Trying to Put the "Meaning" in Meaningful Use

High noon for federal health records program? 2015 will be a critical year for testing the system is an eye opening article.  Arthur Allen gives a critical analysis of the whole dilemma regarding the value of an Electronic Health Record (EHR) based on the present financial incentives.

The article explains the motivation of institutions to digitalize medical records, which primarily are two: money (potentially lost) and fear (of future penalties for not abiding by the complex rules the government has created).

Meaningful Use Objectives are defined in the chart below:

1. Improve quality, safety, efficiency, and reduce health disparities
2. Engage patients and family
3. Improve care coordination, population and public health
4. Maintain privacy and security of patient health information

Ultimately, it is hoped that meaningful use compliance will result in:

1. Better clinical outcomes
2. Improved population health outcomes
3. Increased transparency and efficiency
4. Empowered individuals
5. Robust research data on health systems

The intent of MU is good, but the reality is very different.  For one thing, "meaningful" depends on perspective.  That is, for a clinical user, meaningful is a different animal than it is for administrators, and for CMS, meaningful is a wholly different species.  Providers want usable data that supports direct patient care; they dislike having to capture endless streams of data for clinical irrelevancies.

So let's ask the following- since the bottom line is that everyone wants better care, what does a clinician find meaningful while providing that care:

1. Easy access to all relevant data in a recognizable format
2. Advisory alerts when appropriate
3. Clinical decision support
4. CPOE (computerized order entry system) that is universal and not totally provider driven- (Where have all the ward clerks gone?)
5. Insert your own here "xxx"

The government is looking for data to make political, cost, and cultural changes.  One unintended result is a new industry, a new unregulated "profession", medical scribe and that has certainly raised costs.  Along the same lines, CPOE has led to more tests, which equals more costs.

My suggestion is to read the article.  It does an excellent job of presenting the issues.  Ultimately, the solution is to create a national medical database that is easily accessible, secure, and agnostic as well as transparent to all EHRs, regardless of vendor or format.  With this database and a standardized CPOE, major benefits will be obtained.  Through the retrospect-o-scope, one sees that money could have been spent on this first; then the hospitals and providers would have clamored to be first to get an EHR that makes life easier.  As it is now, there is quite a mess to sort out with respect to interoperability and usability.

10 Things Medical Records Won't Tell You!

The Wall Street Journal published an article last week on the 10 things medical records won't tell you.  I have condensed the list, so you get the idea...

1. COST: The price tag is HUGE!
2. SHARING IMPORTANT CLINICAL INFORMATION between providers is a myth.  Even high-price tag enterprise level systems do not do this well, or cannot, especially between different hospitals and doctors.
3. DOCTORS HATE IT in general and pretty consistently, especially if forced to use it by their hospital, the government, or partners.
4. DOCTORS HAVE LESS TIME to spend with patients...because they have to fiddle with machines.
5. PRIVACY physicians may employ strangers such as scribes to manage there cumbersome EHR into the previously sacred and secure doctor-patient relationship.
6. ERRORS MAGNIFIED mistakes are easier to make; just hit the wrong key, or have a voice recognition system hear "no chest pain" instead of "known chest pain".
7. INFORMATION OVERLOAD TMI- too much information...sometimes, in fact most of the time, we just don't need or want to read "War & Peace" on every patient, and only a section of the total is needed in any clinical situation.  But the EHR commonly gives it all. No one, especially not clinicians, have the time to read it.
8. IDENTITY THEFT EHR's contain much of your demographic information--social security, payment, address, phone, work schedule, etc.  They are therefore a fertile ground for the thieves that prey on such things.
9. YOU BECOME A MARKETING STATISTIC your information will be marketed and sold e.g. to pharmaceutical companies, insurance companies, etc.
10. BIG BROTHER IS WATCHING the government can and will track the events that occur in medical interactions through EHRs.  The requirements and criteria for this sort of tracking are already in place.

Choose an Electronic Health Record that has thoroughly considered these complaints and actively deals with them.  Complaint #10- government policies and incentives is the biggest driver in turning to EHR.

The Appeal of a Failed EHR Incentive Audit

Interesting industry news update from EMR Advocate Jim Tate!

Appealing an Adverse EHR Incentive Audit

by Jim Tate
Twitter: @JimTate

The letter the hospital received said it all, “Based on our desk review of the supporting documentation furnished by the facility, we have determined that Hospital X has not met the meaningful use criteria………….Since your facility did not meet the meaningful use criteria, the EHR incentive payment will be recouped. You will receive a demand for  your total Medicare EHR incentive payment shortly from the EHR HITECH Incentive Payment Center.”
If that doesn’t get your attention, nothing else will. I wouldn’t want to be the one that received the email and have to be the one to show it to the hospital CEO or Board. I would imagine the CFO also would not be too pleased. It sounds so final, “did not meet the meaningful use criteria” and “will receive a demand for  your total Medicare EHR incentive payment shortly”. I guess that is why it is call Final Determination. It sounds like a death sentence. But it doesn’t have to be.
I was contacted by the hospital the week after they received notification they had failed their EHR incentive audit and to expect a demand letter for a seven figure recoupment. They only failed one meaningful use measure, and it wasn’t the infamous Security Risk Analysis. If I had been on board earlier I could have perhaps helped with documentation and clarification that would have met the expectations of the auditor. It is hard to go back and reconstruct what happened during the 2011 attestation. Staff changes and memory fades. By the time I knew anything the audit was failed and they were behind the eight ball. Not a good place to be.
I was raised in the red clay of Georgia and my Aunt Betty was always saying, “Thank my lucky stars”. It was always “lucky stars” this and “luck stars” that. Well, I can tell you, when I heard about the appeals process for failed EHR Incentive audits the first thing I thought was, “Thank my luck stars”. We were told we were the first hospital that took a failed audit decision to the appeal level. That’s right, we were #001. We worked through the appeal process by providing additional clarifying documentation and participating in a number of conference calls. I felt we received a fair and transparent hearing. Last week the hospital received an email stating, “….we are reversing the adverse audit determination”. Now that is one email I bet everyone was glad to share. Thank their lucky stars. I hope you have a few of those lucky stars in your sky if you need them.
Having to go the appeal route is a bad sign. It means you have not met expectations and without some additional viewpoints or personnel a reversal is unlikely. For all providers, and especially for hospitals where so much is at stake, if the EHR incentive audit process is not going smoothly you simply must seek expert guidance on the process and requirements.

Jim Tate is founder of EMR Advocate and a nationally recognized expert on certified EHR technology, meaningful use and the EHR Incentive audit process. Contact him at jimtate@emradvocate.com.

http://myemail.constantcontact.com/News-Digest-for-July-9--2013--The-Appeal-of-a-Failed-EHR-Incentive-Audit.html?soid=1102564327964&aid=I0X4P4Xt73U

Migration Issues

 



They are various types of migrations.  We are going to focus on data and system migrations- both have many complex issues.

• Data migration- the process of transferring data between storage types, formats or computer systems.
• System migration - the tasks involved when moving data and applications from current hardware to new hardware.

A new complexity has been added to the Electronic Health Record when practices, hospitals, departments and urgent cares either transition from paper to electronic and/or change products or vendors.  The reason for change include:

1. Adoption of an enterprise system that co-opts prior vendors.
2. Adopting a product for meaningful use funds and/or e-Prescribing.
3. General discontent for the present system.
4. Lack of support from prior vendor.
5. New products have "wow-factors" the save FTEs.
6. New ownership wants to consolidate their practice to one format, etc.

When purchasing a new Electronic Health record, it is incumbent that the "migration" to the new format is planned and supported by the vendor.  These include interfaces to capture old data, scanning solutions, 24/7 support, and a firm understanding by the new provider of the various complexities.

Avoid "re-inventing the wheel" by having these discussions with all parties to provide a smooth transition.  Do not suffer from inertia- the tendency of a body to maintain its state of rest unless acted upon by an external force.  Making changes to improve productivity, work-flow are always in your best interest.

Guest Blogger - Jim Tate: EHR Incentives Drop Dead Dates

Several times a week I am asked the same question by providers and vendors. The question takes different twists and turns, but it all gets down to one core concern. To put it in the crassest terms, here it is. “What is the absolutely last drop dead date an eligible professional can meet the CMS EHR Incentive Program requirements and not leave any money on the table?” OK, now that the question is clear, let’s answer it once and for all.

For Eligible Professionals there are two CMS programs, Medicare and Medicaid, which incentivize EHR use. An EP must select one of the programs for participation, and is allowed to switch programs once. Let’s take a look at Medicaid first. 2016 is the “Last year to initiate participation in the Medicaid EHR Incentive Program” and 2021 is the “Last year to receive Medicaid EHR Incentive Payment.”

To continue reading this blog visit: http://www.hitechanswers.net/ehr-incentives-drop-dead-dates/

Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and a partner in HITECH Answers. He is also author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1.

HITECH Answers - www.hitechanswers.net

To purchase Jim Tate's book "The Incentive Roadmap The Meaningful use of Certified Technology: Stage 1 visit:  http://www.hitechanswers.net/products-page/