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EHR Innovation & Regulation: Friends or Foes?

Posted on August 16, 2017 I Written By

The following is a guest blog post by Stephen Dart, Sr. Director of Product Management at AdvancedMD.

Healthcare insiders often point out how far behind the industry is in taking advantage of technology when compared to industries like retail or finance.

Technology providers get their share of blame for not designing it with a user in mind, a common argument heard in relation to the Electronic Health Record (EHR) ill-fitting place in the physician’s workflow. What is not talked about much is the role regulations play in shaping the technology and its use in healthcare.

Designing for compliance

Regulations are present in every industry and serve an important function of protecting individuals’ privacy and rights. Healthcare is highly regulated compared to many other industries due to the sensitive nature of Protected Health Information.  There is a good deal of additional regulations regarding programs such as MACRA, dedicated to monitoring provider performance and reporting it back to the government for reimbursement. As such, technology for providers must be designed to capture and report such data.

For vendors like AdvancedMD, one of the challenges is not in designing software to address the regulations, but rather in designing it under the ever-evolving guidelines and shifting deadlines. At times, well-meaning standards also fail to function as intended because they are not enforced end-to-end.

As an example, Meaningful Use Stage 2 required the EHR to meet a standard for interfacing with state immunization registries. For certification, technology providers had to produce a standard-format file and transmit it to the state immunization registry. However, every state had its own set of requirements and most states would not accept the format designated as the certification requirement but instead have their own additional or different requirements.

Consider lab results as another example. The EHR has to meet the engineering standard for using a LOINC code when receiving lab results to enable the physician to report metrics for regulatory attestation. Unfortunately, labs are not held to the same standard, and if the lab does not send results using the LOINC code, the physician cannot get credit when reporting or has to manually add a code for it to be considered for meeting the performance metric.

Naturally, there is cost incurred to design compliance features for vendors. At AdvancedMD, it has a significant impact on our research and development (R&D) budget. It also influences the other two R&D categories that have a direct impact on the end-user experience – keeping the technology on the cutting edge and innovation.

Integrating compliance into workflow

If regulations require physicians to report more data, vendors have a choice of designing compliance features to either ask the physician to input that information manually or to capture it automatically for reporting.

At AdvancedMD, a lot of effort goes into automating the regulatory requirements and integrating the necessary data collection naturally into providers’ existing workflow. If software identifies that the physician has just written an electronic prescription, there is no reason to ask him or her to go into a separate system and attest manually to having done so. This regulatory tracker can be natively built into the platform.

All roads lead to innovation

There is a lot of pressure on everyone in healthcare today and the industry is undergoing constant changes. Patients expect more as they pay more under high-deductible plans.  They increasingly rely on wearables to tell them how well they sleep and how many steps they need to take as part of a larger trend of taking command of their own health. Doctors and patients alike will benefit from this data being integrated into patient records.  If this patient-captured data can be merged into the patient chart, machine learning and analytics algorithms can in some cases predict what an independent practice needs to do next. This next step could be to streamline administrative processes for outreach messaging and improve care through electronic follow-up, leading to increased profitability and better care. Importantly, the EHR, practice management and all other technologies designed for providers need to liberate them to focus on patient care, not distract from it.

All these advanced features are the next frontier in healthcare and require vendors to dedicate a lot more effort and budget to innovation. While healthcare technology can’t be expected to catch up with an Apple or Facebook overnight with regard to user experience, there is much that can be done to close the gap. The industry as a whole will get there much faster when regulations and technology align to advance that goal.

Incremental regulatory steps in areas where standards can be controlled and enforced cradle-to-the-grave will benefit all parties. Vendors can plan their engineering budgets in advance and design fully functional compliance features. The industry will benefit from designing with the user in mind, furthering the role regulations play in shaping technology and its use in healthcare. Ultimately, regulations should allow providers to focus on care and to engage more meaningfully with their patients, thus optimizing the EHR’s role in the physician’s workflow.

Rule to Change MU Reporting Period to 90 Days is Issued

Posted on April 10, 2015 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.

Today, CMS issued a new proposed rule for the Medicare and Medicaid EHR Incentive Programs to align Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3.

The modifications would allow providers to focus more closely on the advanced use of certified EHR technology to support health information exchange and quality improvement.

The new rule proposes a change in the reporting period for meaningful use from one year to 90 days in 2015.

Proposed Changes for EHR Incentive Programs
Together with the proposed Stage 3 notice of proposed rulemaking (NPRM) issued on March 20, 2015, the proposed rules align and merge the “stages” of meaningful use requirements.

The proposed rule changes the programs by:

  • Streamlining reporting by removing redundant, duplicative, and topped-out measures
  • Modifying patient action measures in Stage 2 objectives related to patient engagement
  • Aligning the EHR reporting period for eligible hospitals and CAHs with the full calendar year
  • Changing the EHR reporting period in 2015 to a 90-day period to accommodate modifications

Meaningful Use Is Dead?

Posted on January 29, 2015 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.

Over on EMR and HIPAA, I got the following passionate response on my post titled Meaningful Use Created A Big Need for Certified MAs that I thought many readers on this site would enjoy.

In the EP world, MU is dead. There are some larger groups, especially primary care still struggling to overcome the huge hurdles of MU2, but most I know have given up and running for the hills. There is a ginormous gap between what ONC is peddling in terms of numbers and real MU use.

This is good example of another hidden cost of trying to MU. We have some excellent MA’s, and I could not tell you which are and are not certified. Makes no difference. Sadly, CMS and ONC, do not realize that they are literally driving EPs from accepting Medicare patients, especially us specialists. And once we are gone, or severely limit new patients with Medicare, we are not coming back.

So the 17 times in 11 years fix for SGR, PQRS, VBM, MU, CPQ, ICD10, HIPAA, RAC audits, sequester cuts, etc. Its too much cost. clicking, paper work to take care of these patients. We actually had a serious discussion with our hospital about cutting back severely on doing Medicare total knees and hips next year due to all this. And the hospital initiated the conversation. So its not just us, even EHs are looking into this.

We all know that CMS and ONC want something, anything in terms of numbers to report anything to Congress, but this is the wrong way to do it. Again, everyone out there that is sitting in their cubicle Monday morning quarterbacking our care for these patients, will be very sad, very soon as we will just stop seeing them.

You can see by the numbers, if 250,000 EPs are taking the first MU hit this year, just wait until the rest give up. EPs can see that MU does not equate to better care, safer care, or more efficient care. We all may use an EHR, but could care less about attestations and audit risks and counting numerators/denominators forever. Again now that at least half the EPS are out, the rest will be right behind.

CMS and ONC need to realize that penalties NEVER work. Incentives like the heady days of MU1, got people to try EHR, but the costs are now piling up, big time. Everyone wants their piece of the pie. But as the incentives have gone away and the clerk like data entry has gone up, EPs have left the program. And are never, I mean never, coming back.

This provider makes an interesting assertion about meaningful use being dead. Do you think that MU is dead?

I thought this post’s timing was interesting given the announcement that CMS is changing the meaningful use stage 2 reporting period to 90 days. Correction…they intend to change it, but I think we all see that it’s going to happen. Just let the rule making process take it’s course.

Before this announcement, I would have largely agreed that meaningful use was pretty close to dead. I know some people have sifted through the meaningful use stage 2 attestations and have said it’s better than we thought, but I think those are the early birds and not the majority. With this announcement, I think the majority will take a much deeper look at taking on MU stage 2. If CMS can simplify some things, I could see many participating to get the incentive money, but to also avoid the penalties. Penalties aren’t the end all be all for doctors, but they represent a big chunk of money for many doctors.

I’d love to hear your thoughts. What are you seeing in the trenches?

Could Clinicians Create Better HIE Tools?

Posted on August 13, 2014 I Written By

The following is a guest blog post by Andy Oram.His post reminds me of when I asked “Is Full Healthcare Interoperability a Pipe Dream?

A tense and flustered discussion took place on Monday, August 11 during a routine meeting of the HIT Standards Committee Implementation Workgroup, a subcommittee set up by the Office of the National Coordinator (ONC), which takes responsibility for U.S. government efforts to support new IT initiatives in the health care field. The subject of their uncomfortable phone call was the interoperability of electronic health records (EHRs), the leading issue of health IT. A number of “user experience” reports from the field revealed that the situation is not good.

We have to look at the depth of the problem before hoping to shed light on a solution.

An interoperability showcase literally takes the center of the major health IT conference each year, HIMSS. When I have attended, they physically arranged their sessions around a large pavilion filled with booths and computer screens. But the material on display at the showcase is not the whiz-bang features and glossy displays found at most IT coventions (those appear on the exhibition floor at HIMSS), but just demonstrations of document exchange among EHR vendors.

The hoopla over interoperability at HIMSS suggests its importance to the health care industry. The ability to share coordination of care documents is the focus of current government incentives (Meaningful Use), anchoring Stage 2 and destined to be even more important (if Meaningful Use lasts) in Stage 3.

And for good reason: every time we see a specialist, or our parent moves from a hospital to a rehab facility, or our doctor even moves to another practice (an event that recently threw my wife’s medical records into exasperating limbo), we need record exchange. If we ever expect to track epidemics better or run analytics that can lower health case costs, interoperability will matter even more.

But take a look at extensive testing done by a team for the Journal of the American Medical Informatics Association, recently summarized in a posting by health IT expert Brian Ahier. When they dug into the documents being exchanged, researchers found that many vendors inserted the wrong codes for diagnoses or drugs, placed results in the wrong fields (leaving them inaccessible to recipients), and failed to include relevant data. You don’t have to be an XML programmer or standards expert to get the gist from a list of sample errors included with the study.

And that list covers only the problems found in the 19 organizations who showed enough politeness and concern for the public interest to submit samples–what about the many who ignored the researchers’ request?

A slightly different list of complaints came up at the HIT Standards Committee Implementation Workgroup meeting, although along similar lines. The participants in the call were concerned with errors, but also pointed out the woeful inadequacy of the EHR implementations in representing the complexities and variety of patient care. Some called for changes I find of questionable ethics (such as the ability to exclude certain information from the data exchange while leaving it in the doctor’s records) and complained that the documents exchanged were not easy for patients to read, a goal that was not part of the original requirements.

However, it’s worth pointing out that documents exchange would fall far short of true coordinated care, even if everything worked as the standards called for. Continuity of care documents, the most common format in current health information exchange, have only a superficial sliver of diagnoses, treatments, and other immediate concerns, but do not have space for patient histories. Data that patients can now collect, either through fitness devices or self-reporting, has no place to be recorded. This is why many health reformers call for adopting an entire new standard, FHIR, a suggestion recognized by the ONC as valid but postponed indefinitely because it’s such a big change. The failure to adopt current formats seems to become the justification for keeping on the same path.

Let’s take a step back. After all those standards, all those certifications, all those interoperability showcases, why does document exchange still fail?

The JAMIA article indicated that failure can be widely spread around. There are rarely villains in health care, only people pursuing business as usual when that is insufficient. Thus:

  • The Consolidated CDA standard itself could have been more precisely defined, indicating what to do for instance when values are missing from the record.

  • Certification tests can look deeper into documents, testing for instance that codes are recorded correctly. Although I don’t know why the interoperability showcase results don’t translate into real-world success, I would find it quite believable that vendors might focus on superficial goals (such as using the Direct protocols to exchange data) without determining whether that data is actually usable.

  • Meaningful Use requirements (already hundreds of pages long) could specify more details. One caller in the HIT Standards Committee session mentioned medication reconciliation as one such area.

The HIT Standards Committee agonized over whether to pursue broad goals, necessarily at a slow pace, or to seek a few achievable improvements in the process right away. In either case, what we have to look forward to is more meetings of committees, longer and more mind-numbing documents, heavier and heavier tests–infrastructure galore.

Meanwhile, the structure facilitating all this bureaucracy is crumbling. Many criticisms of Meaningful Use Stage 2 have been publicly aired–some during the HIT Standards Committee call–and Stage 3 now looks like a faint hope. Some journalists predict a doctor’s revolt. Instead of continuing on a path hated by everybody, including the people laying it out, maybe we need a new approach.

Software developers over the past couple decades have adopted a range of ways to involve the users of software in its design. Sometimes called agile or lean methodologies, these strategies roll out prototypes and even production systems for realistic testing. The strategies call for a whole retooling of the software development process, a change that would not come easily to slow-moving proprietary companies such as those dominating the EHR industry. But how would agile programming look in health care?

Instead of bringing a doctor in from time to time to explain what a clinical workflow looks like or to approve the screens put up by a product, clinicians would be actively designing the screens and the transitions between them as they work. They would discover what needs to be in front of a resident’s eyes as she enters the intensive care ward and what needs to be conveyed to the nurses’ station when an alarm goes off sixty feet away.

Clinicians can ensure that the information transferred is complete and holds value. They would not tolerate, as the products tested by the JAMIA team do, a document that reports a medication without including its dose, timing, and route of administration.

Not being software experts (for the most part), doctors can’t be expected to anticipate all problems, such as changes of data versions. They still need to work closely with standards experts and programmers.

It also should be mentioned that agile methods include rigorous testing, sometimes to the extent that programmers write tests before writing the code they are testing. So the process is by no means lax about programming errors and patient safety.

Finally, modern software teams maintain databases–often open to the users and even the general public–of reported errors. The health care field needs this kind of transparency. Clinicians need to be warned of possible problems with a software module.

What we’re talking about here is a design that creates a product intimately congruent with each site’s needs and workflow. The software is not imported into a clinical environment–much less imposed on one–but grows organically from it, as early developers of the VistA software at the Veterans Administration claimed to have done. Problems with document exchange would be caught immediately during such a process, and the programmers would work out a common format cooperatively–because that’s what the clinicians want them to do.

Meaningful Use Stage 2 Saves Doctors’ Time

Posted on July 21, 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 recently saw an older document from an EHR vendor that outlined some reasons why a doctor should take part in meaningful use stage 2. They suggested that meaningful use stage 2 would save our healthcare system money, save doctors’ and hospitals’ time and save lives.

All of these are noble goals worthy of consideration. If meaningful use could achieve this triple aim, then I think every doctor and healthcare organization would happily hop on this new triple aim. Let’s look at each and see how meaningful use stage 2 is doing with this meaningful use stage 2 triple aim:

Save Our Healthcare System Money – This one is interesting because many of the doctors I talk to are afraid that this is exactly what’s going to happen with meaningful use stage 2. They’re deeply afraid that meaningful use is really a way for the government to get access to a physician’s data so that they can pay the physician less. You have to remember that if we save the healthcare system money that means that some organization is going to get paid less.

While I think that the fear these doctors portray is a little overstated, it is true that the government wants the data to be able to pay people using that data. One could argue that a doctor doing good work has nothing to fear and it’s only the crooks that are over billing for their services are the ones that have to worry. Although, we know that data isn’t perfect and there will be collateral damage. I would just argue that the government doesn’t know what to even do with the data right now. So, we won’t see this change happen in the near future. We’ll see if they can achieve this goal long term.

Save Doctors’ and Hospitals’ Time – This suggestion is so ridiculous that I had to make it the title of the post. What I think is possible is that EHR adoption can save an organization time, but I think we need to be careful substituting EHR adoption with meaningful use. Sure, the EHR incentive money has pushed EHR adoption forward, but any time savings that has come from EHR adoption has been lost to the meaningful use check boxes that are required.

Save Lives – Once again, with this one you have to balance the idea of EHR adoption against meaningful use adoption. However, I am hopeful that things like clinical decision support, ePrescribing (ie. legible prescriptions) and a myriad of other things can save some people’s lives. This is hard to quantify, track and measure and so I don’t think we really know. I think there are anecdotal stories of times where care was improved and even lives saved because of something in an EHR. Certainly there’s also some evidence that EHRs can make care worse. Although, I think that is usually just as anecdotal as the lives saved. For now, I’d say this is a bit of a wash, but long term I like the potential of what EHRs can do to save lives. Although, I’m not sure that MU will be the basis for the lives saved.

How the Meaningful Use Stage 2 Timeline Affects Your Medical Practice

Posted on May 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.

The following is a guest blog post by Dana Deardorff.
D. Deardorff pic
The year of 2014 will be a year of great transition for most medical practices. You may be in the beginning stages of using EHR/EMR software, or you may be installing Medical Practice (MP) software for the first time. Perhaps you have been using a software program, but you’ve realized you need to upgrade to software that is certified for Meaningful Use. Or, if you’ve purchased certified software, you may need help proving the “meaningful use” of that software, meeting the requirements of Stage 2.

What does Stage 2 Meaningful Use mean for your medical practice? In addition to more recording and reporting measures, Stage 2 of Meaningful Use emphasizes care coordination and HIPAA-compliant engagement with patients.

Meaningful Use Stage Requirements

Stage 1

Beginning in 2011, the focus was on data capturing and sharing. Eligible providers and hospitals were required to show meaningful use of software by meeting a set number of objectives. These objectives were broken down into core objectives and menu set objectives. To be eligible for incentive payments, eligible providers and hospitals needed to prove they met the requirements for a 90-day period in the first year of participation and the entire second year of participation.

In a nutshell, during Stage 1, you are expected to:

  • Capture health information in a standardized electronic format
  • Use EHR/EMR or MP software to track clinical conditions
  • Report clinical quality measures and public health information
  • Begin engaging electronically with patients via HIPAA-compliant software

Your EHR/EMR or MP software vendor should be able to explain the practical applications of these requirements to you, training your staff how to prove and report compliance.

Stage 2

Once you’ve met the requirements for Stage 1 of Meaningful Use, you will need to widen your focus to include clinical processes.

In shorthand, during Stage 2, you will be expected to:

  • Engage in more rigorous health information exchange
  • Engage in e-prescribing
  • Deliver lab results electronically
  • Offer increased patient-controlled data and engagement with patient through electronic means
  • Transmit patient care summaries securely and compliantly through approved electronic methods

On a practical level, this means your office will need to use software that provides the following features, amongst others:

  • Patient engagement portal, including mobile device access to messages and records
  • Electronic recording of and communication of immunization records
  • E-prescribing capabilities and communication

You can begin meeting Meaningful Use Stage 2 requirements now (2014), assuming you have already met Meaningful Use Stage 1 requirements for the minimum time frame. (Ninety consecutive days one year, and an entire year the following year. Be sure to learn more about the possible Meaningful Use Stage 2 delay.) You will need to do the same with Meaningful Use Stage 2 before you can proceed to Stage 3.

Stage 3

Beginning in 2016, eligible providers and hospitals can take on a third set of requirements, focused on improving quality of care, safety and efficiency. The end goal is to provide improved health outcomes.

Meaningful Use Timeline

Eligible hospitals are held to a fiscal-year timeline, but eligible providers are held to the calendar year. This means you will need to ask your EHR/EMR or MP software vendor to help you figure out what your practice’s deadline is and how to meet it for each stage. A good vendor should be able to help you overcome obstacles like:

  • Employee resistance to using new software or processes
  • Software implementation and integration challenges
  • Office procedure modifications and work flow changes

Participation in Stage 1 opened in 2011. Practices that were early participants are now moving into Stage 2 here in 2014. Those who participate soon will be eligible for Stage 3 participation as soon as 2016, taking advantage of years of incentive payments.

Medical Practice Participation

According to the Centers for Medicare and Medicaid Services, more than 355,000 health care providers have received incentive payments for their participation in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (as of February 2014).  Over $13.6 billion has been paid out through the Medicare EHR Incentive Program thus far, and over $7.5 billion has been paid out through the Medicaid EHR Incentive Program.

Incentive payments aren’t the only reason to upgrade your MP software. Medicaid and Medicare eligible providers and hospitals that do not meet Meaningful Use requirements will be subjected to penalties starting in 2015. These penalties will come in the form of payment reductions, starting at one percent, capped at five percent for each year eligible providers don’t demonstrate meaningful use.

If you haven’t tackled this challenge yet, you’ll want to take it on now, before you miss out on the incentive payments and lose out on a percentage of your Medicaid and Medicare payments.With the right guidance, you’ll find that the upgrade and training will result in an improved experience for everyone, staff and patients alike.

About Dana Deardorff of MediPro

MediPro, Inc. is a full-service medical billing software company offering practice management (PM) software, electronic health records (EHR) and electronic medical records (EMR) from IMS and McKesson. As of April 2014, IMS is certified for Meaningful Use Stage 2, and McKesson, which is certified for Stage 1, will soon also be certified for Stage 2. (McKesson is certified for Stage 2 now, they just haven’t made the formal announcement).

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.

TrueMU – When You Realize the MU Standards Are Too Low

Posted on May 15, 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’ve been writing about meaningful use a lot lately and the path forward for meaningful use. You may want to check out my post about Meaningful Use Being On the Ropes as one example. Although, even more important is this post about how meaningful use missed the patient engagement opportunity. Plus, my next post on LinkedIn is going to be about blowing up meaningful use.

In some ways, people are looking at what I write as a call to dumb down meaningful use. I don’t think that’s what I’m trying to do at all. I don’t think we should lower our standards of what we expect to get from EHR software. I just think that we should make it more meaningful. That’s why the example of patient engagement is an important one. A slight tweak to the meaningful use requirements and we’d actually get more patient engagement out of meaningful use for the same price.

I saw a great example of what I want to achieve in something called TrueMU by HelioMetrics. I think this line from their page says a lot:

“Healthcare providers are achieving Meaningful Use and realizing that standards are lower than the goals that they would like to set for their organizations.”

One of the problems with setting an expectation for people is that they then often go into default mode and just try to meet the expectation. This is happening with meaningful use. People see that as the standard they need to meet to be updated in their use of technology. If this artificial bar weren’t there, many of them would strive for even higher results.

The great part is that we can recognize this and fix it. We can think more strategically in how we’re using technology and achieve well beyond what’s defined in meaningful use. We just have to strategically make this part of our thinking.

I actually saw a lot of this happening with ICD-10. Many organizations saw ICD-10 and didn’t just choose to organize around trying to meet the ICD-10 standard. Instead, they created entire clinical documentation improvement (CDI) programs that would improve the quality of their documentation regardless of which standard they chose to use (or in this case chose to delay).

I wonder what results organizations are seeing when they stop focusing so much on meaningful use and instead focus on ways technology and EHR software can improve their organizations. If you have a story like this, I’d love to hear it.

Meaningful Use is On the Ropes

Posted on May 9, 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.

We’re entering a really interesting and challenging time when it comes to meaningful use. We’ve often wrote about the inverse relationship between incentive and requirements that exists with meaningful use. As meaningful use stage 2 is now becoming a reality for many organizations and EHR vendors, the backlash against it is really starting to heat up.

If you don’t think this is the case, this slide from the HIT Policy Committee presentation says it a lot when it comes to organizations’ view of meaningful use stage 2.

Meaningful Use Stage 2 Attesatation - May 2014

For those that can’t believe what they’re reading, you’re reading it right. 4 hospitals have attested to meaningful use stage 2 and 50 providers as of May 1st. Certainly it’s still relatively early for meaningful use stage 2, but these numbers provide a stark contrast when you think about the early rush to get EHR incentive money during meaningful use stage 1.

This article by Healthcare IT News goes into many of the strains that were seen in the HIT Policy Committee. Sounded like the healthcare IT version of Real Housewives. However, the point they’re discussing are really important and people on both sides have some really strong opinions.

My favorite quote is this one in reply to the idea that we don’t need EHR certification at this point: “Deputy national coordinator Jacob Reider, MD, disagreed. Ongoing certification is required to give physicians and hospitals the security they need when purchasing products.”

Looks like he stole that line from CCHIT (see also this one). What security and assurance does EHR Certification provide the end user? The idea is just so terribly flawed. The only assurance and security someone feels buying a certified EHR is that they can get the EHR ID number off the ONC-CHPL when they apply for the EHR incentive money. The EHR certification can’t even certify EHR to a standard so that they can share health data. EHR Certification should go away.

I’m also a huge fan of the movement in that committee to simplify and strip out the complexity of meaningful use. I wish they’d strip it down to just interoperability. Then, the numbers above would change dramatically. Although, I’ve learned that the legislation won’t let them go that simple. For example, the legislation requires that they include quality measures.

No matter which way they go, I think meaningful use is in a tenuous situation. It’s indeed on the ropes. It hasn’t quite fallen to the mat yet, but it might soon if something dramatic doesn’t happen to simplify it.

Meaningful Use Payouts Hit $19 Billion

Posted on 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 @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

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.