Welcome to EMR and EHR

EMR Stimulus Myth #2: “I have a CCHIT certified EHR so I am good to go for meaningful use”

It is likely that CCHIT will be one of the accredited certification body under the EHR incentive program. HOWEVER, given that there is no formal EHR certification program available from ONC yet, no existing certification, including from CCHIT, means much towards meaningful use.

As I covered in EMR Stimulus Myth #1, even if you implement an ONC certified EHR (when the certification program is finalized), it does not get you to meaningful use. Providers have to meaningfully use the certified EHR and report on defined clinical qualify measures over a set reporting period to meet meaningful use. Given that no EHR today is certified, how should you proceed with EHR purchase decision?

If you are making the decision to buy an EHR now, YOU MUST VETT THE EHR VENDOR prior to purchase so that you minimize the risk of buying the wrong EHR. Vetting should include the assessment of EHR against the current definition of certified EHR from ONC plus the match of EHR to the makeup of your organization. Of course, any promises of future from the vendor should be baked into the contract you are executing with them. EHR needs of a solo or a small practice group is much different than a larger group/clinic/hospital.

People often find real value in getting the assistance of a meaningful use expert for this assessment. The pitfalls avoided make it worth the investment. You don’t want to purchase and implement an EHR and then find out your EHR won’t meet the meaningful use requirements. That would be a depressing realization.

About David:
David Lee is the Principal at eRECORDS, Inc.  David has provided successful healthcare technology, CRM and financial product consultancy for the past two decades and most recently, guiding healthcare organizations to “meaningful use”.   You can reach David at david.lee@eRecords.com or visit www.eRecords.com.

I rated the HISTalk party at HIMSS as the Wildest party in my Best and Worst of HIMSS post on EMR and HIPAA. No doubt the HISTalk party was an event to remember with a lot of really influential people there. However, probably the best part of the night for me was this Meaningful Use rap by Mr. HIT. I can’t imagine how much he practiced this since he did this 2.5 minute Meaningful Use rap flawlessly with no notes. That’s impressive. If you read this blog regularly, I think you’ll enjoy it too:

I always love when people are interested in doing guest posts on this site. This is going to be the first in a series of blog posts about some of the misinformation that’s out there about the EMR stimulus, certified EHR, and meaningful use. I hope you enjoy!

My name is David Lee and I am a principal of a healthcare technology consulting firm called eRECORDS, Inc. Day in and day out, I talk to independent physicians, practice group owner and community clinics about HITECH Act and “meaningful use”.  My company takes pride in providing accurate and up to date information to the physicians and clinics so that they can make intelligent decisions about meaningful use.

I am continually amazed at the misinformation surrounding meaningful use and the one that scares me more than anything else is ”My EHR vendor told me that if I implement their certified EHR, I will meet the meaningful use requirements and collect EHR incentive payments.”

It is true that a “certified EHR”  is a key component to meeting the requirements of “meaningful use”.  However, a “certified EHR” is not the silver bullet to meaningful use.  Let me share some important facts:

• Fact: Although the definition and requirement of a certified EHR has been released by the ONC, there is no organization recognized or approved by the CMS to certify EHR to meet the requirements of the meaningful use criteria.
• Fact: Even if your organization implements a certified EHR (when certification bodies are appointed and your EHR vendor passes the certification), this does not get you to meaningful use..
• Fact: Meeting meaningful use requirements involve qualified providers meaningfully using a certified EHR and reporting clinical quality measurements.  The key words are “meaningfully using” and “reporting” not simply having a certified EHR.

Don’t be fooled by any vendor claiming that they are certified or promising they will be certified.  Although some EHR vendors are better prepared to meet the certification when available, not a single vendor today is certified for the EHR incentive payment program.  More importantly, you cannot meet the requirements of “meaningful use” by simply implementing a certified EHR. It is vital that you find experts who can provide accurate assessment and plan for “meaningful use”.

This is a continuing series where David will share and hope to clear the myths about HITECH Act and “meaningful use”.

About David:
David Lee is the Principal at eRECORDS, Inc.  David has provided successful healthcare technology, CRM and financial product consultancy for the past two decades and most recently, guiding healthcare organizations to “meaningful use”.   You can reach David at david.lee@eRecords.com or visit www.eRecords.com.

Anyone that works in Healthcare IT knows who John Halamka is and so of course I was interested in his post of his top 10 impressions after HIMSS. It’s an interesting list and I think he does a pretty good job of looking at things from a very high level. Here they are as posted on his blog:

1. Meaningful Use is everywhere. Vendors are promising EHRs, modules, appliances, and services to help clinicians achieve it. I had dinner on Monday night in a small Indian vegetarian restaurant. Sitting next to me were 3 engineers from Bangalore who were arguing about the details of Meaningful Use in between bites of vegetable curry. I could not escape Meaningful Use anywhere!

2. Certification is everywhere. It’s particularly ironic that many vendors claimed their systems were certified, even though the certification NPRM was just released today, making compliance with the new certification process in time for HIMSS impossible.

3. Cloud computing, Software as a Service and ASP models are popular tactics to accelerate EHR rollouts. There are still lingering concerns about how to ensure privacy in a cloud environment.

4. Several firms such as Intersystems, Axolotol, and Medicity are offering HIE platforms that include many of the standards noted in the IFR. The marketplace for HIE products is just emerging and it’s hard to predict who will become the market leader.

5. The Continuity of Care Document is gaining traction. I found many vendors supporting CCD exports from their EHRs. A company called M*Modal , has developed natural language processing technology that captures dictated content in its original context (ontology-driven
rules) as a CDA document.

6. Consultants abound. It’s clear that Regional Extension Centers and Health Information Exchanges will require expertise and staffing from professional firms. They all had large booths at HIMSS.

7. 30,000 people attended, including 10,000 I did not recognize (just kidding). It’s clear to me that many IT professionals, even those with limited healthcare domain expertise, attended HIMSS to better understand how they could participate in the euphoria of HITECH stimulus dollars.

8. Self service kiosks for patient identification and self-registration are now mainstream. Just as we print our airline boarding passes, we can now use credit cards or biometrics to check into ambulatory care appointments and automatically settle all co-pay balances.

9. Image exchange in the cloud is being offered by several vendors. As I mentioned in Monday’s blog, Symantec announced an appliance for small clinician offices that cloud enables all imaging modalities using a facebook-like social networking invitation to share/view images.

10. PHRs and patient engagement are becoming more mainstream. Google and Microsoft continue to innovate in the non-tethered PHR marketplace.

George Hripcsak, MD, the co-chair of the workgroup and a biomedical informatics professor at Columbia University, said the following during a Health IT advisory group meeting as reported by Healthcare IT News:

None would be dropped in the area of privacy and security. “You can do things that are easy to measure, and you want to make sure it’s done for some but not measures that force more manual labor,” Hripcsak said.

I think this is a very very good point. The idea that “meaningful use” will end up being satisfied thanks to more manual labor is sad to consider, but a very possible outcome. I’ve already heard people talking about how they’re going to satisfy the meaningful use requirements and many of the reporting components require a lot of manual footwork.

One thing is certain from my point of view. The meaningful use bar as it is now will be a major hindrance to doctors interested in finally implementing an EMR for stimulus money. I’m not sure if they’ll find this out before implementing or after they’ve implemented. Either way, it will not achieve the desired outcomes.

If you are interested, you can listen to the HIT Policy Committee meeting tomorrow, at 10 AM Eastern. Find all the details of the webcast here.

I was reading an online forum today and was blown away by something someone said about meaningful use:

The “Meaningful Use” stages can only be met if the systems are easy to use and the data is accessible in a timely matter. This will mean that EHR/EMR systems will need in-depth analytical capabilities or the information accessible by Business Intelligence systems that understand healthcare.

Healthcare organizations that understand this will be able to tap into the upwards of millions of dollars set aside by the government in the stimulus package.

Ok, I can’t really knock the fact that EMR software needs to be easy to use. I think they probably meant to say that the EMR vendor needs to make it easy to enter the data required to show “meaningful use.” This seems like a given that every EMR vendor that wants their users to get EMR stimulus money should consider. Sadly, I think they’re likely to find this a VERY difficult task.

Although, what bothers me about this quote is the idea that you need some sort of in-depth analytical capabilities or some sort of BI (Business Intelligence) system to show meaningful use. Take a quick look at this simple meaningful use matrix or the list of 25 meaningful use objectives. Which of the criteria requires this in depth analysis and BI? None of them. At most they’re a pretty simple report.

Now I’m not saying that meeting the requirements of meaningful use is easy. However, the work around meaningful use is around the entry of the data and ensuring that you’re entering the data for all 25 meaningful use objectives. The hard part isn’t accessing the data once it’s in the EMR.

I just found this really nice interview by InformationWeek with David Blumenthal, Health IT Czar. Here are a few snippets of what David Blumenthal said with my own commentary in italics.

Congress set very ambitious goals for the HITECH legislation. The concept of meaningful use is novel, and a very powerful and important concept. The process of defining meaningful use has gone through many months, through many public hearings.

I think David Blumenthal realizes that meaningful use is going to be a major problem for many doctors offices. I think we’re going to hear him blaming Congress for the “ambitious” HITECH legislation which has his hands tied. It probably does, but it’s too bad he can’t just say it that way if it is the case.

The Office of National Coordinator is still committed to developing the Nationwide Health Information Network. Many of our federal colleagues and quite a number of larger healthcare organizations are on the verge of using NHIN as it was originally conceived and configured for their own purposes, and we’re continuing to invest in it.

At its last meeting the HIT Policy Committee adopted recommendations that they have not yet formally transmitted to me to encourage the development of a more flexible, adaptable, less complicated method of health information exchange than the Nationwide Health Information Network. And that’s something that we’ll be studying.

I think this is a good move. This national network in its current state just doesn’t seem like it’s going to have much affect on small doctors offices, which last I checked make up a large part of our healthcare system. I think in politics they call this move taking it to the people.

InformationWeek: Once you get clinicians using e-medical records, who pays to maintain the exchange infrastructure?

Blumenthal: It’s a short-term issue. Long term it’s going to become an expectation on the part of the clinician and patient that information is going to be exchanged. And I think it will become a cost of doing business in the healthcare sector just as physicians and nurses consider it a cost of doing business to buy stethoscopes and run an office.

Doctors will hate to hear this quote. Although, they shouldn’t be too upset. In reality, they’ll be passing this cost on to the consumers. Now how we get to the point Blumenthal talks about is beyond me. That’s a huge gap to cross.

InformationWeek: Will the Certification Commission for Heath IT–CCHIT– remain the organization doing these certifications, or will there be others?

Blumenthal: We’ll have to see what the regulation actually is and see where CCHIT fits in. CCHIT is clearly going to have the option to participate in certification going forward, but I can’t tell you what role exactly it will play.

Translation: I don’t care about CCHIT. If they want to participate great, but I’m playing no favorites here.

These webcasts have been popping up all over the place. It’s really quite amazing. You could make it a full time career just attending various webcasts on the EMR stimulus and meaningful use. Well, I’ve seen a ton of them, but this one by Modern Healthcare looked pretty interesting with a variety of people including the Director of CMS Office of E-Health Standards and Services. You can read more about it here and I’ll put some of the details of the meaningful use regulations webcast below:

Wednesday, Jan. 27, 2010
10 a.m. Central Time
FREE REGISTRATION*

About this Webcast

The federal government is offering as much as $34 billion in financial assistance to healthcare providers that buy, implement and use information technology in a manner consistent with the way the government wants it to be used. The government explained what it wants in nearly 700 pages of proposed regulations issued earlier this month.

In this webcast moderated by Modern Healthcare Information Technology Reporter Joseph Conn, four healthcare IT experts will break down those regulations and help attendees:
Identify the key sections of the regulations
Understand the impact of the regulations on hospitals, health systems and physician practices
Teach providers strategies to qualify for federal funding
Featured Speakers

J. Michael Kramer, M.D.
Chief Medical Information Officer
Trinity Health
Novi, Mich.

David Seaman
CEO
Pronger Smith Medical Care
Blue Island, Ill.

Tony Trenkle
Director
CMS Office of E-Health Standards and Services
Washington

Paul Tang, M.D.
Chief Medical Information Officer
Palo Alto Medical Foundation
Palo Alto, CA

P.S. If you’re able to attend this or any other webcast and want to do a guest post on what was said at the webcast, feel free to contact me on the EMR and EHR contact us page.

Lots of people have been putting out lots of simplified versions of Meaningful Use. The latest I found is a “simple” 12 page PDF file that has a matrix of the various stage 1 meaningful use objectives and the criteria for Eligible Professionals and the criteria for Hospitals. I’ll keep searching the net to compile the various resources out there. Then, I’ll decide if it’s worth making my own or if I’ll just continue to compile others and provide commentary on the criteria themselves. What do you think?

Healthcare IT News has an article that did a good job listing the 25 meaningful use objectives in a simple to read format. Much better than the 692 pages of Meaningful Use and Certified EHR information HHS put out. Here’s the 25 Meaningful Use Objectives you’ll need to meet to get the EMR stimulus money:

[1] Objective: Use CPOE
Measure: CPOE is used for at least 80 percent of all orders

[2] Objective: Implement drug-drug, drug-allergy, drug- formulary checks
Measure: The EP has enabled this functionality

[3] Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data.

[4] Objective: Generate and transmit permissible prescriptions electronically (eRx).
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

[5] Objective: Maintain active medication list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data.

[6] Objective: Maintain active medication allergy list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient has no medication allergies) recorded as structured data.

[7] Objective: Record demographics.
Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data

[8] Objective: Record and chart changes in vital signs.
Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20.

[9] Objective: Record smoking status for patients 13 years old or older
Measure: At least 80 percent of all unique patients 13 years old or older seen by the EP “smoking status” recorded

[10] Objective: Incorporate clinical lab-test results into EHR as structured data.
Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data.

[11] Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach.
Measure: Generate at least one report listing patients of the EP with a specific condition.

[12] Objective: Report ambulatory quality measures to CMS or the States.
Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures are discussed in section II.A.3. of this proposed rule.

[13] Objective: Send reminders to patients per patient preference for preventive/ follow-up care
Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over

[14] Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules
Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3.

[15] Objective: Check insurance eligibility electronically from public and private payers
Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP

[16] Objective: Submit claims electronically to public and private payers.
Measure: At least 80 percent of all claims filed electronically by the EP.

[17] Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request
Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours.

[18] Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies)
Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information

[19] Objective: Provide clinical summaries to patients for each office visit.
Measure: Clinical summaries provided to patients for at least 80 percent of all office visits.

[20] Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
Measure: Performed at least one test of certified EHR technology’s capacity to electronically exchange key clinical information.

[21] Objective: Perform medication reconciliation at relevant encounters and each transition of care.
Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care.

[22] Objective: Provide summary care record for each transition of care and referral.
Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals.

[23] Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted.
Measure: Performed at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries.

[24] Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
Measure: Performed at least one test of certified EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically).

[25] Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities.
Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1) and implement security updates as necessary.