Monday, July 15, 2013

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

Computer Failures



Steps to take when your computers and/or Internet fails.
 
  1. Relax!
  2. Check the power source.
  3. Reboot the computer.
  4. Call the "Help Desk"????
  5. Have a back-up plan in place for charting, ordering, prescribing, and discharging patients.  Avoid re-inventing the wheel each time there is an outage.
  6. Install a back-up computer system with paper charts that can be scanned in later.
  7. If forced to input data in the Electronic record later, make sure to note the circumstance of late entries.
  8. Use the "Russian Space Utensil" aka a Pencil- works in zero gravity.
  9. Use a reliable back-up company to store all your data.
  10. If using your own server, have a contingency plan with redundancy.
  11. Cloud hosting should keep you protected.
  12. Hand write prescriptions- there is a pad laying around somewhere.
 
Bottom line - Plan Ahead - It is inevitable!!

Monday, July 1, 2013

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.

Monday, June 24, 2013

Continuing Medical Education



Staying current in the rapidly changing world of medical education, guidelines, protocols, and technological innovations is a continual challenge for most practitioners.  Having practiced since 1975, multiple reinventions of the wheel, standard of care, and now evidence-based medicine have all had their days in the sun. 

Evidence based medicine is now the buzzword for all education, but unfortunately, a lot of the data was not obtained in blinded, multi-center, prospective studies.  Much of the information is gleaned in meta-analysis format that uses flawed data as the source of their conclusions.

Treatment plans, protocols, and guidelines are far superior then in the past, but again contain "expert opinion" not necessarily the true facts.  What is left out in these plans is the "Art of Medicine".  An experienced clinician can take the best of the information and cater it to the individual patient.

How does one keep up?
  1. Develop a consistent plan that teaches you what is presently being taught in the residencies and medical schools.  Take this information and adapt it to the reality of your practice.
  2. Maintain Board Certification because it forces one to take an extensive review course in 8-9 years.
  3. If possible, work with others.  Isolation leads to "antique practices".
  4. have continuous access to the Internet at work- the former peripheral brain, or notebook in the pocket, with modern enhancement!
What to read/review?  These are what I use and have kept me pretty current.  These are not direct recommendations, but suggestions based on my specialty and practice.
  1. Emergency Medical Abstracts- reviews the literature.
  2. Risk Management Monthly- all the lawyers I know listen to it!
  3. Emergency Medicine: Reviews and Perspectives (EM:RAP)- current real-time podcast education with practicing professors.
  4. American Board of Emergency Medicine- Lifelong Learning and Self-Assessment (LLSA)
  5. Medscape

Monday, June 10, 2013

Factors that Affect Usability


One of the recurring themes of practitioners is that EHR programs lack of easy, intuitive usability that creates major work-flow issues.  These problems directly affect throughput, efficiency, and provider work satisfaction.  These factors ultimately lead to a 15-20% decrease in productivity, while forcing providers to add additional services like scribes and mid-level providers.  Bottom line:  costs are up, income is down, and generalized unhappiness is rampant.
 
The following tech blog analyzes the cost of poor usability on productivity.  Hope you find it informative.
 
 

Monday, June 3, 2013

CPOE Woes & Wishes!



There's an inevitable clash between the goals of a CPOE and the realities required for its clinical use.  Conceptually, the intent is for the provider to govern quality and cost through direct interaction with the machine, without interference.  But in reality, most providers need help when keying in the data.

CPOE, therefore, has multiple potential redeeming values.  How may of those actually come to fruition in real ED life?  Let's look...

In theory, on the positive side, we have:
  1. Legibility - No handwriting to decipher
  2. Decision Support - Cross-checking allergies, drug-drug interactions, dosing accuracy, order sets- enabling smoother initiation and real0time modification of protocols for common yet complex problems like Sepsis and ACS.
  3. Real-time Alerts - Identify issues such as improper dosing, safety in pregnancy... warnings should avoid pitfalls, and thereby aid, not hinder, patient flow.
  4. Accurate Recording - An honorable CPOE system should create and accurate record of events, as the system gathers the information input with timestamps of all communications, instructions, and actions.  This is good for quality measures, physician incentives and charge capture.
  5. Facilitates Read-through prior to submittal - Ideally, the provider would have the opportunity to consider all the orders as to their practical clinical and economic value, functioning not unlike the final checkout review before an placing an Amazon order.
  6. Efficiency - By eliminating duplication, unnecessary steps and personnel, CPOE has great potential to not only speed up processing of orders to nurses, pharmacy, lab, and x-ray, but also to remove vulnerable points in the process that add to risk.
  7. Auditing - Such tedious data tasks as verifying compliance various local and governmental requirement (think Core Values PQRS Clinical Support) would, again theoretically, support capture of data necessary to assure hospital financial incentives are received for compliance with various guidelines and regulations.
All these anticipated "pipe-dream" positives are balanced by the inevitable presence of unintended consequences.  CPOE, as many efforts in the realm of HIT, suffers from the old axiom:  "The Devil is in the Details".  We would think that when CPOE implementation successfully keeps it simple stupid (KISS), addressing the goals noted in the positives, it can in most cases, be easily utilized, and with success.  Yes, one would think...Right??

Actually what happens... First, there are the realities of HIT development in the modern world.  Often, the development team has difficulty retaining the focus and goal of more simple modules and projects.  As a result, the addition of new wish-lists from those beta-testing the rougher drafts, accumulate and grow.  In that way, many teams feel they can accomplish more than they actually can.  And just because the team's desire is there, that does not translate into superbly usable final product.  Commonly a development team can get lulled into trying to expand the conceptual boundaries of a module, like CPOE, and make an all-inclusive "problem solver".  But in reality, that extension of purpose often adds layers of complexity, and winds up impairing usability for the clinician.  Moreover, since CPOE implementations are often hospital-wide, there frequently arises a "one-size fits all" mentality, that encourages uniformity, instead of specialized diversity, and tries to cater to every specialty with the same structure.  Thus, many attempts to create facility wide CPOE have turned into cumbersome, user-unfriendly, mammoths that demand and the record voluminous transactions, failing to truly assist each individual physician user in a fashion appropriately specific to his or her needs.

Since the CPOE record is necessarily interwoven with the various documents of care, these extraneous elements become part of the chart, and in real-time, influence the tracking board, hence flow and efficiency with the equivalent of sludge in an engine.  Here are some design principles to help that not happen.
  1. CPOE design should optimally incorporate modules that are directed, not to the entire institution, but to the are setting in which it is used.
  2. The CPOE should be broken apart by interfaces to provide the needs of a specific department.  The Emergency department, or other care setting, usually has finite definable order needs 98% of the time.  Modular templates of care enable rapid development of a focused order plan.  When more are needed, the whole database can be searched.
  3. All CPOE modules should automatically facilitate input of test and other clinical data into the chart.  findings from x-ray reports, labs, consultations, vital signs, and other ordered assessments should be added automatically, and the provider should be notified when these are complete or when a significantly abnormal result is obtained.
  4. The hart should reflect significant orders that change status or care setting.  For example, a CPOE order to admit should be reflected in the chart, and a note to admit on the chart should appear in the CPOE screen.
  5. A good system will enable the clinician to choose a way of ordering common tests, and replicating that with simple screen or keyboard input (KISS approach).
  6. Ordered medications to be given while the patient is still in house should be clearly distinct, perhaps allotted a separate section from medications provided as outpatient prescriptions.  Failure to clearly make this distinction can add-significantly to complexity and potential confusion.  Care must be given not to complicate medication and/or prescription ordering to the extent that it affects patient flow.  Pediatric dosing should not need a time and resource consuming pharmacy consult.
  7. Recognizing that the ED probably uses only about 50-60 standard P.O and IV medications, some complex medications included in high-risk protocols, oxygen, need treatments, IV fluids, will keep the formulary selection simple.  The outpatient prescription writer is unlikely to need more than 50 common drugs that all staff physicians agree upon.
In conclusion:  A cohesive, concise CPOE would allow the provider to practice medicine in a manner that is interactive with the machine, but is not overburdened with data entry.  It would support the provider in making make intelligent choices that optimize patient care, and consciously utilize resources.

 
Work-flow Commentary by Donald Kamens, MD, FACEP
 
Some footnotes on physician-machine interaction, and how to get the most efficiency from the most expensive person:
  • Do not allow current absence of good usability to put a barrier between the physician and the machine.  That could happen if- for the sake of workflow- unskilled, non-clinical workers are inserted into the doctor-patient relationship.  Any barrier between the physician and the machine is a symptom of poor usability- PERIOD!
  • A well-functioning user interface should NEVER slow down a physician, but should speed him or her up.  Persistent work-flow impairments that result from new implementations should--after a customary break-in period-- be deemed to result from a poor interface.
  • It is important to analyze productivity in terms of evolution of the technological capacity of the providers.  The coming generations not only don't want other persons in the communication flow which they control (think Facebook, Twitter), but also see these as interfering obstructions in environment they are quite comfortable within.
  • Any attempt to insert individuals into the direct communication link between provider and ultimate enactor (nurse, lab tech, x-ray tech, etc.) is doomed.  These communications should be open and free... and CPOE is a good place to start.
  • An important element in all this is the cognitive environment.  That is, in what space does a provider best think?  There are two: 1) at the bedside, and 2) at the machine (eliminating the bathroom, that is!).  Optimally the CPOE device will be employed at the bedside.  Tidying up, communications, and arranging disposition are okay times for sitting down.  But the ED of the future, will need to eliminate the necessity of sitting down for long periods AFTER seeing the patient, to compose thoughts and write orders.  There is not, nor will there be, enough time for such digression from actually seeing and caring for patients with dynamic tools like CPOE that are best executed at the bedside.
  • Thus, the most efficient physician, will no longer sit down at a desk to compose his/her chart.  That will be completed (for the most part) while interviewing and examining the patient, and updated later as labs come in, treatments and re-assessments are done, and disposition is arranged.  The result will be a much more efficient (albeit more physically tired) physician, who can go from room to room easily.
  • If our children can walk though their lives with eyes glued to a small screen, and thumbs ablaze, we should expect no less from the next generation of docs.





Thursday, May 9, 2013

Are you losing 1% of your Medicare payments for not sending Electronic Prescriptions (eRx)?

Stop losing 1% of your Medicare payments for your Medicare patients by ePrescribing their medications during their office visits.  Good news- No registration is required.  You just need to report the following G-Code on the Medicare claim form - G8553 and submit a minimum of 25 eligible eRx events between January 1st and December 31st, 2013.  You can use the following criteria to determine your eligibility.

Becoming Incentive Eligible
  • Each visit must be accompanied by the eRx G-8553 indicating at least one prescription was electronically prescribed during the office visit.
  • Electronically generated refills not associated with a face-to-face visit DO NOT qualify as an eRx event.
  • Faxes do not qualify as an eRx event.
  • Submit a minimum of 25 eligible eRx events between January 1st and December 31st, 2013.
How to Start Reporting
  1. Bill one of the CPT or HCPCS codes noted in the eRx measure for eligible patient visits (Medicare Part B PFS patient face-to-face visit only qualify as an eligible patient).  *See qualifying CPT or HCPCS codes below.
  2. If you electronically prescribed during the eligible patient visit, report the following G8553 code on the Medicare claim form or via another applicable reporting method.
*Qualifying CPT or HCPCS codes to be associated with the G8553: 90791, 90792, 90832, 90834, 90837, 90839, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99304, 99305, 99306, 99307, 99308, 99309, 99310, 99315, 99316, 99324, 99325, 99326, 99327, 99328, 99334, 99335, 99336, 99337, 99341, 99342, 99343, 99344, 99345, 99347, 99348, 99349, 99350, G0101, G0108, G0109

2013 eRx Payment Adjustment
Individual eligible professionals and group practices participating in the eRx Group Practice Reporting Option (GPRO) who are not successful electronic prescribers will be subject to a 1.5% payment adjustment on their Medicare Part B services provided January 1, 2013 through December 31, 2013