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The Meaningful Use Revolution

Posted on May 29, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Meaningful Use change is afoot in the world of EHR software. Many doctors, hospitals and EHR vendors were set up to step away from meaningful use stage 2. Many would have filed for an exception, others would have opted out of Medicare, and others would have just taken the penalties on the chin. It wouldn’t have been pretty and the people at CMS/ONC/HHS realized this was happening and had to do something to avoid the meaningful use stage 2 fall out. It wouldn’t have looked good to have billions of dollars of EHR incentive money sitting on the table with no one wanting it.

CMS decided to cover this wound with a bandaid fix that essentially delays meaningful use stage 2. There are still a lot of details of the proposed rule that are unclear. For example, can anyone attest to meaningful use stage 1 or is that option only available to those EHR vendors who aren’t ready for meaningful use stage 2? I’ve sent that question to CMS, but still haven’t gotten an answer.

Can you imagine the fallout if this is indeed the case? Basically they’d be saying, “All of you EHR vendors and organizations that were good and stayed up with the latest regulations are going to have to do more work and attest to the stricter MU2 criteria while we reward those EHR vendors and organizations that weren’t ready for MU2 with a simpler option.” Can you imagine the backlash that would occur if this is indeed what they decide to do? For that reason alone, I can’t imagine them keeping it that way. I think they have to just open up all the stages/certifications to anyone and everyone regardless of your EHR vendor’s readiness for MU2. (Note: I haven’t dug in to see if this is really a viable option or if a 2014 Certified EHR required changes to the software which make it so it can’t do both MU2 and MU1, but I think it should work out fine. For example, CQMs are tied to certification year and not MU stage. Update: Lynn Scheps from SRSSoft sent me the following update “Prior to the publication of the proposed rule, 2014 CEHRT was required for everyone who wanted to earn an incentive in 2014, so part of the certification requirements was that the EHR could be used for stage 1 or stage 2.”)

What’s even more important is that this is really just the start of the meaningful use revolution. I’ve pointed out my article to “blow up meaningful use” a few times before and that message is starting to be shared by other healthcare IT influencers. For example, the title of this post came from a post by EHR certification and Meaningful Use expert, Jim Tate’s post “You Say You Want a Meaningful Use Revolution” which was a great follow up to his “Meaningful Use Zombie Land” post.

It has become really clear that there’s a lot of confusion afoot. The thing people want most from government regulation is clarity and ICD-10 and now meaningful use are suffering from a lack of clarity. John Halamka summarizes this issue really well:

at some point we need to recognize that layering fixes on top of existing Meaningful Use regulation, some of which was written by CMS and some of which was written by ONC creates too much complexity. I have direct access to the authors of the regulations and email them on a daily basis. It’s getting to the point that even the authors cannot answer questions about the regulations because there are too many layers. I realize that we are reaching the end of the stimulus dollars, but as we head into Stage 3, I wonder if we can radically simplify the program, focusing on a few key policy goals such as interoperability, eliminating most of the existing certification requirements, and giving very clear direction to hospitals and professionals as to what must be done when.

I’m glad to see that John Halamka and myself are on the same page. We need to simplify meaningful use and focus on interoperability. That’s a simple and clear message that providers will understand. I was excited that EHR vendor athenahealth offered a similar view in their post “We Should Be Pushing Interoperability Boundaries, Not EHR Certification Timelines.”

Jim Tate has a good call to action to those who care about what’s happening with meaningful use. As of last night, only 8 comments had been made during the public comment period for the meaningful use stage 2 delay NPRM. You can submit your comments on the rule incredibly easy at the following link: http://www.regulations.gov/#!documentDetail;D=CMS-2014-0064-0002 I’ll be taking this post and my “blowing up meaningful use” and modifying them as my comments. I hope you’ll take the time and share your thoughts on the delay and the future of meaningful use.

Meaningful Use Stage 2 Delayed Until 2015 (Unless You Don’t Want to Wait)

Posted on May 20, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Big news coming out of HHS today, CMS issued a proposed rule that changes the EHR certification requirements, firms up the meaningful use stage 3 delay that was announced previously, and most importantly delays the meaningful use stage 2 requirement until 2015. I guess one could argue that it’s not a delay since you can still attest to MU stage 2 in 2014 if you’d like (some already have), but for practical purposes this is a delay in the enforcement of meaningful use stage 2 for many organizations.

It looks like CMS and ONC was listening to the backlash against meaningful use stage 2 and the potential fallout. This isn’t quite blowing up meaningful use, but it’s a step in that direction. Here’s the chart that ONC put out that shows the new timelines:
New Meaningful Use and EHR Certification Timelines - Meaningful Use Stage 2 Delay

It’s worth noting that this is just a proposed rule, but there were usually very few drastic changes between proposed rules and final rules in the past. Sure, there could be a few tweaks, but I bet this goes into place essentially as it stands.

This will be a relief to hundreds of EHR vendors that are behind on becoming 2014 Certified. I expect most will continue with their 2014 Certified plans, but many of their users will likely opt to stick with the simpler meaningful use stage 1 objectives and measures. What’s not clear to me is if the attestation process will stay the same (ie. self attestation in MU stage 1) or not. I’ve asked HHS and will update the post (see update at the bottom of the post) once I hear from them.

What do you think of these changes? What impact will this have on you and your organization?

Here’s another email that CMS sent out:

CMS and ONC Release NPRM Allowing CEHRT Flexibility and Extending Stage 2

Today, CMS and ONC released a notice of proposed rulemaking (NPRM) that would allow providers participating in the EHR Incentive Programs to use the 2011 Edition of certified electronic health record technology (CEHRT) for calendar and fiscal year 2014.

The NPRM will grant flexibility to providers who are experiencing difficulties fully implementing 2014 Edition CEHRT to attest this year. The proposed rule would allow providers to use EHRs that have been certified under the 2011 Edition, a combination of the 2011 and 2014 Editions, or the 2014 Edition.

Beginning in 2015, all eligible providers would be required to report using 2014 Edition CEHRT.

2014 Participation Options
Under this proposal, valid only for the 2014 reporting year, providers would be able to use 2011 Edition CEHRT for either Stage 1 or Stage 2, would have the option to attest to the 2013 definition of meaningful use core and menu objectives, and use the 2013 definition CQMs.

Providers currently working on Stage 1 in 2014 would be able to demonstrate:

  • Stage 1 (2013 Definition) using 2011 Edition CEHRT, or using a combination of 2011 and 2014 Edition CEHRT; or
  • Stage 1 (2014+ Definition) using 2014 Edition CEHRT.

Providers currently working on Stage 2 in 2014 would be able to demonstrate:

  • Stage 1 (2013 Definition) using 2011 Edition CEHRT, or using a combination of 2011 and 2014 Edition CEHRT;
  • Stage 1 (2014+ Definition) using 2014 Edition CEHRT; or
  • Stage 2 (2014+ Definition) using 2014 Edition CEHRT.

UPDATE: Here’s the response I got from CMS about the reporting periods:

Reporting periods are not changing.

For 2014 Only
Because all providers must upgrade or adopt newly certified EHRs in 2014, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month (or 90-day) EHR reporting period in 2014:

Medicare eligible professionals beyond their first year of meaningful use must select a three-month reporting period fixed to the quarter of the calendar year for eligible professionals. Providers must attest to these reporting periods no later than February 28, 2015 at 12 am ET.

Medicare eligible professionals in their first year of meaningful use may select any 90 day reporting period.

Medicaid eligible professionals can select any 90-day reporting period that falls within the 2014 calendar year.

EHR Post Acquisition, 2014 Certified, ICD-10 and the Amazing Charts Future with John Squire, President and COO

Posted on April 30, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I had the chance to sit down and interview John Squire, President and COO of Amazing Charts. I was interested to learn about the transition Amazing Charts has experienced after being purchased by Pri-Med and the departure of Amazing Charts Founder, Jonathan Bertman. Plus, I wanted to learn why Amazing Charts wasn’t yet 2014 Certified and their plans to make it a reality. We also talk about the value of meaningful use and the ICD-10 delay. Then, we wrap up with a look at where Amazing Charts is headed in the future.

Check out EHR videos for all of my EHR and Healthcare IT interview videos and be sure to subscribe to the Healthcare Scene youtube channel.