Networks
*Joel Kanick – interfaceMD
*Michael Brozino – simplifyMD
*Dr. Michael Koriwchak
*Karen Knecht – Encore Health Resources

I recently wrote what’s been a really popular article on EMR and HIPAA called “Meaningful Use Program a Success…Depending on How You Measure Success.” I think we’re at an interesting point in the meaningful use program and it’s worth taking a step back and seeing where we’re at with meaningful use.

As I state in the other article, there’s no doubt that the EHR incentive money has moved the needle on EHR adoption. Those of us who believe that EHR holds lots of potential benefit to healthcare have to be happy about the amazing EHR adoption rate that has occurred thanks largely to $36 billion of EHR incentive money (we’ll save the question of whether we’ve gotten our money’s worth for another post).

While we could Monday Morning quarterback (appropriate football reference the week of the Super Bowl) the EHR incentive program and meaningful use, that won’t change the fact that it’s here and it’s not going anywhere. So, instead of asking whether we should have spent the money on EHR and whether we should have done meaningful use, I decided to take a deeper look at meaningful use and how we could improve the program. Which elements of meaningful use are really adding value and which parts of meaningful use should be removed? Or maybe it’s all great and we should just continue on the path we’re on.

I decided to use a simple approach to identify what’s good and what’s bad with meaningful use. I reached out to EHR vendors, doctors, practice managers, hospital executives, and other EHR experts and asked them a simple question. The answers to this question should provide a solid understanding of what’s meaningful in meaningful use and what’s not.

Here’s the question I asked:
If meaningful use were gone (ie. no more EHR incentive money or penalties requiring meaningful use), which parts of meaningful use would you remove from EHR immediately and which parts would you keep?

The concept is simple. If there wasn’t some outside influence (ie. government money) influencing the requirement to do meaningful use, which elements of MU actually provide value to the users of an EHR. Those that provide value will continue to be embraced by an EHR vendor and those that don’t will be removed. Plus, this is the reality of what’s going to happen once the EHR incentive money runs out, so let’s find this info out now.

I originally thought that this question would lead to a blog post with quotes from a variety of people offering their unique perspectives. However, every person who’s answered so far had so much to say on the topic, that each of their responses was worthy of a blog post of its own.

With that in mind, over the next couple of weeks, I’ll be posting all of the responses as separate posts across the network of Healthcare Scene blogs. I’ll link each of these blog posts at the bottom of this post as they are published.

Open Call for Participation
As I considered this, I realized that hundreds of other people might want to participate as well. As a health IT community I think we can make a real impact. So, I encourage everyone who reads this to publish their response to the question above.

If you have your own blog, publish it there and link back to this post so we can add your post to our list below. If you don’t have a blog, wish to remain anonymous, or would just rather have us publish it, we’re happy to publish it for you. Drop us a note on our contact us page and we can work out the details.

I believe this will become an incredible resource of information to better understand how to improve meaningful use. Once I’ve gathered a good number of responses, I’ll be reaching out to ONC and CMS to make sure they take in the body of contributed work as well. Hopefully this simple approach will be effective at gathering a response from more people than the convoluted rule making process was able to do.

Meaningful Use will go down as one of the most impactful things to hit healthcare IT and EHR in my lifetime. It behooves us to do what we can to make the most of meaningful use.

January 30, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

McKesson, Meditech Chosen As EHR Test Systems for Meaningful Use

Here’s an interesting situation which is just popped up on my radar screen.  CMS and the ONC have chosen the first two vendors to serve as designated test EHR systems, and they’ve gone with McKesson and Meditech.

These test vendors are there to help eligible providers meet the requirements of Meaningful Use Stage 2.  To meet MU Stage 2 requirements, providers must successfully conduct at least one exchange test with a CMS-designated test EMR. (The providers can also meet the requirements by performing one electronic exchange of a summary of care document with a recipient using a different EMR technology.)

What intrigued me about this is that CMS and ONC are starting out with only two vendors for use as test EMR providers.  Given the diversity in the marketplace, you’d think that CMS would want to have fuller stock of vendors lined up before it went forward announcing its plans.

If I were an eligible provider going this route, I’d want to have the choice of a wider range test EMRs. Given how little real interoperability there is between EMRs, I’d like to know that I had a fallback position if my original tests didn’t work out.  After all, nothing I’ve read here suggests that EPs won’t have a chance to try again if the initial testing doesn’t go through, and if I were a provider, it’d be good to know that I could take the shot with other test EMRs. But I could be wrong, and that could have an effect on whether vendors see this as a win.

Let’s see if other substantial EMR vendors take up the ONC’s call to serve as test EMR participants.  It will be interesting to see whether vendors see participation as a credibility-raiser or a chance to get pantsed publicly if interoperating with their systems is a pain.

January 23, 2014 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @annezieger on Twitter.