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A Do-Not-Forget Checklist for EHR Switchers on the Hook for Meaningful Use

Posted on November 21, 2013 I Written By

The following is a guest post by Tom S. Lee, PhD, CEO and Founder at SA Ignite.

According to a recent survey by Black Book rankings, as many as 16 percent of ambulatory EHR users may become  EHR switchers within the next 12 months.  Large health systems such as Intermountain (a client of ours) and the Department of Defense have recently announced that they are switching EHRs or are currently evaluating a change. Many such organizations are planning to switch EHRs while continuing to meet increasingly difficult Stage 2 Meaningful Use (MU) requirements.  According to past National Coordinator  Dr. Farzad Mostashari, there will be no delay of MU Stage 2. That means your health IT road map may now include switching EHRs, managing Stage 2 attestations, and achieving ICD-10 compliance.

How do you switch jugglers while the number of balls in the air increases at the same time?

We have encountered a common set of issues and questions in our work with clients, discussions with prospects, and exchanges with thought leaders in the industry related to the EHR switching scenario, especially as it relates to Meaningful Use.  Here are some things to consider:

1. Assess and properly store data from your old EHR for future MU audits. A recent wave of MU audit notices has been sent by CMS to some of the country’s leading health systems. Each MU attestation is subject to audit 6 years after the attestation date.  With this in mind, be sure to pull out and securely and centrally store all supporting data from your old EHR before its license expires.  Get expert assistance if needed to understand how to build a comprehensive and solid audit trail.  One great place start is the guidance on audit documentation provided by CMS.

2. Optimize the timing of the EHR switch relative to government reporting timelines.  For example, in 2014 there is a one-time opportunity to report on only a calendar quarter’s worth of data for many eligible providers, rather than the entire year.  This modification to MU was originally made to accommodate delayed Stage 2 certifications by the EHR vendors.  However, it can also be leveraged by EHR switchers who can time the switch to happen within 2014 to benefit from a lower compliance bar while the massive impacts of switching EHRs are absorbed by the organization.

3. Plan to merge data across EHRs to meet MU reporting requirements.  Even with the 2014 calendar-quarter reporting reprieve, for many hospitals and eligible providers to achieve Meaningful Use in an EHR-switching year it’ll be necessary to stitch together Meaningful Use data across the old and new EHRs in order to meet many MU reporting requirements.  For example, this may be required simply to meet the minimum certified EHR usage threshold to be eligible for the MU program in that year.  Assume merging data will be necessary, prepare how to do so before your old EHR license expires, seek help, or do both. An interesting contingency we have seen is to drive eligible providers to “over perform” on their MU measures on the old EHR in anticipation that MU performance will drop at the outset of adapting to the new EHR.  This will increase the chances that providers’ total MU performance within a reporting period spanning both EHRs will end up above threshold.

4. Plan to be supporting two EHRs at the same time.  Although it is sometimes possible to do a “big bang” switchover to a new EHR across an entire organization, we often see that rollout plans for the new EHR are phased across specialty, location, or other sub-groups.  During those periods when the organization could be supporting two different EHRs, such as two ambulatory EHRs in different geographic regions, it is important to organize and align teams to not only handle the immediate demands of MU but also transition completely to supporting the new EHR.  For example, MU data reporting and attestation can be hard enough for just one ambulatory EHR, much less two.  It takes preparation well in advance of the EHR switch and government attestation deadlines to avoid 11th hour fire drills.

Is your organization juggling MU requirements while switching EHRs? If so, I’m sure that you’ve found there are additional considerations surrounding an EHR switch that are important to keep in mind. I’d love to hear your suggestions in the comments.

Meaningful Use Attestations With Faked Vendor Info?

Posted on April 17, 2013 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 @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

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.

Few Healthcare Pros Have Attested To Meaningful Use

Posted on February 25, 2013 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 @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

Despite all of the attention given to Meaningful Use, it seems that eligible healthcare professionals have been relatively slow to achieve compliance. A new report published in the New England Journal of Medicine concludes that just over 12 percent of EPs had attested to the Medicare portion of Meaningful Use as of May 2012, well into the life of the program.

The reasons for this relatively low uptake are complex, but clearly, the EMRs physicians are buying are part of the problem. As a piece in iHealthBeat notes, the National Center for Health Statistics recently found that only 27 percent of office-based physicians had EMRs capable of supporting 13 of the Stage 1 objectives for the MU program.  Since EPs have to meet 15 core objectives, plus five of 10 menu options, that leaves the remaining 73 percent of office-based physicians out in the cold.

To calculate uptake of Meaningful Use attestation for the NEJM, researchers with Brigham and Women’s Hospital looked at combined CMS data from April 2011 to May 2012, and GAO estimates of the number of eligible professionals in the U.S.

The researchers found that 12.2 percent of 509,328 eligible professionals had attested to the Medicare portion of the MU program as of May 2012, including 17.8 percent eligible PCPs and 9.8 percent of specialists. PCPs accounted for 44 percent of all Medicare Meaningful Use attestations, the researchers concluded.

Looked at state by state, the median Medicare attestation rate was 7.7 percent of eligible professionals, though rates varied from 1.9 percent in Alaska and 24.2 percent in North Dakota.

These statistics must not be very encouraging ones for CMS, particularly the leaders are ONC. And they certainly make one wonder whether the mass of doctors will end up facing penalties in 2015 rather than making sure they attest to Meaningful Use Stage 1. This should be a real eye-opener for policymakers.  As for doctors whose systems simply won’t make the grade, well, this has been called the year of the big EMR switch. I guess we may see even more switching than we expected.

Who Will Police EMRs and EHRs?

Posted on November 7, 2011 I Written By

Priya Ramachandran is a Maryland based freelance writer. In a former life, she wrote software code and managed Sarbanes Oxley related audits for IT departments. She now enjoys writing about healthcare, science and technology.

Amid all the dog-bites-man type health IT news, here are some not-so-positive EMR/EHR stories that have been reported:

– An EMR in Lifespan hospital group gave incorrect prescriptions to some 2000 patients. The article in the Providence Journal says that

The hospitals have placed calls to nearly all the affected patients, although not all have called back, Cooper said. Most patients reached had already obtained the correct medication because the error was noticed by someone at the hospital, or a pharmacist or doctor outside, she said. So far, Cooper said, there is no evidence that any- one was harmed.

Thank goodness for that.

– Incorrectly calculated MU thresholds (GE Centricity). I’m not going to rehash the story, but you can check out Neil Versel’s article in InformationWeek, the spirited discussion on my previous EMR and EHR blog post and John’s EMR and HIPAA blog post.

It might be just be my skewed viewpoint, but GE Centricity related issues are nowhere on par with people being prescribed the wrong prescription. In one case, a few practices may not be able to demonstrate Meaningful Use. Wrong medication could actually be life-threatening to you. So if I had to rank my problems, I’d rather be short by 44K than worry about my EMR inadvertently killing my patients off.

What we need is a governing body, similar to the National Transportation Safety Board, to police EMRs, says Paul Cerrato in a recent InformationWeek Healthcare article.

Cerrato writes:

“An NTSB-like organization for EHRs would at the very least provide a reporting mechanism to keep track of incidents and life-threatening consequences of misusing e-records. More importantly, it could police vendors and healthcare providers who repeatedly ignore these dangers.”

Cerrato goes on to say there are only 120 EHR-specific problems reported to the FDA over the last 18 years. That figure, if correct, to me shows:

  • EMR users don’t know how/where they can report EMR related errors or don’t expect any action to be taken – this certainly is credible, because from all quarters, it seems as if the focus is just to get the healthcare field into electronic data capture, not on whether the experience delivers any tangible and useful benefits
  • Maybe they’re willing to give EMRs a pass assuming the healthcare IT to be in infancy
  • They’re too overwhelmed with the EMRs’ capabilities/inabilities to really see what’s going on

For a national database of EMR problems to be truly relevant, here’s the information I would look for, on problems I’m facing:

  • How critical was the error? How many people did it affect, and in what ways – medically, financially?
  • How was it handled?
  • How common is it – are there others who’ve faced similar problems?
  • If the problem was not sorted, what raps on the fingers did the vendors face?

Read the article here.