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?
Patient engagement solutions abounded at HIMSS14, though their levels of sophistication varied. Like many other commentators, I felt this was a big jump in interest over last year. It will be interesting to see if this level sustains into 2015, and how the same products will mature come HIMSS15 in Chicago.
The theme of engagement was heard most loudly in several educational sessions I attended. I was happy to pre-register for an Orion Health / ePatient Dave event; and make time at the last minute to attend a live demo of the new Blue Button Connector, and a brief presentation by Regina Holliday, founder of the Walking Gallery.
I believe ePatient Dave (aka Dave deBronkart) has been at this awhile, but the Orion Health lunch and learn I attended was my first opportunity to hear him tell his story live. And what a compelling story it was! It certainly resonated with the audience of about 75, and I couldn’t help but wonder why he wasn’t up on stage in a “From the Top” session. The theme that ran throughout his presentation and audience questions was the need for online patient communities, and the subsequent need for providers to let their patients know about them. Websites like PatientsLikeMe.com and Sharecare.com were brought up as interesting resources.
I headed from there to the exhibit hall, where HIMSS had set up a very nice learning gallery, complete with comfy chairs, swivel desktops and a nice presentation area. Lygeia Ricciardi spent a good 20 minutes going through the new Blue Button Connector website, which you can find here: http://bluebuttonconnector.healthit.gov/. While not a true, live demo, she did offer several screenshots, and was very forthcoming about the ONC’s plans and goals for the site. Apparently they see it as almost a marketing tool, similar to the Energy Star label you see on just about every appliance these days. The Blue Button symbol will hopefully come to be recognized as an endorsement of easy access to patient data. She was frank in saying that it’s not a panacea, but will be a powerful tool in the hands of consumers, and developers who choose to take advantage of its open source code and bake it into their own apps.
It is literally a connector. The new website simply allows patients to connect to third parties that may house their medical records, such as payers, pharmacy, labs, physicians or hospitals, immunization registries and health information exchange portals. Knowing I already have a provider that participates in Blue Button via their athenahealth patient portal, I went through the “Physician or Hospital” steps to see how the Connector worked. I didn’t see my physician listed, so I’ll likely send an email to email@example.com. The Connector is in beta right now, and Riccardi mentioned they are very interested in gathering as much user feedback as possible during this process, so I encourage you to check it out and drop them a comment or two.
I was back at the Learning Gallery the next afternoon to hear Regina Holliday of the Walking Gallery speak, and she did not disappoint. Like a preacher that just can’t stay in the pulpit, Regina passionately talked about the power patients have when they come together and demand change. It was my first time hearing her speak live and I was not disappointed. It was a powerful sight to see close to 30 Walking Gallery members stand up at the end of her session and show their jackets. Why they were not on a larger stage in front of a capacity audience is beyond me.
That’s it for my notes from HIMSS. Next up on my conference dance card is the Healthcare IT Marketing and PR Conference, taking place April 7-8 in Las Vegas, and hosted by Healthcarescene.com. I hope to see you there!
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.
I don’t think it will be news to anyone reading this that HHS is getting hammered for their implementation of Healthcare.gov. Sebelius congressional testimony was brutal. Certainly the botched implementation of Healthcare.gov will have long lasting impacts on all future HHS IT projects.
While not purely an IT project, I wonder if the experience of Healthcare.gov will have an impact on the ICD-10 implementation. Will HHS be gun shy after the Healthcare.gov debacle that they’ll delay ICD-10 to avoid another one?
My gut reaction is that I don’t think this will happen, but it’s worthy of consideration.
On October 1, 2014, HHS’s IT isn’t ready to accept ICD-10, then you can read the headline already: “HHS Botches Another IT Project.” For those of us that work in healthcare IT, we know that ICD-10 has deep IT implications. Not the least of which will be CMS being ready to accept the ICD-10 codes. While you’d think this is a simple change, I assure you that it is not. Plus, if CMS isn’t ready for this, a lot of angry doctors and hospitals will emerge. It will be a major cash flow issue for them.
We still have almost a year for HHS to get this right. Plus, HHS has had years to plan for this change so they shouldn’t have any IT challenges. Although, if they do have IT challenges this extended time frame will damage them even more. The article will say they had plenty of time and they still couldn’t implement it properly.
With the comparison, there are also plenty of reasons why ICD-10 is very different than Healthcare.gov. In many ways, ICD-10 is a project implemented by companies outside of HHS as opposed to a project run by HHS. First, I think it’s unlikely that HHS won’t have their side ready for ICD-10. Second, their part of ICD-10 is very little compared to what has to be done by outside payers, hospitals, and doctors offices.
If ICD-10 has issues it will likely be seen as the payers or healthcare organizations not being ready as opposed to HHS. That’s not to say that HHS won’t have some damage if they force an ICD-10 mandate and people aren’t ready. They could have some collateral damage from it, but not the same as Healthcare.gov where the product is really their own product.
Plus, if ICD-10 goes bad, consumers/patients won’t know much difference. No patient cares if you code their visit in ICD-9 or ICD-10. They’ll still get the exact same care when they’re visiting the doctor. If ICD-10 goes bad, it will be doctors and hospitals that suffer. That’s a very different situation than Healthcare.gov which was to be used by millions of Americans.
I hope that HHS doesn’t delay ICD-10 based on their experience with Healthcare.gov. If HHS becomes gun shy about any project that IT touches, nothing will ever get done. That’s a terrible way for an organization to function.
E-prescribing has become almost commonplace, if not universally used, among providers with EMRs during the last four years, a new study concludes. The study, which was published in The American Journal of Managed Care, was conducted by a team led by ONCHIT’s Meghan H. Gabriel, PhD. Researchers found that between 2008 and 2012, the total number of e-prescribers using Surescripts shot up from 7 percent (47,000 providers) to 54 percent (398,000), according to a report in EHR Intelligence.
As EHR Intelligence notes, these numbers didn’t just appear out of nowhere. Part of the reason e-prescribing has gained so much ground is that 94 percent of pharmacies are now able to accept e-prescriptions, up from 61 percent in December 2008.
It’s a good thing pharmacies are on board. E-prescribing must be in place – specifically, certified EHR technology (CEHRT) — to meet one of the requirements of Stage 2 Meaningful Use. The requirement is that eligible providers need to transmit more than 50 percent of “all permissible prescriptions” via their CEHRT, EHR Intelligence points out, 10 percent higher than the Stage 1 requirement.
Side note: CMS seems happy with e-prescribing progress to date. According to the agency, more than 190 million electronic prescriptions had been sent by doctors, physician’s assistants and other healthcare providers using EMRs. That 190 million is the cumulative total sent since the inception of the Meaningful Use program in 2011.
But from my way of looking at things, it isn’t completely kosher that e-prescribing by providers is barely over the half-way mark, despite representing considerable improvement over the years. While 54 percent is a nice round number, it still suggests that nearly half of providers are not equipped to achieve compliance with Meaningful Use Stage 2, an undesirable situation at best.
No, despite the improvement in e-prescribing uptake, to me the current stats actually look like a problem, not a win at this stage. The 46 percent of providers not online with e-prescribing had better get their act together.
What a strange week in healthcare IT it’s been, particularly where EMRs are concerned. First came breaking news that Kim Kardashian’s privacy potentially had been breached (insert ironic arch of eyebrow) by Cedars-Sinai employees who had inappropriately accessed patients’ private medical records last month. Then came much more noble press via NPR, which has devoted a series on All Things Considered this week to profiling the world of EMRs:
I had to shush my husband – clap a hand over his mouth, actually – when the NPR interview with Farzad Mostashari came on. “I’ve met that guy!” I told my husband. “He’s a celebrity in our industry, but for all the right reasons!” It was almost invigorating, especially after reading Kardashian headlines, to hear him discuss the many points we’ve all been debating and/or covering for the last few years. He was just as much a compelling cheerleader for the adoption of EMRs and the impact they are likely to have on patient safety as he had been when he bounded across the stage at HIMSS a few years ago.
Which brings us to the middle of the week, when CMS released its latest set of data touting the latest round of EMR success:
More than 50% of eligible health care professionals and 80% of eligible hospitals have begun using electronic health record systems since the meaningful use program launched in 2011
Shared more than 4.6 million EHR copies with patients;
Sent more than 13 million appointment, test and check-up reminders;
Checked medication interactions more than 40 million times; and
Sent more than 190 million electronic prescriptions
I’m beginning to think that CMS and federal agencies like the ONC are really getting the hang of this media game. I’m sure it’s no coincidence that NPR ran its stories the same week CMS released its latest success story. I just wonder how the general public is digesting this information. With 80% of hospitals now on EMRs, it’s a safe bet that the majority of patients in this country (even Kim Kardashian) have information stored away in one. Are they beginning to realize the benefits this technology brings to their care? Or are most patients still uneasy with the lack of eye contact from their doctors, who are now glued to a computer screen?
Do the CMS numbers tell the whole truth? Has patient safety increased to the detriment of patient satisfaction with bedside manner? Let me know your thoughts in the comments below.
I’m a big fan of historical fiction, and just finished up “Madame Tussaud: A Novel of the French Revolution”by Michelle Moran. I’ve read many fictional and non-fictional accounts of that time period, but the depiction of the French citizenry’s dissatisfaction with the monarchy and just about everything else in their society struck a particular chord with me this time around. I don’t think I go too far in saying there is just a hint of their discontent brewing in the world healthcare consumers. While consumers and patients haven’t quite reached the level of hysteria the likes of Robespierre or Marat did centuries ago, there now seems to be a societal voice given to a need – I’d go so far as to say a right – to know the true costs of medical services before and after they are supplied.
And I wonder if the government’s push towards electronic medical records and more coordinated care isn’t halfway to blame. Easily accessible information, such as patient health data and doctor’s notes that can now be placed directly in patients’ hands has made us all wonder, “If I can understand the reasoning behind my doctor’s directives, why can’t I understand the reasoning behind the cost of that care?”
I mentioned last week my discontent with the way I was approached by my hospital to pay for labor and delivery services shortly after my daughter’s birth. It was no surprise to me then to come across “American Way of Birth, Costliest in the World,” a well-written article in the New York Times chronicling a number of mothers’ similar frustrations with healthcare costs, billing and payment. In these days and times, I could not imagine trying to navigate the financial part of pregnancy, labor and delivery without insurance coverage. And it saddens me that for all the money that we spend in this area of healthcare, our infant and maternal mortality rates are nothing to be proud of.
But I digress. My true point this week is that there is a growing movement by consumers to demand transparency into healthcare costs – ideally before treatment is given, but most definitely after it is received. Providers should be able to explain services line item by line item, and consumers should be able to compare the costs of those services provider by provider, hospital by hospital. I’m confident we’ll get there, as this movement only seems to be growing. There’s an interesting timeline that has occurred:
March 4 – Time Magazine publishes Steven Brill’s oft-referenced article “Bitter Pill: Why Medical Bills are Killing Us,” perhaps kicking off CMS’ attempts to bring greater transparency to healthcare costs
May 7 – CMS releases new open dataset to shed light on hospital pricing variations
May 8 – Mainstream press, such as The Washington Post, publish lengthy online articles complete with data visualizations to assist consumers in understanding the vast differences between what hospitals charge Medicare for their services.
May 15 – CMS releases state and national averages a week after The Washington Post article, aggregating the data for comparison on the state level.
June 3 – CMS releases another wave of data, including average estimated submitted charges for 30 types of hospital outpatient procedures; information on Medicare spending and utilization at the county, state and hospital-referral region; and the prevalence of certain chronic conditions among Medicare beneficiaries.
July 5 – The Center for Studying Health System Change releases study on “Geographic Variations in the Cost of Treating Condition-Specific Episodes of Care among Medicare Patients” showing that geographic variations in Medicare medical treatment costs can differ among episodes of care for certain conditions and not only across but within regions.
How will all this play out in the coming years? Will consumers continue and increasingly demand to know what healthcare will cost them? Will private payers offer up this same type of information sooner rather than later? Should this knowledge be a right, rather than a privilege? What do you think? Let me know via the comments section below.
My third trip to the HFMA ANI show was by far the best yet, for a number of reasons. I found the overall event to be easily manageable in terms of way finding, session offerings and overall organization. Every HFMA volunteer I encountered had a smile on their face, and that’s saying something at 7:15 three mornings in a row. This positive attitude was also evident in the brief keynotes given by the association’s executives and board members, including Ralph Lawson, Steve Rose, Melinda Hancock and Joe Fifer. Each exuded an air of gratefulness at being put in a position of leadership, and seemed optimistic – yet realistic – about the future of healthcare.
Rose was particularly realistic in his comments, noting that the event’s theme of “Whatever it Takes” is one that he applies to his own life, most notably (visually at least) in the area of weight loss. I have to admit, it’s always nice to see healthcare professionals being healthy. (I didn’t see many taking advantage of the doughnuts during the continental breakfast each morning, though everyone does seem to love their caffeine and a few even snuck a cigarette – yuck!)
The only tone of dissension I detected amongst HFMA’s ranks was a result of the keynote given by Joe Gibbs, a celebrated football coach and racing team owner unknown to me before the event. As Gibbs spoke about leadership and picking the right players, I wondered how his testosterone-fueled keynote would compare to the first “Women as Leaders” session held a few days later. While Gibbs’ presentation was so-so, the female-centric session held a few days later was amazing. It was at times confessional in tone, always blunt and occasionally tear-inducing. Five HFMA board members shared their struggles, their triumphs and advice around working, parenting and trying to juggle both. It was refreshing to hear each of them go off script – touching on faith, values, husbands, kids and extended family.
I had the chance to attend most of the keynotes, a session on the challenges faced by small, independent hospitals, and the Women as Leaders panel. I spent a ton of time in the exhibit hall, and will cover that part of the show in next week’s post. For now, I’ll cover some high-level themes I gleaned from talking with attendees and exhibitors, and share a few pictures.
1. It’s time for hospitals to be more proactive in reaching out to payers and physicians, especially when it comes to sharing data. I had no idea that the “H” in HFMA once stood for Hospitals, so this inclusiveness has been in the works for some time. My thinking is that as the industry consolidates and hospitals try to become payers, payers buy hospitals, and physicians get caught in between, it’s only natural that an association like HFMA broaden its horizons to better serve its constituents.
2. Value-based care seems to the new name for accountable care and/or coordinated care. It’s certainly a phrase that will resonate better with consumers, which leads me to number three.
3. Everyone is aware of the need for more transparency into healthcare costs. Consumers have become more vocal in demanding it, and some hospitals are beginning to see the light, offering pre-service estimates. In fact, Fifer announced that HFMA has formed a task force to address the issue of price transparency in healthcare. You can view his announcement below:
4. Health insurance exchanges were covered copiously in sessions I was unable to attend. The “what ifs?” certainly outnumbered the “without a doubts.” I’ll be interested to see how these conversations go next year, once every state is in deep.
5. I did not hear one mention made of mobile health during the entire conference. I realize the attendee demographic is more finance than IT, but I would have thought at least one or two sessions would have addressed mobile health and the benefits this concept and technologies bring to healthcare’s bottom line. Isn’t mobile health key to cost containment and patient engagement?
I’m beginning to think Orlando is my favorite city for conferences. This picture pretty much says it all – beautiful area of town, sunny skies with the typical once-a-day shower, and definitely warm. Even though it was humid, the outside atmosphere was a welcome respite from the absolutely freezing temperatures inside the convention center.
Joe Gibbs gave Monday morning’s keynote. He kept referring to “salesmen,” which made me wonder if he’d been properly debriefed.
This was a pretty interesting panel on the fate of small, independent hospitals. It helped paint a much clearer picture for me of the competitive markets these types of hospitals face.
Dr. Don Berwick, former head of the CMS, gave my favorite keynote on Tuesday morning. It was fairly high level in nature, but he presented seven or eight examples of healthcare organizations that were taking the term “value-based care” to new levels. He referred to the much venerated “Triple Aim” often, and shared a number of slides, including the one above on “The Structure of the Affordable Care Act.” Notice the word “partial” at the end. To me, this slide conveys the complexity and somewhat confusing nature for the ACA.
That’s all for now. I’ll follow up next week with observations from the exhibitors hall. I’d be interested to hear from anyone else who attended what they took away from the event.
Are you ready to be reviewed? Well, get prepared. As part of its ongoing program of supervision, CMS plans to audit 5 percent of participants in the Meaningful Use program for compliance, according to Modern Healthcare.
Since January, CMS has been auditing program participants that have already received their money, as well as those who have applied to receive incentive payments. Going forward, the two groups will receive about the same level of attention, with a total of 5 percent of program participants ending up getting closer scrutiny from the feds, MH reports.
To date, there haven’t been many adverse findings by CMS, though the agency has discovered a few questionable situations, Robert Anthony, deputy director of the HIT Initiatives Group at CMS, told the magazine. But a few providers are already beginning the appeal process, and several providers may face fraud enforcement investigations, he said.
The bulk of the Meaningful Use reviews will be what the agency dubs “desk audits,” done by the CMS audit contractor Figliozzi and Co., in which information is exchanged electronically. However, a few on-site audits may be conducted as well, Anthony told Modern Healthcare.
To date, among the most common problems CMS has learned about has been provider failures to meet the requirement that they complete a data security risk assessment, a step also required by HIPAA. When the auditors find that a provider hasn’t done the required data security risk assessment, they could be referred to the HHS Office of Civil Rights for a HIPAA compliance investigation.
Another issue which has turned up frequently has been a lack of adequate documentation that providers have answered some of the “yes or no” questions which are part of Meaningful Use criteria, such as whether their EMR has been tested for clinical data exchange. In that case, providers must be able to document what happened whether or not the test was successful.
When providers attest to Meaningful Use Stage 1 compliance, they have to identify the vendor whose EMR they used. But what if a large number of providers were faking this step in an effort to get incentive money that they don’t deserve? That would be a lot of fraud, no?
Well, according to one vendor CEO, this could be happening on a large scale. Mike Jenkins, CEO of cloud-based vendor BuildYourEMR.com, reports that after going over CMS data on Meaningful Use, he found that a whopping 74 percent of providers who attested to using his company’s technology were not his customers.
Jenkins points out that if fraud were actually this common, a full $5.4 billion of the $7.6 billion paid out to providers would have been paid out in error. He admits that there could be something wrong with the CMS data, or that providers selected his company’s product name by accident, but concedes that it’s possible attestation fraud is more common than we think.
I’m not telling you this to suggest that the Meaningful Use program is riddled with fraudulent activity. I’m doubful, in fact, that even a fraction of providers would dare incur the wrath of Medicare by making such a traceable error, much less consciously try to rip the incentive program off.
This does suggest, however, that more healthcare IT people should take a look at the CMS data and go over it themselves, especially EMR vendors. While there may not be a hailstorm of fraud going on, something may be seriously amiss in how CMS collects data or how providers report on their attestation. It’d definitely be good to get ahead of any pending troubles with CMS, for sure.