Holidays are creeping up. I hate to come across like Scrooge, but I like Thanksgiving
better than Christmas: the pace isn’t as frenetic; expectations are lower; and the drama potential is less. A dry turkey causes less angst than a child or adult blubbering about some imagined slight attendant to getting anything less than the “perfect” gift. Plus Christmas is on Saturday and I’m not sure if I’ll get Friday off. Then again I spent the Friday after Thanksgiving waiting for Godot, so who knows.
I write a weekly column about HIT, investment banking, HIT services, or anything else that I think about. I’ve been doing it for 21/2 years and it helps keep me current as I scramble for topics or stop to examine the next bright, shiny thing in the road.
One recent continuing theme is how lightweight the Meaningful Use Stage 1 criteria are.
As a way of background, the American Recovery and Reinvestment Act of 2009 (ARRA) economic stimulus package aims at incenting more physicians (aka Eligible Providers - EP) to adopt electronic health records (EHR) in their practices. For office-based physicians, as a general rule, the Health Information Technology For Economic & Clinical Health Act (HITECH) portion of ARRA provides up to $44,000 in funding under Medicare and up to $65,000 in funding under Medicaid per EP over a five-year period for adopters of “certified” EHR products used in a “meaningful way.” Incentive payments begin in May, 2011. About 70% of the 5 year HITECH incentive payments will be disbursed (e.g., $30k of $44k) in the first 2 years, As an added stimulus for a physician to invest in a “certified” EHR, the HITECH provides that the Center for Medicare and Medicaid Services (CMS) will reduce its reimbursements to non-participating physicians by an amount of up to 5% of reimbursements otherwise due to a physician beginning in 2015. The Congressional Budget Office estimates that 90% of U.S. physicians will adopt EHRs by 2019 compared to less than the 10% current meaningful use adoption in the physician office setting if all goes as planned. Not so fast.
The original plans for features and functions of a “certified” EHR, and what constitutes “meaningful use” were gutted by the various lobbying groups. Virtually all of these lobbyists were interested only in trying to get HITECH incentive payments to their members as quickly as possible while ensuring that their members only needed to deliver the least amount of features and functionality possible for the most amount of money. Fair disclosure: I am a member of one of those groups, HIMMS. While it makes me almost tear up with pride to reflect on what HIMMS and others have done, I eventually remember that as taxpayer I am going to be paying for this so my chest-thumping stops, at least briefly.
We thought it might be useful to paste in Stage 1 (of 3) criteria and not just link to the Healthcare IT article. The "measure" part is what constitutes "meaningful use." Meeting the simple Stage 1 criteria could result in 70% of the incentive payments flowing to the EP before Phase 2 comes up. Stage 1 is the easy stuff: the hard parts (Stages 2 and 3) are theoretically more valuable to patients and are a risk of being inadequately funded and poorly serviced if EPs pick only a vendor proclaiming that its product is Stage 1 MU certified. That vendor may not be around for future stages and EPs will have no easy answer (see below as to one tried and true solution****)
From: “Meaningful use objectives: eligible professionals, hospitals”, July 13, 2010 | Healthcare IT News Staff
Core Set **
1) Objective: Record patient demographics (sex, race, ethnicity, date of birth, preferred language, and in the case of hospitals, date and preliminary cause of death in the event of mortality)
Measure: More than 50 percent of patients' demographic data recorded as structured data.
2) Objective: Record vital signs and chart changes (height, weight, blood pressure, body mass index, growth charts for children)
Measure: More than 50 percent of patients two years of age or older have height, weight and blood pressure recorded as structured data
3) Objective: Maintain up-to-date problem list of current and active diagnoses
Measure: More than 80 percent of patients have at least one entry as structured data
4) Objective: Maintain active medication allergy list
Measure: More than 80 percent of patients have at least one entry recorded as structured data.
5) Objective: Record smoking status for patients 13 years of age of older
Measure: More than 50 percent of patients 13 years if age of older have smoking status recorded as structured data
6) Objective: For individual professionals, provide patients with clinical summaries for each office visit; for hospitals, provide an electronic copy of hospital discharge instructions on request
Measure: Clinical summaries provided to patients for more than 50 percent of all office visits within three business days; more than 50 percent of all patients who are discharged from the inpatient department or emergency department of an eligible hospital or critical access hospital and who request an electronic copy of their discharge instructions are provided with it
7) Objective: On request, provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication list, medication allergies, and for hospitals, discharge summary and procedures)
Measure: More than 50 percent of requesting patients receive electronic copy within three business days
8) Objective: Generate and transmit permissible prescriptions electronically (does not apply to hospitals)
Measure: More than 40 percent are transmitted electronically using certified EHR technology
9) Objective: Computer provider order entry (CPOE) for medication orders
Measure: More than 30 percent of patients with at least one medication in their medication ordered through CPOE
10) Objective: Implement drug-drug and drug-allergy interaction checks
Measure: Functionality is enabled for these checks for the entire reporting period
11) Objective: Implement capability to electronically exchange key clinical information among providers and patient-authorized entities
Measure: Perform at least one test of EHR's capacity to electronically exchange information
12) Objective: Implement one clinical decision support rule and ability to track compliance with the rule
Measure: One clinical decision support rule implemented
13) Objective: Implement systems to protect privacy and security of patient data in the EHR
Measure: Conduct or review a security risk analysis, implement security updates as necessary and correct identified security deficiencies.
14) Objective: Report clinical quality measure to CMS or states
Measure: For 2011, provide aggregate numerator and denominator through attestation; for 2012, electronically submit measures
Menu Set ***
1) Objective: Implement drug formulary checks
Measure: Drug formulary check system is implemented and has access to at least one internal or external drug formulary for the entire reporting period
2) Objective: Incorporate clinical laboratory test results into EHRs as structured data
Measure: More than 40 percent of clinical laboratory test results whose results are in positive/negative or numerical format are incorporated into EHRs as structured data
3) Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach
Measure: Generate at least one listing of patients with specific condition
4) Objective: Use EHR technology to identify patient-specific education resources and provide to the patient as appropriate
Measure: More than 10 percent of patients are provided patient-specific education resources
5) Objective: Perform medical reconciliation between care settings
Measure: Medication reconciliation is performed for more than 50 percent of transitions of care
6) Objective: Provide summary of care record for patients referred or transitioned to another provider or setting
Measure: Summary of care record is provided for more than 50 percent of patient transitions or referrals
7) Objective: Submit electronic immunization data to immunization registries or immunization information systems
Measure: Perform at least one test of data submission and follow-up submission (where registries can accept electronic submission
8) Objective: Submit electronic syndromic surveillance data to public health agencies
Measure: Perform at least one test of data submission and follow-up submission (where public health agencies can accept electronic submission)
Additional choices for hospitals and critical access hospitals
9) Objective: Record advance directives for patients 65 years of age or older
Measure: More than 50 percent of patients 65 years of age or older gave an indication of an advance directive status record
10) Objective: Submit of electronic data on reportable laboratory results to public health agencies
Measure: Perform at least one test of data submission and follow-up submission (where public health agencies can accept electronic data)
Additional choices for eligible professionals
11) Objective: Send reminders to patients (per patient preference) for preventative and follow-up care.
Measure: More than 20 percent of patients 65 years of age or older or five years if age or younger are sent appropriate reminders
12) Objective: Provide patients with timely electronic access to their health information (including laboratory results, problem list, medication lists, medication allergies)
Measure: More than 10 percent of patients are provided electronic access to information within four days of it being updated in the EHR.
*This overview is meant to provide a reference tool indicating the key elements of meaningful use of health information technology. It does not provide sufficient information for providers to document and demonstrate meaningful use in order to obtain financial incentives from the Centers for Medicare and Medicaid Services. The regulations and filing requirements that must be fulfilled to qualify for the Health IT financial incentive program are detailed at www.cms.gov
** These objectives are to be achieved by all eligible professionals, hospitals, and critical access hospitals in order to qualify for incentive payments.
*** Eligible professionals, hospitals, and critical access hospitals may select any five choices from the menu set.
So the bulk of the HITECH incentives payments may be out the door before the value of fully certified EHRs to patients or EPs is realized.
**** Then we’ll have to have another incentive program for the lobbyists to gut to “realize the EHR dream.” Only in America, Land of Opportunity: Just like the Jets and the Sharks.
Jack Langworthy is a Managing Director at Covington Associates. He can be reached at 617-314-3950 or ibankerblog@covllc.com.
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