This is the next post in my series of Do’s and Don’ts Healthcare IT. As we all know, some of our most important citizens live in rural settings, small cities, the countryside, or remote areas. These areas have smaller populations and less direct access to vital healthcare resources. In the past 15 years or so we’ve made some great strides in remotely accessible healthcare; these offerings, called telemedical tools, provide important clinical care at a distance. Here are some do’s and don’ts of telemedicine:
What do’s and don’ts would you add to a telemedicine strategy? Drop me a comment below.
I recently wrote, in Do’s and Don’ts of hospital health IT, that you shouldn’t make long-term decisions on mobile app platforms like iOS and Android because the mobile world is still quite young and the war between Apple, Microsoft, and Google is nowhere near being resolved. A couple of readers, in the comments section (thanks Anne and DDS), asked me to elaborate mobile and mHealth strategy for healthcare professionals (HCPs) and hospitals.
A couple of the key points were:
The approach I recommend right now for mobile apps, if you’re developing them yourself, is to stay focused on HTML5 browser-based apps and not native apps. So, to answer Anne’s and DDS’s question specifically, no you shouldn’t wait to allow usage of mobile apps by anyone; but, if you’re looking to build your own apps and deploy them widely (not in simple experiments or pilots) then you shouldn’t write to iOS or Android or WP7 but instead use HTML5 frameworks like AppMobi and PhoneGap that give you almost the same functionality but protect you from the underlying platform wars. In the end, HTML5 will likely win and it’s cross-platform and quite functional for most common use cases. If you’re not developing the apps yourself and using third-party apps, then of course you must support the use of iOS native, Android native, and soon Windows native apps on your network.
So, from a general perspective you should embrace mHealth but do so in a strategic, not tactical manner. Here are the most critical questions to answer in a mHealth strategy — it’s not a simple one size fits all approach:
If there is interest in this topic, I will expand on my list of Do’s and Don’ts — mHealth is a very complex topic and requires a good strategy. Just saying that you allow the use of mobile devices like smartphones in your hospital is not an mHealth strategy.
In case you haven’t seen it, MU attestations data is now available on Data.gov and it includes analyzable vendor statistics.
The data set merges information about the Centers for Medicare and Medicaid Services, Medicare and Medicaid EHR Incentive Programs attestations with the Office of the National Coordinator for Health IT, Certified Health IT Products List. This new dataset enables systematic analysis of the distribution of certified EHR vendors and products among those providers that have attested to meaningful use within the CMS EHR Incentive Programs. The data set can be analyzed by state, provider type, provider specialty, and practice setting.
The data set does not include dollar amounts or the difficulty of attestation (e.g. how many times it took to pass). I’ll try and find out if that data might be available in the future. It’s also unclear whether the provider counts were broken up into each line (meaning one provider per row) or if multiple providers were aggregated into lines (meaning multiple providers were grouped).
The dataset is available now on Data.gov at http://www.data.gov/raw/5486 and is worth checking out. Since the file has been downloaded over 75 times, it’s clear some of you already know about this so if you’ve done some analysis with it; if you’ve done any analysis or posted results please drop me a note below so that everyone can benefit.
Last year I started a series of “Do’s and Dont’s” in hospital tech by focusing on wireless technologies. Folks asked a lot of questions about do’s and dont’s in other tech areas so here’s a list of more tips and tricks:
One of the most important activities you can undertake before you begin your EHR implementation journey is to standardize and simplify your processes to help prepare for automation. Unlike humans, which can handle diversity, computers hate variations. Before you begin your software selection process, get help from a practice consultant to reduce the number of appointment types you manage, reduce the number of different forms you use, ensure that your charting categories (“Labs”, “Notes”, etc.) don’t look different per patient type or physician, determine how you will manage medication lists and problem lists across the patient population, and deal with how you’ll manage paper in your digital world.
If you spend even just a few hours a week doing the prep-work before you buy any software, you will be better prepared in your selection process. Without some level of standardization your EHR implementation will either fail, be delayed, or have many unhappy users; the more you can standardize and simplify, the more likely you will have a successful outcome. A strong project manager with authority to make decisions will be the difference maker in the simplification process.
To help you with your workflow assessment and standardization efforts, check out the The Agency for Healthcare Research and Quality (AHRQ.gov) Workflow Assessment for Health IT Toolkit. Even if you’ve done workflow assessments before, the toolkit is worth checking out.
As most of my regular readers know, I work as a technology strategy advisor for several different government agencies; in that role I get to spend quality time with folks from NIST (the National Institute of Standards and Technology), what I consider one of the government’s most prominent think tanks. They’re doing yeoman’s work trying to get the massive federal government’s different agencies working in common directions and the technology folks I’ve met seem cognizant of the influence (good and bad) they have; they seem to try to wield that power as carefully as they know how. Since most of you are in the technology industry, albeit specific to healthcare, I recommend that you learn more about NIST and the role it plays – they can make your life easier because of the coordination and consensus building work they do for us all. I, for one, was thrilled when NIST was picked as the governing body for the MU certification criteria. These guys know what they’re doing and I wish they got more involved in driving healthcare standards.
A few years ago NIST came up with the first drafts of the seminal definitions of Cloud Computing; they ended up setting the stage for communicating complex technical concepts and helping making “Cloud” a household name. After 15 drafts, the 16th and final definition was published as The NIST Definition of Cloud Computing (NIST Special Publication 800-145) in September. It’s worth reading because it’s only a few pages and is understandable by the layperson. No computer science degree is required.
Yesterday I was speaking to a senior executive in the EHR space and we had a great discussion on what healthcare providers are doing in terms of cloud computing and how to communicate these ideas to small practices as well as hospitals. It reminded me of the numerous similar conversations I’ve had with other senior executives we serve in the medical devices and other regulated IT sectors. In almost every conversation I can remember about this topic over the past couple of years, I had to remind people that NIST has already done the hard work and that we can, indeed, rely on them. Most of the time the senior executive was unaware of where the definitions came from so I figured I’d put together this quick advisory.
My strong recommendation to all senior healthcare executives is that we not come up with our own definitions for cloud components – instead, when communicating anything about the cloud we should instruct our customers about NIST’s definition and then tie our product offerings to those definitions. The essential characteristics, deployment models, and service models have already been established and we should use them. When we do that, customers know that we’re not trying to confuse them and that they have an independent way of verifying our cloud offerings as real or vapor.
Below I have copied/pasted from NIST 800-145 their key definitions. Imagine how many debates you would avert with technicians at clients when, during conversations with a client, you communicated some of the following information first, showed them how it was a “standard definition” and handed them a copy of the publication, and then mapped your offerings and discussions to the different areas. Your sales teams and the marketing teams would appreciate the clarity, too.
Note that you do not need to map every offering you have to every definition – just start mapping the obvious ones and then figure out how you can communicate the “gaps” as being not applicable to your products / services or if those gaps will be filled in the future as part of your roadmap. Treat these definitions as canonical but not inclusive – meaning that just because your SaaS offering doesn’t fit every essential characteristic doesn’t mean that you’re not “cloud” – it just means partially cloud.
If you’ve got questions about how to map your product offerings, drop me some comments and I’ll assist as best as I can.
Here are the key definitions from NIST 800-145, copied directly from the original source:
Cloud computing is a model for enabling ubiquitous, convenient, on-demand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or service provider interaction. This cloud model is composed of five essential characteristics, three service models, and four deployment models.
On-demand self-service. A consumer can unilaterally provision computing capabilities, such as server time and network storage, as needed automatically without requiring human interaction with each service provider.
Broad network access. Capabilities are available over the network and accessed through standard mechanisms that promote use by heterogeneous thin or thick client platforms (e.g., mobile phones, tablets, laptops, and workstations).
Resource pooling. The provider’s computing resources are pooled to serve multiple consumers using a multi-tenant model, with different physical and virtual resources dynamically assigned and reassigned according to consumer demand. There is a sense of location independence in that the customer generally has no control or knowledge over the exact location of the provided resources but may be able to specify location at a higher level of abstraction (e.g., country, state, or datacenter). Examples of resources include storage, processing, memory, and network bandwidth.
Rapid elasticity. Capabilities can be elastically provisioned and released, in some cases automatically, to scale rapidly outward and inward commensurate with demand. To the consumer, the capabilities available for provisioning often appear to be unlimited and can be appropriated in any quantity at any time.
Measured service. Cloud systems automatically control and optimize resource use by leveraging a metering capability1 at some level of abstraction appropriate to the type of service (e.g., storage, processing, bandwidth, and active user accounts). Resource usage can be monitored, controlled, and reported, providing transparency for both the provider and consumer of the utilized service.
Software as a Service (SaaS). The capability provided to the consumer is to use the provider’s applications running on a cloud infrastructure2. The applications are accessible from various client devices through either a thin client interface, such as a web browser (e.g., web-based email), or a program interface. The consumer does not manage or control the underlying cloud infrastructure including network, servers, operating systems, storage, or even individual application capabilities, with the possible exception of limited user-specific application configuration settings.
Platform as a Service (PaaS). The capability provided to the consumer is to deploy onto the cloud infrastructure consumer-created or acquired applications created using programming languages, libraries, services, and tools supported by the provider.3 The consumer does not manage or control the underlying cloud infrastructure including network, servers, operating systems, or storage, but has control over the deployed applications and possibly configuration settings for the application-hosting environment.
Infrastructure as a Service (IaaS). The capability provided to the consumer is to provision processing, storage, networks, and other fundamental computing resources where the consumer is able to deploy and run arbitrary software, which can include operating systems and applications. The consumer does not manage or control the underlying cloud infrastructure but has control over operating systems, storage, and deployed applications; and possibly limited control of select networking components (e.g., host firewalls).
Private cloud. The cloud infrastructure is provisioned for exclusive use by a single organization comprising multiple consumers (e.g., business units). It may be owned, managed, and operated by the organization, a third party, or some combination of them, and it may exist on or off premises.
Community cloud. The cloud infrastructure is provisioned for exclusive use by a specific community of consumers from organizations that have shared concerns (e.g., mission, security requirements, policy, and compliance considerations). It may be owned, managed, and operated by one or more of the organizations in the community, a third party, or some combination of them, and it may exist on or off premises.
Public cloud. The cloud infrastructure is provisioned for open use by the general public. It may be owned, managed, and operated by a business, academic, or government organization, or some combination of them. It exists on the premises of the cloud provider.
Hybrid cloud. The cloud infrastructure is a composition of two or more distinct cloud infrastructures (private, community, or public) that remain unique entities, but are bound together by standardized or proprietary technology that enables data and application portability (e.g., cloud bursting for load balancing between clouds).
AUSTIN, TX– Oct. 19, 2011–Drummond Group Inc. (DGI), the trusted interoperability test lab, last week submitted to the DEA its e-Prescribing of Controlled Substances (ePCS) Certification Process documentation. The DEA is currently reviewing this ePCS Certification Process for approval. Upon approval, DGI will be providing ePCS certification to healthcare software companies with the capability of e-Prescribing controlled substances.
Since 2005, Drummond Group has been the lead auditor and certification organization for the DEA’s final rule regulations on the Controlled Substance Ordering System (CSOS). CSOS enables drug manufacturers, distributors and pharmacies to electronically automate the order and fulfillment supply chain of controlled substances. Drummond Group also serves as an Authorized Testing and Certification Body (ATCB) under the Health and Human Services’ (HHS) electronic health records (EHR) certification program and has certified more than 450 software applications, including e-Prescribing solutions, since its inception in 2010.
For complete press release, please click here.
Last month, Steven Posnack, director of the Federal Policy Division within the Office of the National Coordinator for Health (ONC), wrote a very helpful blog on fact and fiction related to the ONC certification program. We have recently had many questions related to Drummond Group’s involvement in the ONC Permanent Certification program and related certification. Here is our own QA session for questions and how that affects certification from the current Temporary Program.
Question: What is difference between the Permanent Certification Program and the Temporary Certification Program? What about ATCBs and ACBs? Is ANSI now involved in certification?
Answer: The Temporary Certification Program and the Permanent Certification Program are ultimately about the governance of the testing and certification program, specifically, the bodies that are testing and certifying, like Drummond Group. Their work and requirements are, in most ways, outside the concern of EHR vendors and HIT users. Meaningful Use measures and ONC certification criteria are completely separate from the Final Rules governing both certification programs.
The requirements within both programs are very similar. The chief difference is the accreditation method. In the Temporary Program, an organization like Drummond Group was required to take comprehensive tests and submit two sets of quality manuals: 1) for testing plans and processes and 2) for our certification processes. These were approved by ONC itself to be accredited as an ONC Authorized Testing and Certification Body (ATCB). In the Permanent Program, ONC is no longer acting as the accreditation body of either testing or certification although they will still oversee the program. Instead, there is a new ONC-Approved Accreditors (ONC-AA), ANSI, who will do the accreditation for the certification bodies as an ONC-Authorized Certification Body (ACB), and NVLAP, a division of NIST, will run the accreditation program for the testing bodies.
Question: Will Drummond Group be a part of the Permanent Certification Program? Will you also do testing?
Answer: Drummond Group’s intention is to be an ACB (Authorized Certification Body), as well as an NVLAP accredited testing body for EHRs. We are currently working on preparations for approval in the Permanent Program.
Question: When will Drummond Group or others be named as ACBs? Do you have a timeframe?
Answer: We are really hesitant to even speculate on a specific date when ACBs will be open for business given there are many unknowns. Here is what we do know: NIST will be releasing the final testing accreditation requirements for testing agencies around December and will begin processing the applications on Jan. 15, 2012. We have no word from ANSI or ONC on details for applying to become an ACB, nor additional certification body accreditation requirements apart from the core ISO Guide 65.
Also, accreditation is just the first step. Only after you are accredited by ANSI for your certification quality procedures can you submit your application to ONC to be a part of the Permanent Certification program. In the Temporary Program, the submission to ONC to be an ATCB until official approval was a process that took approximately two months.
Question: Will there be new criteria to test and certify in the Permanent Program and will certified EHRs have to return and be recertified with an ACB to remain on the CHPL?
Answer: As stated above, the Temporary and Permanent Program Final Rules are ultimately about the governance of the testing and certification program but not about the criteria which the ATCBs or ACBs will certify. The testing requirements and certification criteria come from ONC separate from anything to do with the current state of the certification program.
Even in the Temporary Program, ONC could revise and update the certification criteria requiring products to be retested and recertified. In fact, they actually did make a revision to the public health surveillance criteria (170.302.l) in an interim rule in October 2010 although it did not require recertification. Eventually, the criteria will be updated when new meaningful use stages are introduced, but that is not connected with the timing or availability of the Permanent Program. Also, certified EHRs will not need to be recertified by an ACB simply because the ATCBs are dissolved with the closing of the Temporary Program.
Question: Once we are in the Permanent Program and new criteria are introduced, such as with Meaningful Use Stage 2, will certified EHRs to have to retest everything previously tested and certified in the temporary program?
Answer: On retesting previously certified criteria, the Permanent Program Final Rule does make a reference to allowing for “gap” certification of new or revised criteria added in later stages versus fully recertifying and retesting all criteria, including those unchanged from previous ONC rulings. However, it ultimately leaves this to the decision of the ACB. We (Drummond Group or any other ATCB) cannot speak definitely on this until we are an ACB and receive further guidance from ONC and possibly ANSI, which is the selected ONC-AA who will accredit us.
Question: In his blog, Steven Posnack stated that current CHPL certification will not expire. However, the certification seals issued in the Temporary Program make reference to 2011/2012. What does that mean?
Answer: Those 2011/2012 Certification Seal dates come from the ONC Final Rule on the Temporary Program, but they are not explicit expirations. Rather, they reflect what was anticipated as the timeline of the criteria and associated Stage 1 Meaningful Use measures.
It ultimately depends upon the current module criteria requirements. If they are not updated, then the certification is still valid.
As a testing company with more than a decade’s worth of experience, we’ve certified many software products across multiple industries. In the process, we’ve worked with quite a few certification and standards-setting bodies.
For the past several months, we’ve been busy in the healthcare industry, working under the auspices of the government’s electronic health records incentive program. As a matter of fact, since becoming an Authorized Testing and Certification Body (ATCB), we’ve certified more than 300 electronic health records systems using a testing script developed by National Institute of Standards and Technology (NIST) for the Office of the National Coordinator for Healthcare Information Technology (ONC-HIT).
Although we’ve tested systems for a variety of standards-setting groups, we weren’t quite sure what to expect when we started working as a testing company under the purview of the Health Information Technology for Economic and Clinical Health (HITECH) legislation – a behemoth government program to say the least.
Much to our delight: We’re really happy with the way things are going so far.
Why? First, we think the leaders in the government program got it right. The powers-that-be managed to develop clear technical requirements without imposing restrictive implementation methods, making it possible to ensure that certified EHRs all perform at a certain level, but also leaving enough flexibility for EHRs to meet specific user needs and for developers to continue to innovate. It’s a tricky balance but one that the ONC seems to have mastered quite well.
As a result, there’s plenty of room for developers to come up with products that push the envelope with new features and functions or to tailor systems to meet the very specific needs of certain specialists such as OB-GYNs, chiropractors or plastic surgeons. At the same time, end-users can rest easy, knowing that software systems that have been certified actually live up to the specifications that will make it possible for them to meet the government’s meaningful use requirements and, subsequently, qualify for their share of the federal government’s incentive funds.
We’re also happy with our work in the program. We feel that Drummond Group has been able to add value to the overall process by infusing a healthy dose of neutrality into the testing and certification process. Steadfastly maintaining neutrality has, after all, been a concept that we have built our company on since the beginning.
Although happy to be a member of the healthcare IT community, we purposely shy away from becoming deeply involved in professional coalitions or advocacy efforts. As such, when we test a product, we test a product. We don’t have to worry about the fact that an industry coalition spoke out against one of the ONC test requirements because our neutrality would keep us apart.
In essence, we make sure we don’t attach to anything else, so that the only thing we are attached to is testing. It’s a singular focus that serves software developers and the overall mission of the HITECH program well.
It’s complicated. That’s how many hospital leaders describe their electronic health records initiatives. These hospitals – instead of having a neat all-in-one EHR solution driving their efforts – have moved toward electronic records by cobbling together a variety of off-the-shelf, customized and possibly even home-grown solutions.
If you work at one of these facilities, you are probably all too familiar with the complications. And, when it comes time to get the stamp of approval needed to qualify for incentive funds, you probably don’t know exactly where to start. No worries. Drummond Group is ready to help. We’re taking applications from hospitals that want to achieve ONC-ATCB 2011/2012 certification for their unique EHR solutions. We stand ready to help hospitals in this situation move forward by testing their solutions to gain the certification required to move toward meaningful use.
Best of all, though, we are gearing up to truly offer more than a cursory certification. With more than 10 years of software testing experience, we have the interoperability know-how that you can tap into to truly get your miscellaneous solutions working together as one unified EHR. Having worked in a variety of complicated industries, we have encountered many difficult software and integration testing scenarios – and have had to evaluate a wide variety of software configurations from the simplest, out-of-the-box applications to complicated solutions derived from a variety of cobbled-together software applications.
What’s more, we are truly committed to meeting the specific needs of healthcare providers. We are presently answering inquiries with hospitals and working on setting up certifications for them. And, while we are ready to start working with you today to qualify your customized or home-grown system for certification, we plan on rolling all of our know-how up into a formal service offering early next year.
Remember, though, to achieve ONC-ATCB 2011/2012 certification, EHR software has to be tested based on the official criteria as defined by ONC. Authorized Testing and Certification Bodies (ATCBs) test and certify the software and then HHS approves and lists these certifications on the Certified Health IT Products Listing (CHPL). Customized programs for hospitals or specific specialties – while designed to help meet the unique needs of various classes of HIT vendors — are not required for the certification that will enable your organization to meet meaningful use incentives.
We’re often asked why we jumped into the healthcare industry. Our answer: It’s simple Business 101 logic. We saw a need and we knew we could fill it.
First, we started hearing from healthcare information technology vendors about the need for software testing. We investigated and discovered that the Department of Health and Human Services (HHC) Office of the National Coordinator (ONC) for Health Information Technology was recruiting organizations to serve as Authorized Testing and Certification Bodies (ATCBs) to provide the stamp of approval to electronic health records (EHRs) that would be used by healthcare provider organizations as they seek to qualify for incentive funds under the American Recovery and Reinvestment Act.
All of this opportunity, of course, piqued our interest. Realizing that we really had something special to offer the healthcare industry, however, made us take the plunge.
Most importantly, we felt that we could offer the efficient and effective software testing that the industry needs –as vendors are scrambling to meet the needs of providers with officially certified EHR solutions. Because we have tested complex software products in a plethora of industries for more than a decade, we have what it takes to get the job done. As a result, vendors can quickly and affordably get their EHR solutions listed on the Certified Health IT Products Listing (CHPL) – and providers can use the solutions to qualify for incentive monies.
Our vision extends beyond the short-term, though. We also realized that we could offer healthcare information technology companies the testing services that they will need as meaningful use requirements evolve—and become more complex. Because of our extensive testing experience, we have become experts in interoperability and privacy issues. Also, we feel that we will be able to help healthcare IT vendors with these issues as meaningful use evolves.
Drummond Group’s ONC-ATCB Certified EHR products have now been posted on the HHS Certified Health IT Products Listing.
Problems viewing the HHS Certified Health IT Products Listing?
Home page of healthit.hhs.gov and look under “What’s New”
Questions? Shoot us an email at EHR@drummondgroup.com
By Sheldon Needle
The real problem of an established medical practice moving into the realm of EHR is not the cost of the medical software package; it is not the training necessary for staff; and it is not security and backups.
The real problem of moving into EMR/EHR is the problem of unstructured medical data.
If you are involved in a new or relatively new practice, this is a no-brainer. Begin with a serious search to compare medical software vendors who are available to answer your questions honestly. It is not truly so difficult to get on a friendly medical screen to enter your patient’s blood pressure or lab test values. You can get used to that.
Neither is it difficult to take notes on a notebook that upload to the EHR system.
The real problem is taking your notes and dictation on a patient that go back 15 years and finding a way to get his possible symptoms, his worry about IBS, his headache history, and his worries over his children into a metrically available rendition that that does not take you or a member of your practices days to decipher. These notes are usually on dictation, hand written notes, and referral letters.
The concerns are many: this can take what feels to be forever, and the anxiety issues and unclear symptoms may not translate easily into metrics but may be critically important in future diagnoses.
There are two critical questions here:
In the long run, it doesn’t even matter if it is worth it. It will happen. Medicine as well as the rest of our cultural world, is becoming electronically-based whether we like it or not. But in the long run, it is worth it. Think of a patient going in to the hospital after a car accident, all by himself, and having all his data available to the admitting doctor in an instant: blood type, history, etc.
Think of a patient being referred to you, the specialist, and having all his patient history available in less than a minute. What a time saver! What insight!
Medical informatics has a number of methodologies it is using to translate unstructured data into useful and structured data.
Three basic methodologies exist to accomplish this:
These methods will be refined, utilized, and integrated in some way into most decent medical vendor software packages over the next few years. For you the physician or practice manager, this may start to pay off in a while, but you still have to get from hand written records into the database.
The obvious way to proceed makes use of our culture idea of, “going forward”:
The real message to practitioners moving to electronic health records is, don’t look at the top of the mountain when you start climbing, just put one foot in front of the other. Delaying the climb will not get you anywhere, but starting the march will move faster than you think!
Having recently spent time as an observer in a hospital setting, I was struck by the lack of intelligent planning and forethought made for doctors trying to move into an EMR / EHR environment.
Though I saw a well-known EHR panel on the computer screens within an ICU, and the EHR being used to record certain patient data, doctors were taking their notes in long-hand. Later on the same day I saw the same doctors transcribing their notes onto their computers. The doctors, doing double duty on note taking were not available to their patients because they were acting as secretaries.
When a large clinical environment is incorporating an EHR it has to be done in a modular way that does not impact productivity any more than it has to. The task is hard enough. If you are using an EHR to record point of care patient information, give your doctors a Notebook so they can take their notes electronically. In fact, insist on electronic note-taking. Incorporate change with some forethought to peoples’ time and effort.
This real-life observation just underscores the need to plan for transition to an EMR rather than throwing an institution into the chaos of change for its own sake, or for the sake of Meaningful Use incentive payments. As in all things, the old US Coast Guard motto holds true: Semper Paratus! Always be ready and prepared.
Most good EMR / EHR systems can offer medical clients some guidance as to best practices in incorporating EMR / EHR systems within their practices.
By Sheldon Needle
The prospects for EHR in the coming year are exciting but more than a little daunting. The issue is really how to find an EMR/EHR system that will organize and centralize the functions of your practice, without bankrupting you and throwing your staff and yourself into turmoil.
If you look at the websites for EMR vendors today, you can see that the functions they describe within their system –the integration of clinical records with practice management data, e-prescription, patient portals — could conceptually do wonderful things for you and for your patients in the way you handle their individual cases, but many of the details are still not working smoothly.
Here are some of the things to be aware of:
Remember, always read the fine print and ask every question you need to. Know that EMR software decisions is a very competitive business. The vendors need you just as much as you need them!
By Sheldon Needle
5010 is not only a date 3,000 years in the future: ANSI 5010 is the newest version of the HIPAA transaction standards regulating electronic transmission of medical and healthcare transactions. The existing standard is called 4010, and 4010 does not support ICD-10 coding.
The current coding standard for diagnosis and procedure coding is the ICD-9, and it has outlived its possibilities –it limits the number of new procedure and diagnostic codes that can be created.
This is how the CMS.gov (center for Medicare and Medicaid services, at: http://www.cms.gov) defines the ICD-10:
ICD-10-CM/PCS (International Classification of Diseases, 10th Edition, Clinical Modification/Procedure Coding System) consists of two parts:
ICD-10-CM is for use in all U.S. health care settings. Diagnosis coding under ICD-10-CM uses 3 to 7 digits instead of the 3 to 5 digits used with ICD-9-CM, but the format of the code sets is similar.
ICD-10-PCS is for use in U.S. inpatient hospital settings only. ICD-10-PCS uses 7 alphanumeric digits instead of the 3 or 4 numeric digits used under ICD-9-CM procedure coding. Coding under ICD-10-PCS is much more specific and substantially different from ICD-9-CM procedure coding.
The transition to 5010 is supposed to happen by January 1, 2012. This means that electronic transmissions including claims, eligibility inquiries and remittance advices must be made in a 5010-compliant format. Healthcare providers, health plans and clearinghouses for transactions are all expected to upgrade their transmissions. Non-compliance may result in claims denied or slower payment.
Systems that are certified as ONC-ATCB for 2011/2012 are already 5010 compliant. If you are contemplating buying a system that is so certified, you do not have to worry about the software compliance, but you do need to educate your staff, including yourself, if you are the physician or the P.A., on what the differences between 4010 and 5010 mean to their everyday work.
If you are using old medical software that has not been updated, or are contemplating installing software that is not certified as ONC-ATCB for 2011/2012, you need to update to a newer version, or face delays and uncertainties in your billing and claims submission. In other words, do some serious upgrading, or else!
By Sheldon Needle
November 30, 2011: Today HHS Secretary Kathleen Sebelius announced incentives to speed the adoption and use of health IT in the form of meaningful-use qualified EHR in doctors’ offices and hospitals nationwide, which will improve health care and create jobs nationwide.
The new administrative actions announced today, which will be made possible by provisions of the HITECH Act, will loosen requirements for doctors and other health care professionals to receive incentive payments for adopting and meaningfully using health IT.
“When doctors and hospitals use health IT, patients get better care and we save money,” said Secretary Sebelius. “We’re making great progress, but we can’t wait to do more. Too many doctors and hospitals are still using the same record-keeping technology as Hippocrates. Today, we are making it easier for health care providers to use new technology to improve the health care system for all of us and create more jobs.”
The press release continues to state: “HHS also announced its intent to make it easier to adopt health IT. Under the current requirements, eligible doctors and hospitals that begin participating in the Medicare EHR (electronic health record) Incentive Programs this year would have to meet new standards for the program in 2013. If they did not participate in the program until 2012, they could wait to meet these new standards until 2014 and still be eligible for the same incentive payment. To encourage faster adoption, the Secretary announced that HHS intends to allow doctors and hospitals to adopt health IT this year, without meeting the new standards until 2014. Doctors who act quickly can also qualify for incentive payments in 2011 as well as 2012.”“ (The italics are ours.)
We need to understand what acting quickly means: buying in 2011? Incorporating EHR within the next month, so that meaningful use occurs in 2011? This is not yet clear.
HHS is redoubling its effort to reach out with information, education, and the possibility of incentive payments to doctors and hospitals and vendors about stepping up the pace of transitioning practices and HER software to meet standards of Meaningful Use. What Meaningful use means to the individual practice depends on size, degree of implementation of the EHR, and the nature of the client base (how many Medicare or Medicaid patients, for instance, figures into the formula of Meaningful Use.
The Obama Administration is working to create a nationwide network of 62 Regional Extension Centers, comprised of local nonprofits, to help eligible health care providers learn how to participate in the Medicare and Medicaid EHR Incentive Programs and meaningfully use health IT.
See the HHS press release, at: http://www.hhs.gov/news/press/2011pres/11/20111130a.html to learn more.
Keep your eyes on the newspapers, government announcements and on this blog to learn about EMR and EHR news and updates.
By Sheldon Needle
You know that your medical practice will have to bite the EMR bullet sooner or later (actually, sooner). The digital handwriting is on the tablet, isn’t it? So what is it stopping you from moving ahead at a planned pace rather than being forced into converting your medical practice to an EMR at the 11th hour?
Here are some of the most common obstacles people face in converting their practices to the use of electronic medical record software, and here are some strategies to deal with them or get the process going:
1. How will we migrate from paper to digital images? Conversion of paper medical records to digital format: If you have your eye on an EMR, learn how tolerant it is of varying formats: does it accept PDF files? JPG format? Ascii text files? Extracts from excel files?
Don’t bit off more than you can chew to begin. If you are practice with reams of folders full of paper files to convert, decide how many years back you need to go in getting your EMR up and running. Perhaps you can start with one year of files via EMR? Or perhaps you need to go much further back?
Look into the possibility of having a consultant specializing in data conversion take charge of your files. There are companies that specialize in just such medical data conversions. If you are really desperate, hire your responsible college students, make the specs clear, and pay her decently!!
2. How will we train everyone in such a new system? Training your self and your staff: Once you have chosen your EMR system, engage the company’s own training staff; that way, you are sure you are being oriented in the current system, using the right documentation. Before you chose your EMR, see what kind of training options the company offers. You might go for a short orientation up front, with a good help desk that is available 24/7. Check reliable Electronic medical records ratings to see which companies provide good in person and on the phone / online support
3. Do we have to set up all the hardware and maintain the software? I don’t think we can manage that. Consider a cloud-based EMR solution: If you are reluctant to invest in a server and commit to the upkeep of hardware and software, consider a Web-based EMR solution, in which you log onto an EMR that worries about security, and updates to hardware and software.
4. How can I compare products so that my practice knows what it is getting into? How much can I trust referrals from other practices? Don’t put all of your EMR decision eggs into one basket: While personal referral are extremely helpful and reassuring, not all are meaningful for your unique EMR practice situation. There are many good EMR products to choose from, and each has its strengths, and its weaknesses.
The right choice will depend as much on the nature of your medical practice and the answers to many questions: What is your medical specialty? How many employees do you have? How expensive is the EMR, per year? How much money can you dedicate to investing in your EMR annually? Can you integrate your medical billing software with your proposed new EMR? Can you afford to hire a dedicated IT employee? How comfortable you and the others in your practice are with using an electronic device as the main source of medical input to your system. These are just a few of the many questions you need to ask yourself.
Talk to people in other practices, yes; but learn to ask the right questions and compare apples to apples and oranges to oranges. Great EMR comparison tools are available to you at no charge, and they can educate you to ask the right questions and maintain a solid baseline for comparison when choosing an EMR.
It seems like everyone I talk to or interact with in the Health IT world is in full on HIMSS 12 preparation mode. I only attended my first HIMSS 2 years ago in Atlanta. So, I’m mostly a newbie at HIMSS. I sometimes long for the days when I just went to HIMSS with little real planning. I just went and enjoyed myself.
As you can imagine, HIMSS is a perfect place for me and my business. I’ve often told people that the core of my business is great content and advertisers. Turns out that every booth and every person at HIMSS is possibly both. For me, it’s like being a kid in a candy store. So, many exciting things to try (and you might even say you get sick after “eating” too many as the flavors all run together). To be quite honest, I love the entire experience. I was meant for the system overload that happens at HIMSS. I love large crowds of people and being overstimulated. I guess that’s why I love living in Las Vegas (which is also convenient for this year’s HIMSS).
HIMSS Attendee and Exhibitor Count
Enough about me. What can we expect at this fantastic affair called HIMSS 2012? Last year there were 30,000 attendees and I wouldn’t be surprised if this year it’s somewhere in the neighborhood of 35,000 people attending HIMSS. During an #HITsm twitter chat about HIMSS, I said that there would be at least 1000 vendors exhibiting at HIMSS. If I remember right (I can’t find the tweet), one of the HIMSS staff corrected me and said there would be 1100 companies exhibiting at HIMSS this year.
What does all this mean? Well, as my mother always told me: You can’t do everything. I’d always look at her shaking my head saying, “You’re right….but I’m sure going to try.” I think this describes my approach to HIMSS as well. Although, each year I am getting more selective on what I spend my time doing.
Press at HIMSS
I’m sure that many reading this are wondering how they can get some coverage on the Healthcare Scene blog network at HIMSS. Considering the 40 or so emails from PR people that I have filed away already, I’m going to have to apply a pretty strict filter.
What then are my filters?
First, if you’re an EHR company, then I’m probably interested in connecting with you in some form. Although, if you’re an EHR company that’s just seen me and has nothing new to say, then I’ll probably pass at this HIMSS. To be honest, I could probably fill my entire schedule with just EHR companies considering how many EHR companies there are out there. Plus, I think I’m going to bring around my flip video and do an EHR series called “5 Questions with EHR Companies.” I’ll see how many EHR companies I can get to answer the same 5 questions.
However, an entire week of just EHR talk would be a little rough. Plus, I asked on Twitter if I should look at things outside of EHR and they all said I should. I’m a man for the people, so I must listen. How then could another healthcare IT company get me interested in meeting with them at HIMSS?
The best way to get me interested in talking with your company is to provide something that will be interesting, unique and insightful to my readers. Remember that my main goals are great content and advertising. If you provide me with great content that my readers will love, then I’ll love you and likely write about that content.
I didn’t realize this when I started blogging, but I’m not like a lot of journalists. I don’t go to any conference with stories in mind. I’m not digging around HIMSS to try and find an ACO story for example. Instead, every person that I talk to I’m trying to discover what stories are being told at HIMSS that are worth telling. I’m always happy when people help me find interesting stories.
Social Media at HIMSS 12
Speaking of finding stories. One of the most interesting ways I use to find stories and connect with people is through social media and in particular Twitter (see this post I did on EMR and HIPAA about Twitter). I guarantee you that Twitter usage at HIMSS 12 is going to be off the charts. There is going to literally be no way to keep up. I love the idea that Cari McLean had of the HIMSS Social Media Center summarizing the most important tweets during HIMSS. Granted, that’s an almost impossible task to ask anyone to do.
Of course, the HIMSS related hashtags will be another great way to filter through the various HIMSS related tweets that are happening. Here are some of the ones I’m sure I’ll be using:
#HIMSS12 — official hashtag for the event
#HSMC — HIMSS Social Media Center
#HITX0 — HIT X.0: Beyond the Edge specialty program
#LFTF12 — Leading from the Future specialty program
#eCollab12 — eCollaborative Forum
Here’s a bunch more HIMSS related social media hashtags you might want to consider:
HIMSS Social Media Center
If you love social media like I do, then you’re also going to love the HIMSS Social Media Center. They’re doing a number of Meet the Bloggers sessions again and I’ve been invited to participate in the Health IT Edition of Meet the Bloggers at HIMSS. I’m on the panel along with: Brian Ahier (Moderator) Health IT Evangelist, Mid-Columbia Medical Center, Jennifer Dennard, Social Marketing Director at Billian’s HealthDATA/Porter Research/HITR.com, Neil Versel, Freelance Journalist and Blogger, Carissa Caramanis O’Brien, Social Media Community and Content Director, Aetna. Should make for a pretty interesting conversation. Plus, you know I always like to mix it up a bit.
New Media Meetup at HIMSS
More details coming soon. We’ll have to work on Neil Versel’s idea of starting a Twitter storm to get Biz Stone to come to the HIMSS meetup.
Dates of HIMSS
Be sure to check the dates of HIMSS. As Neil Versel noted, it’s a little different days than it’s been in the past. I personally like these dates better than the other ones.
There you have it. I thought I’d do a short post on HIMSS and I guess I had a lot more to say. I’d love to hear if you’re going to HIMSS. If you know of any events, sessions, parties, announcements, technologies etc. that I should know about at HIMSS, let me know.
And the most exciting part of HIMSS…seeing old friends and making new friends. I can’t wait.
No related posts.
One thing that I love about this industry is its willingness to collaborate, and I’m not just talking about collaborative care. I’m talking about healthcare IT’s propensity to brainstorm new ideas as the drop of a hat. Put two HIT folks – be they physician, vendor or blogger – in a room, and 20 minutes later you’re going to have a new idea related to care delivery, product development or possible partnership on your hands. It gets even more prolific when editorially minded marketing folks like me are added to the mix.
I’ve been pleasantly surprised at how even blogs can foster this sort of collaboration. Last month in “Finding an EMR Job Champion,” I chatted with Rich Wicker, HIMS Director at Shore Memorial Hospital in New Jersey, about how this industry can best align recent graduates of HIT certification programs with training and jobs. Some of you may have noticed several comments left on that post by Sean McPhillips, a man of many hats. He is currently an adjunct instructor at Cincinnati State – a community college in the HITECH College Consortia; project manager at the Kentucky Regional Extension Center; and creator of the HITECHWorkforce.com, a free resource to help students enter the HIT work environment.
In his comments, he advocates for a mentor-protégé program: “Students still need some more help finding jobs. What I think needs to happen is a “Mentor/Protégé” model. That is, pairing students with industry professionals who can mentor them into the industry. I’ve passively done that…to success. I think that will work.” He later followed up with the news that he hopes to work with HIMSS, which is developing a similar program, to get this model off the ground.
I recently had the opportunity to speak with McPhillips a bit more about his idea. I was eager to find out just how he plans to jumpstart it:
It seems as if you’ve been kicking this idea around for a while. How did it come about?
Being with the extension center, I’ve mentored a handful of people along the way, and I think there needs to be a more structured process so that students coming out of these [HITECH College Consortia] programs who want to be mentored have a place to go, they know how to get and stay engaged in the process. I think that there is with HIMSS, but I don’t think it’s really been tightly coupled with the workforce development program.
When I spoke with Helen Figge, Senior Director of Career Services at HIMSS, she was really excited to talk with me, and pointed me to HIMSS’ career development page to look around and see what they have out there. I’m thinking of how we can connect [what they’re already doing] into the workforce development program within the overall HITECH project structure, so that we can connect students who come out of these programs with their local HIMSS chapter, which could then pair them up with a mentor that’s in their region. That’s what’s really missing. That’s what’s really necessary to get people plugged into this profession – especially if they’re coming from outside of this profession.
HIMSS does not already have some sort of relationship with the college consortia?
They kind of do, but I don’t think it’s really tightly coupled. I think HIMSS recognizes this, so they’ve been developing their career development program. They’re near completion of a new, entry-level certification called the CSHIMS certification. That is something where you don’t need to have a whole lot of experience in health information technology, but you need to demonstrate some degree of knowledge in subject matter to obtain that certification. That might be a good way to help these students take the next step into the profession, when they’re looking to get a job. That could be part of the whole mentorship program concept.
Isn’t there a double-edged sword to it financially? Wouldn’t students have to become paying members of HIMSS, and then would they have to pay for certification? If they’re looking for jobs, finances might be tighter than usual.
That’s a great point. The question is, what are the costs associated with certification and becoming a member. There is a student membership discount. There’s a cost to certification, obviously, so these are things that are to be considered. That has not escaped me, so that’s going to be part of my brainstorming session. I’m going to meet up with them in Vegas when I go out to HIMSS.
One of the things I want to be able to do is make this attractive for people, particularly students, and if they have to lay out $500 or $1,000, and they’re already unemployed or they’re financially strapped, it becomes not just a double-edged sword, it becomes a disincentive.
I wonder if the vendors couldn’t get involved and offer scholarships.
It’s funny that you mention scholarships because that might be something the local HIMSS chapters can do. I know the Ohio HIMSS chapter used to do a $1,000 scholarship every year for students. So this might be something that the boards or the individual chapters could subsidize.
If you’re in the HITECH workforce development program, maybe HIMSS would be willing to waive membership for one year. That might be something they may be interested in doing.
This is part of the whole brainstorming session that I’m going to try to have over the next month or so. I’ll vet this through HIMSS over the next couple of weeks and hopefully we’ll come up with a good strategy by the end of February. And then we’ll start piloting it in the March timeframe.
I hope to run into McPhillips in Vegas to see how his chat with the HIMSS career development folks is coming along. It’s nice to know that one industry insider’s idea, and subsequent blog comments, might actually create job opportunity in the industry.
I recently saw a tweet to the National Conference of State Legislatures (NCLS) list of “Top 12 Legislative Issues of 2012.” It’s an interesting look into issues that state legislatures will be dealing with in 2012. Plus, it makes an interesting observation at the outset that state budgets have been cut so much in past years that lawmakers won’t have to focus all of their initial energy on budget shortfalls.
Most of the list is not surprising with managing the state budget and jobs are at the top of the list. However, there are a couple healthcare and health IT related sections in their list of top government issues as well.
One of the issues is Medicaid: Efficiencies and quality. It talks about how the tough economy is making the Medicaid budgets in states a real challenge and many are looking for cost containing actions. Plus, it points to ACO type reimbursement based on patients’ health outcomes, medical homes and streamlining services. The ACO part was quite interesting to me. I wonder how much of an effect lack of Medicaid budget will push forward a new model of healthcare.
The disturbing part of the report comes in the “Health: Reform in the states, health care exchanges, technology and benefits. Here’s the section on health IT, the EHR incentive money and HIEs.
HEALTH INFORMATION EXCHANGE: One focus for state legislatures in 2012 will be how to move health care providers, especially those participating in the Medicaid program, toward the adoption of certified electronic health records (EHRs). Essentially, instead of having a different health record at each doctor or provider you visit, an EHR will serve as one file that all of your doctors can see. EHRs, once fully implemented, are expected to provide doctors and health professionals with easier access to patient histories and data, resulting in cost-savings and better health outcomes by removing costly errors and duplications in services.
I love how this basically assumes that by having widespread adoption of EHR software, that we’ll then have one patient record that each doctor you visit can see instead of having a different health record at every doctor. Of course, those of us in the EHR world know that this is a far cry from the reality of EHR software today. In most cases you can’t even share a patient record with someone using the same EHR software as you let alone sharing a patient record with a doctor who is using a different EHR.
The sad part is that whoever wrote these legislative issues must have realized that there was some issue with EHR software exchanging information, because then they wrote the following about the state HIE initiatives.
In addition, states are responsible for building and implementing health information exchanges (HIEs) where those EHRs can be accessed by health care providers. HIEs function like an online file cabinet where your medical record is securely stored, and can be accessed by any doctor or health care professional you visit. By mid-year 2012, every state should have Medicaid EHR Incentive programs in place and will be working toward building an HIE by late 2014 or early 2015 as required by deadlines attached to federal cooperative agreements.
So, wait. If EHR software has created one file where any doctor can access our patient record, then why do we need “an online file cabinet” for our medical records? We know the answer is that we need the online filing cabinet because EHR software isn’t connected and there isn’t one patient record. Each doctor maintains their own patient record and that’s not going to change any time soon.
The above quote also implies that every state is working towards an HIE program per the federal program. I must admit that I haven’t gone through every state, but is every state working on an HIE? I certainly know there are a lot of states working on some sort of HIE project, but I didn’t think that every state had funding for HIE. I guess maybe the question is whether there is any state that doesn’t have some sort of HIE program in the works.
Reading issues described like this, you can understand how government passes legislation with limited understanding. Based on this resource, EHR software creates one patient record. Wouldn’t that be nice if it were the case?
EMR and EHR Readers, have you already started breaking your New Year Resolutions? I know I have. My New Year resolution was a very unambitious I will exercise at least every other day, and I couldn’t hold on to that for a week. However, all is not lost. Even if you’re falling short on fulfilling your resolutions, you can still make a compelling video on some kinds of health IT related resolutions and maybe walk away with a decent cash prize. Don’t know what I’m talking about?
The Office of National Coordinator on Health IT is hosting a health IT challenge. Participants need to create a short (upto 2 mins) in length video that covers:
a) what your health resolution for 2012 is
b) how you will use IT to fulfill your resolution and
c) how you maintain your resolution using health IT tools.
Here are some examples listed on the ONCHIT website:
I will set up an online personal health record for myself (or another family member) so I can have all of my health information conveniently stored in one place.
I will ask my doctor for a copy of my own health records — electronically if available — and help him or her to identify any important information that may be missing or need to be corrected.
I will find an online community that helps me figure out the best ways to manage my health condition (depression, cancer, diabetes, etc.)
I will use an electronic pedometer to help me track my physical activity and will try to take 10,000 steps per day.
I will find an app on my smartphone to help me track my food intake so I can lose 10 pounds by my high school reunion.
I will sign up for a text reminder program on my cell phone to help me stop smoking or remind me to take my medications on time.
Please note that these are just suggestions, not listed topics. In fact ONCHIT encourages you to get creative and create your own HIT resolutions.
Of course, being as it is 2012, and well into Web 2.0fication of our lives, it’s not enough to make resolutions about improving our health. If you want to participate in the ONCHIT challenege, you’ll have to find ways to incorporate health IT into your resolution. I’ve worked pretty much my whole adult life, barring some exceptions, in the IT industry. But even so, I believe that IT can only solve some classes of problems, so I’m a bit wary when developers and programmers bring their hey-I-can-create-an-app-for-that attitudes whenever they’re confronted with any problems. That said, I do think some aspects of health IT can be useful. And I’m excited to see what creative things people will come up with.
No related posts.
Time for the next entry covering Shawn Riley’s list of 101 Tips to Make your EMR and EHR More Useful. I met someone at a conference who commented that they liked this series of posts. I hope you’re all enjoying the series as well. This is the second to last post in the series of EMR tips
10. Build performance dashboards, not just quality dashboards
Yes, Dashboards can work well for clinicians, but for support people as well. If you start measuring something and displaying the results of that measurement, then the measurement improves. Study after study has shown this.
9. Flexibility with physician devices is important, but you still need to standardize
I think this is a little bit of an evolving issue. However, it’s unreasonable to expect your IT staff to support every platform, every version, and every type of device out there. Tech innovation is moving way too fast and an attempt to go this route will lead to failure. Create some standards so you don’t have your IT staff spinning their wheels and cursing your name for a bad policy.
8. Do time studies
My gut reaction to this one is two fold. First, get the data. Don’t assume you know the data. Get as much data as possible and focusing on the time it takes to do things is one of the best places to get data since this is incredibly important for users. Second, don’t shy away from the truth. If your EHR software has doubled the time it takes to do something, don’t be afraid to find that out. It’s better to know that there’s a problem and try to fix it than to let the problem fester because you didn’t want to know the truth.
7. Make sure IT shadows the clinicians
I’d probably take this one step further. If your IT doesn’t want to shadow the clinician, then you might want to find other IT. There’s no way that IT can help to design the proper system for the clinicians if they don’t understand the daily processes that the clinician has to do. Clinicians need to be willing to let IT in on what they do as well. It takes two to Tango and this is certainly true when you’re talking about implementing an EHR. It’s not nearly as pretty if they aren’t dancing together.
6. Use predicative analytics
I’m definitely not an expert on predicative analytics and its application, so I’ll just give you Shawn’s summary:
Predictive analytics are old hat in most industries. However, health care hasn’t put PA in a real forefront of the clinical practice. If you want your physicians (especially in a ED / UC) to be able to prepare for trends due to environment or time, make sure to have PA built into your EMR and easily available for all providers.
If you want to see my analysis of the other 101 EMR and EHR tips, I’ll be updating this page with my 101 EMR and EHR tips analysis. So, click on that link to see the other EMR tips.
As most of you know, I’m attending the Digital Health Summit at CES this year. As happens at most conferences, it’s hard to blog about the happenings at the conference while attending the conference. Particularly with all the CES traffic issues (it’s a literal zoo) and the packed CES Press Room. Although, I must admit that I haven’t found too many things all that impressive. More on that later.
They seriously have grass on the ground and a wood path through their booth. Plus, they have some of the only benches at CES (many really enjoyed those including myself). They’re also doing the pedometer promotion they did last year at CES and that they did at mHealth Summit, but this time you record your findings through the OptumizeMe app. I better win the iPad for all the walking I’m doing at CES. At least this time we’re not up against the exercise demo lady in the booth across from United Health Group. That was totally unfair (No, I’m not bitter).
Also, I’m surprised how few people know about SOPA. So I thought I’d do my small part to get the word out to more people. SOPA is an abomination that they’re trying to push through Congress. Here’s the tweet I sent out recently about it:
— John Lynn (@techguy) January 12, 2012
As you can see I’ve put the STOP SOPA badge on my Twitter icon and will be doing it on some other places, likely including the blog logo above. I’m good with legislation that actually works to stop copyright infringement, but SOPA does nothing to stop it and does a lot to really screw up the internet as we know it today. I hope others will join me in helping to stop SOPA. This weekend I’ll see if I can do a full post on why SOPA is bad if people are interested.
No related posts.
“The National Consortium of Breast Center's Board of Trustees has given their consent to the following position statement reflecting their stand on the issue of mammographic screening, in response to the recommendations made by the US Preventive Services Task Force.
National Consortium of Breast Centers, Inc.
Position Statement regarding the Mammography Screening Recommendations of the United States Preventive Services Task Force (USPSTF)
The National Consortium of Breast Centers (NCBC), the largest national organization devoted to the inter-disciplinary care of breast disease, requests the USPSTF rescind their new position on mammography screening.
The U.S. Preventive Services Task Force (USPSTF) published a paper detailing model estimates of potential benefits and harms to women screened for breast cancer with mammography.1 They provided an updated USPSTF recommendation statement on screening for breast cancer for the general population that alters currently accepted guidelines for women over 40 years old.2
The NCBC opposes the new guidelines as written. We cite specific evidence that screening mammography leads to early detection which leads to improved survival.3 In every country starting population screening, mortality declines coincide with onset of screening, not systemic therapy. These USPSTF models are not based on sound data, namely different denominators in the “harms” vs. “benefits” groups leading to invalid comparisons. Recent data from randomized controlled trials reveal significant mortality reductions evident approximately five years after screening programs were initiated. The reductions in age-adjusted, disease specific mortality (30-40%) since 1990 define screening program benefits not seen in the prior six decades. In the United States, these mortality declines continue at a rate of approximately 2% per year. 4 This mortality improvement counts as a remarkable public health achievement.
In addition, the USPSTF panel (comprised almost exclusively of primary care physicians) did not include breast imaging specialists nor was it represented by any of the multiple other specialists who collaborate to optimize patient outcomes. These specialists include pathologists, surgeons, medical oncologists, radiation oncologists, reconstructive surgeons, technologists, geneticists, nurse navigators, educators and others.
The NCBC does not understand the assumptions used by the USPSTF to value human life. We note the cited literature was selective and failed to acknowledge equally powerful and credible peer-reviewed literature, which supports currently accepted breast cancer screening guidelines.
We would also like to note that quality of life has a significant value, not just survival. It is well established that if we discontinue mammography for women in their 40’s, the cancers eventually detected will be larger, more likely need more aggressive surgery, more likely need chemotherapy and more likely lead to other significant socio-economic concerns.
The NCBC requests input into future guideline development and vows to work with government, scientists and industry to keep the process transparent and keep the focus on the patient. We recommend further efforts target screening, risk assessment, education and awareness regarding the implications of positive and negative screening findings. Funding for further research is imperative and supported by the controversy these articles have generated.
Finally, we note the USPSTF article states, “whether it will be practical or acceptable to change the existing U.S. practice of annual screening cannot be addressed by our models.”1 The NCBC agrees with this comment and finds their screening guideline suggestions unacceptable. The NCBC believes many women’s lives will be placed at risk if current screening guidelines are altered. We respectfully request the Task Force rescind their position on this specific women’s healthcare screening policy.
# # # #
About NCBC: The National Consortium of Breast Centers (NCBC) is the largest national organization devoted to the inter-disciplinary care of breast disease. In keeping with our mission, to promote excellence in breast care through a network of diverse professionals dedicated to the active exchange of ideas and resources including: 1) To serve as an informational resource and to provide support services to those rendering care to people with breast disease through educational programs, newsletters, a national directory, and patient forums; 2) To encourage professionals to concentrate and specialize in activities related to breast disease; 3) To encourage the development of programs and centers that address breast disease and promote breast health; 4) To facilitate collaborative research opportunities on issues of breast health; and 5) To develop a set of core measures to define, improve and sustain quality standards in comprehensive breast programs and centers.
1. November 17th edition of the Annals of Internal Medicine, Vol. 151, Number 10, 738-747.
2. November 17th edition of the Annals of Internal Medicine, Vol. 151, Number 10, 716-726.
3. Tabar L, Vitak B, Chen HT et al. Beyond randomized controlled trials: organized mammographic screening substantially reduces breast cancer mortality. Cancer 2001; 91: 1724-1731.
4. American Cancer Society, Breast Cancer Facts and Figures, 2009-2010.
All content and design © 2009 by the National Consortium of Breast Centers, Inc.”
Tonight, President Obama spoke to the nation about his plans for healthcare reform. He outlined how he plans to reform the current system and how he plans to pay for it including cutting over $100 billion worth of subsidies to insurance companies as part of Medicare.
Few key points:
He also touched upon the need to increase health IT and move way a fee for service system to a team-based approach to deliver healthcare.
Full Text: Obama’s Remarks on Health Care
(without question/answer session)
Following is a text of the prepared remarks by President Obama before his White House news conference on Wednesday, as released by the White House.
Good evening. Before I take your questions, I want to talk for a few minutes about the progress we’re making on health insurance reform and where it fits into our broader economic strategy.
Six months ago, I took office amid the worst recession in half a century. We were losing an average of 700,000 jobs per month and our financial system was on the verge of collapse.
As a result of the action we took in those first weeks, we have been able to pull our economy back from the brink. We took steps to stabilize our financial institutions and our housing market. And we passed a Recovery Act that has already saved jobs and created new ones; delivered billions in tax relief to families and small businesses; and extended unemployment insurance and health insurance to those who have been laid off.
Of course, we still have a long way to go. And the Recovery Act will continue to save and create more jobs over the next two years – just like it was designed to do. I realize this is little comfort to those Americans who are currently out of work, and I’ll be honest with you – new hiring is always one of the last things to bounce back after a recession.
And the fact is, even before this crisis hit, we had an economy that was creating a good deal of wealth for folks at the very top, but not a lot of good-paying jobs for the rest of America. It’s an economy that simply wasn’t ready to compete in the 21st century – one where we’ve been slow to invest in the clean energy technologies that have created new jobs and industries in other countries; where we’ve watched our graduation rates lag behind too much of the world; and where we spend much more on health care than any other nation but aren’t any healthier for it.
That is why I’ve said that even as we rescue this economy from a full-blown crisis, we must rebuild it stronger than before. And health insurance reform is central to that effort.
This is not just about the 47 million Americans who have no health insurance. Reform is about every American who has ever feared that they may lose their coverage if they become too sick, or lose their job, or change their job. It’s about every small business that has been forced to lay off employees or cut back on their coverage because it became too expensive. And it’s about the fact that the biggest driving force behind our federal deficit is the skyrocketing cost of Medicare and Medicaid.
So let me be clear: if we do not control these costs, we will not be able to control our deficit. If we do not reform health care, your premiums and out-of-pocket costs will continue to skyrocket. If we do not act, 14,000 Americans will continue to lose their health insurance every single day. These are the consequences of inaction. These are the stakes of the debate we’re having right now.
I realize that with all the charges and criticisms being thrown around in Washington, many Americans may be wondering, “What’s in this for me? How does my family stand to benefit from health insurance reform?”
Tonight I want to answer those questions. Because even though Congress is still working through a few key issues, we already have agreement on the following areas:
If you already have health insurance, the reform we’re proposing will provide you with more security and more stability. It will keep government out of health care decisions, giving you the option to keep your insurance if you’re happy with it. It will prevent insurance companies from dropping your coverage if you get too sick. It will give you the security of knowing that if you lose your job, move, or change your job, you will still be able to have coverage. It will limit the amount your insurance company can force you to pay for your medical costs out of your own pocket. And it will cover preventive care like check-ups and mammograms that save lives and money.
If you don’t have health insurance, or are a small business looking to cover your employees, you’ll be able to choose a quality, affordable health plan through a health insurance exchange – a marketplace that promotes choice and competition Finally, no insurance company will be allowed to deny you coverage because of a pre-existing medical condition.
I have also pledged that health insurance reform will not add to our deficit over the next decade – and I mean it. In the past eight years, we saw the enactment of two tax cuts, primarily for the wealthiest Americans, and a Medicare prescription program, none of which were paid for. This is partly why I inherited a $1.3 trillion deficit.
That will not happen with health insurance reform. It will be paid for. Already, we have estimated that two-thirds of the cost of reform can be paid for by reallocating money that is simply being wasted in federal health care programs. This includes over one hundred billion dollars in unwarranted subsidies that go to insurance companies as part of Medicare – subsidies that do nothing to improve care for our seniors. And I’m pleased that Congress has already embraced these proposals. While they are currently working through proposals to finance the remaining costs, I continue to insist that health reform not be paid for on the backs of middle-class families.
In addition to making sure that this plan doesn’t add to the deficit in the short-term, the bill I sign must also slow the growth of health care costs in the long run. Our proposals would change incentives so that doctors and nurses are free to give patients the best care, not just the most expensive care. That’s why the nation’s largest organizations representing doctors and nurses have embraced our plan.
We also want to create an independent group of doctors and medical experts who are empowered to eliminate waste and inefficiency in Medicare on an annual basis – a proposal that could save even more money and ensure the long-term financial health of Medicare. Overall, our proposals will improve the quality of care for our seniors and save them thousands of dollars on prescription drugs, which is why the AARP has endorsed our reform efforts.
Not all of the cost savings measures I just mentioned were contained in Congress’s draft legislation, but we are now seeing broad agreement thanks to the work that was done over the last few days. So even though we still have a few issues to work out, what’s remarkable at this point is not how far we have left to go – it’s how far we have already come.
I understand how easy it is for this town to become consumed in the game of politics – to turn every issue into running tally of who’s up and who’s down. I’ve heard that one Republican strategist told his party that even though they may want to compromise, it’s better politics to “go for the kill.” Another Republican Senator said that defeating health reform is about “breaking” me.
So let me be clear: This isn’t about me. I have great health insurance, and so does every Member of Congress. This debate is about the letters I read when I sit in the Oval Office every day, and the stories I hear at town hall meetings. This is about the woman in Colorado who paid $700 a month to her insurance company only to find out that they wouldn’t pay a dime for her cancer treatment – who had to use up her retirement funds to save her own life. This is about the middle-class college graduate from Maryland whose health insurance expired when he changed jobs, and woke up from emergency surgery with $10,000 in debt. This is about every family, every business, and every taxpayer who continues to shoulder the burden of a problem that Washington has failed to solve for decades.
This debate is not a game for these Americans, and they cannot afford to wait for reform any longer. They are counting on us to get this done. They are looking to us for leadership. And we must not let them down. We will pass reform that lowers cost, promotes choice, and provides coverage that every American can count on. And we will do it this year. And with that, I’ll take your questions.
The ONC policy committee on meaningful use has published an updated matrix on the subject. It can be found here.
Someone in the GOP needs to learn how to use Microsoft Visio, or the Democrats need to come up with a better plan for improving our healthcare system.
If you believe this nightmare chart created by Congressman Kevin Brady’s office (R-Texas 8th District), then you’ll need a PHD in obfuscation to figure out what the Democrats are planning. More likely, however, is that Brady is painting an overly bleak picture of what a government plan might look like.
Jokes aside, as this battle continues to play out, both sides are sticking to their guns; however, the Obama administration believes it has the trump card: 60 votes. Bloomberg News is reporting that “Obama Open to Partisan Vote on Health-Care Overhaul.”
We’ll follow how this plays out, and keep you apprised of any interesting happenings.
UPDATE July 22, 2009:
A graphic designer, Robert Palmer, took it upon himself to “correct” the republican nightmare chart and made it significantly easier to understand. The updated chart, along with a PDF can be found on Mr. Palmer’s Flickr page. He also penned a note to Representative Boehner:
Dear Rep. Boehner,
Recently, you released a chart purportedly describing the organization of the House Democrats’ health plan. I think Democrats, Republicans, and independents agree that the problem is very complicated, no matter how you visualize it.
By releasing your chart, instead of meaningfully educating the public, you willfully obfuscated an already complicated proposal. There is no simple proposal to solve this problem. You instead chose to shout “12! 16! 37! 9! 24!” while we were trying to count something.
So, to try and do my duty both to the country and to information design (a profession and skill you have loudly shat upon), I have taken it upon myself to untangle your delightful chart. A few notes:
- I have removed the label referring to “federal website guidelines” as those are not a specific requirement of the Health and Human Services department. They are part of the U.S. Code. I should know: I have to follow them.
- I have relabeled the “Veterans Administration” to the “Department of Veterans’ Affairs.” The name change took effect in 1989.
- In the one change I made specifically for clarity, I omitted the line connecting the IRS and Health and Human Services department labeled “Individual Tax Return Information.”
In the future, please remember that you have a duty to inform the public, and not willfully confuse your constituents.
California 53rd District
The Certification Commission for Healthcare Information Technology (CCHIT) has responded to the Office of the National Coordinator’s recently released Meaningful Use matrix [pdf]–and responded with a vengeance.
The bottom line: “CCHIT recommends that meaningful use measures be either simplified for 2011, or postponed until 2013.”
Its recommendation was formed by comparing the CCHIT 2008 criteria against the meaningful use matrix prepared by the National Coordinator’s Workgroup on Meaningful Use and finding that while many of the 22 proposed objectives are fully supported by the current certification, at least 8 have minor to major gaps with the CCHIT 08 criteria.
The commission argues that “the lag between a decision to invest in EHR technology and its full, meaningful use in a provider organization is 1 to 2 years at best, and more typically, 3 to 5 years,” and for this reason it recommends postponing the 2011 measures until 2013. It isn’t that some EHRs do not currently meet the standards drafted for 2011 (MTBC’s EMR does), it’s that CCHIT criteria does not currently cover or test for all of the proposed 2011 measures. Additionally, CCHIT does not believe that the marketplace is fully ready to support some of the reporting standards outlined in the draft.
As always, we will continue to cover this story as new developments arise and as key shareholders continue to weigh in with comments and responses.
Why don’t you let us know what you think? Should the 2011 measures be postponed until 2013?
When you buy a car, the manufacturer usually offers some kind of warranty on your purchase e.g. bumper-to-bumper coverage for 50,000 miles or 5 years, whichever comes first. Or coverage for 100,000 miles for the power train and 50,000 miles bumper-to-bumper. Some are now offering oil changes for life, free car washes, dry cleaning, or the salesman will pick up your kids from soccer practice if you make a purchase now. Ok, maybe they won’t pick up your kids, but you will please! buy now?
Francois de Brantes, a nationally known advocate of health care quality, is hoping to bring warranties to healthcare. He and a few associates penned an article in Health Affairs describing the benefits of a new payment model for physicians which may inspire physicians to improve patient outcomes by putting their skin (and money) in the game.
The warranties which de Brantes proposes–Prometheus Payment as he’s called it–flip the current medical billing payment model on its ear. Prometheus Payment offers set fees to providers for recommended services, treatments and procedures. However, unlike the current system where all fees are covered by third-party payers, the provider now becomes a party in the payment process by assuming fiduciary responsibility for outcomes–should patients develop an avoidable outcome, providers become responsible for half the costs. The warranty is based on the costs of these avoidable outcomes and is risk adjusted for elderly or frail patients.
de Brantes and his co-authors explain that “the warranty concept has filtered into the self-pay portion of health care, such as corrective eye surgery, general cosmetic surgery, and dental care, which are often based on a global fee that includes any necessary rework by the provider. But it has taken much longer for warranties to appear in the third-party payer system.” They argue that with this global-fee model, overall costs in the healthcare can be reduced while improving outcomes for patients by making (and paying) the provider for any expenses before, during, and after the procedure.
The abstract to the Health Affairs article reads:
How health care providers get paid has implications for the delivery of care and cost control; the topic is especially important during an economic downturn with persistent growth in health spending. Adding “warranties” to care is an innovation that transfers risk to providers, because payment includes allowances for defects. How do such warranties affect patient care and bottom lines? We examine a proposed payment model to illustrate the role of warranties in health care and their potential impact on providers’ behavior and profitability. We conclude that warranties could motivate providers to improve quality and could increase their profit margins.
I find two points interesting.
This whole idea adds a new wrinkle to medical billing. As your billing service, we’d not only be incentivized to help you collect more money but also provide you tools to provide better patient care. Great news for you, we have a CCHIT-certified EMR which provides just the tools you need. Find out more here.
We will keep you posted if this model crops up at any payers near you.
Read more about Prometheus Payment:
On June 16 the Workgroup on Meaningful Use presented its recommendations on the definition of Meaningful Use. They prepared a preamble describing their overall path to this definition and a matrix to organize their recommendations for each year. For those who have been under a rock for the past 6 months, “meaningful use” is the defining measure by which the incentive payments included in the American Recovery and Reinvestment Act (ARRA) will be determined.
With this working definition, vendors, physicians, and hospitals can better plan for implementation and delivery of technology and services to achieve the measurable goals outlined by the Workgroup.
Meaningful Use for Whom?
First it is important to note that “meaningful use” will have different meanings for hospitals and for groups in private practice. The preamble states “some features and capabilities will be recommended as required in an ambulatory setting before similar functions are expected to be widely used in the hospital.” This means that proving “meaningful use” will be a more rigorous exercise for private practices than it is for hospitals. However, private practices have a broader range of options and lower barriers of entry (cost, availability of technology, shorter implementation time frames, etc) when it comes to implementing technologies which can deliver “meaningful use.”
Let’s go over some of the measures which are planned for 2011 and look at some examples of each item. More details for each of the items below can be found in the matrix. John Halamka, MD of the CareGroup Health System of Harvard Medical School and the chairman of the US Healthcare Information Technology Standards Panel (HITSP) said in Healthcare IT News that this matrix still needs to be populated with the most up to date standards and an implementation guide. These details will help vendors and physicians alike ensure that their software meets these measures. Expect this in July.
Each of the items below has associated metrics which will need to be reported to verify meaningful use; for example, one of the objectives calls for reminders to patients for preventive/follow-up care. In order to prove meaningful use, the EMR application must be able to provide a reporting of the percentage of patients over 50 with annual colorectal screening. Keep in mind that each of the items below has an associated measure (found in the matrix) which will require reporting to an authorized agency.
Items marked with a Yes! indicate that the MTBC EMR helps your practice meet or exceeds these measures.
Now that you know the definition of Meaningful Use what should you do now? The answer is simple: get an EMR. Ok it is not that simple, but you will be happy to know that you have plenty of options in the marketplace. Dr. Halamka writes, “Hospitals and Clinician offices now know what is expected for 2011, so the time is now to begin your software implementations.” Never before have there been so many EMRs which provide such a high level of functionality and interoperability. Today’s major differentiators are not function, but price and service.
MTBC Can Help
MTBC’s CCHIT certified EMR (free to MTBC medical billing clients) can help your practice meet the goals of 2011. Click here to find out more about MTBC’s unified medical billing and practice managagement services.
However, if “free” is not your bag, you have plenty of other options beginning at the $1,000 range and your imagination as the only limit. Vendors have become very creative in their pricing with new options emerging such as monthly subscriptions, charges for each fax sent from the EMR, hosting fees for web-based applications, fees for technical support by email, server replacement plans (a la replacement plans sold by big box stores), 50¢ per 100MB of storage, and many others.
MTBC’s EMR rivals those of its competitors because it is implemented, supported, and updated completely free of charge of its premium medical billing clients. To find out more about how MTBC’s EMR can help you meet the goals of Meaningful Use, request a demo today and, if you are not currently an MTBC billing client, find out how you can download a free trial.
Watch this space for more information regarding meaningful use and its impact on the healthcare IT.
Doctors’ adoption of health information technology doubled in two years, according to a new report, Department of Health and Human Services Secretary Kathleen Sebelius released Wednesday. Sebelius also announced extension of the meaningful use qualification date to 2014. See link for more info – http://www.healthcareitnews.com/news/hhs-extends-mu-stage-2-deadline-spur-faster-emr-adoption?topic=01,08
The survey I posted earlier has now been completed – here are the results.
High physician fees, rather than factors such as practice costs, volume of services or tuition expenses, were the main drivers of higher U.S. healthcare spending and physician income, according to research presented in the September issue of Health Affairs.
The study, conducted by Miriam J. Laugesen, PhD, and Sherry A. Glied, PhD, both of the Mailman School of Public Health at Columbia University in New York City, found that in some cases, physicians in the U.S. are paid as much as double their counterparts in other countries. There is also a larger gap between fees paid for primary care and fees paid for specialty care, particularly orthopedic surgeons, in the U.S. compared to other countries evaluated by the study.
Fees paid by public and private payors for primary care office visits and hip replacements were compared in six countries: Australia, Canada, France, Germany, the U.K. and the U.S.
Laugesen and Glied found that primary care physicians in the U.S. were paid, on average, 27 percent more by public payors for an office visit, and 70 percent more by private payors for an office visit, compared to the other countries. The largest difference in fees paid between countries was for hip replacements. Physicians in the U.S. were paid 70 percent more by public payors and 120 percent more by private payors for these procedures as compared with physicians in the other countries.
Across the fees analyzed by the study, the biggest disparities in pay to U.S. physicians existed on the private side. Fees paid by private insurers in six markets in the U.S. averaged about 33 percent above Medicare rates for primary care and 50 percent above Medicare rates for hip replacements.
“Our analysis suggests that policymakers in all countries need to consider how differential prices paid by both public- and private-sector payors to specialists influence specialty choices,” wrote the authors. “Furthermore, this analysis suggests a need for greater standardization of cross-national data on the nature of physician services provided, fees, education and incomes to allow ongoing comparative research on the relationship between prices and healthcare spending growth.”
Incomes were also higher for U.S. primary care and orthopedic physicians compared to their foreign counterparts.
The authors said other factors thought to contribute to physicians’ fees, such as high medical education tuition costs for American physicians or increased work volume, could not fully explain the disparity in fees when compared across the countries.
“Although the tuition cost of medical education in the U.S. borne by individuals is substantial, it cannot fully account for the observed differences between the earnings of U.S. physicians and physicians in all other countries,” wrote Laugesen and Glied.
For the services examined by the study, higher physician incomes did not appear to be due to a higher volume of services, though the authors acknowledged the rates of other procedures not studied may be higher and contribute to the elevated fees and incomes.
One possible explanation offered by the authors for the high U.S. physician fees was the notion that higher fees may reflect the cost of attracting highly skilled candidates. When physician fees in each country were compared to the mean incomes of the top 1 percent of households within that country, the results were broadly consistent, suggesting higher U.S. fees were the result of a “society with a relatively more skewed income distribution,” according to Laugesen and Glied.
The New York Times (9/6, B1, Freudenheim, Subscription Publication) reports, “Under heavy pressure from government regulators and insurance companies, more and more physicians across the country are learning to think like entrepreneurs.” One result is the rapid growth in joint M.D./M.B.A programs to 65 at present with an estimated 500 students. Some intersperse business courses with medical courses while others have students complete their medical training and add a year or more of business education. “Dr. Barry R. Silbaugh, chief executive of the American College of Physician Executives, a professional society that provides medical education courses and career counseling, said more start-ups were being run by doctors.” He explained that some “are focused on adapting technology to health care, not just electronic medical records,” adding, “The use of social media is of great interest to many younger physicians, and so is health care analytics.”
Like the dot-com bubble, the EHR bubble—nurtured by the government incentives—will not last. As I look at what’s happening in the market, it becomes apparent that at some point in the not-too-distant future, the EHR bubble will pop and many vendors will face financial challenges that will lead to their demise.
Several market factors will come into play, including:
To understand how these factors will affect EHR vendors, it is important to understand how such companies typically raise money and what kind of “hockey-stick” growth projections they made to attract investors.
Missed growth projections; continued expenses for implementation, support, and ongoing upgrades; and diminishing government incentives will leave many companies unable to find investors willing to fund their future growth.
There will be market consolidation, and financially strong companies will acquire distressed companies for pennies on the dollar.
…To read the full story, see HIStalk Readers Write.
HHS has made it official—Stage 2 of meaningful use will be pushed back to 2014. The announcement by HHS Secretary Sebelius came as no surprise, following as it did the recommendation made by the HIT Policy Committee and the endorsement by ONC head Farzad Mostashari. The change only affects providers whose first incentive payment year is 2011, since they are the only providers who would be subject to Stage 2 regulations in 2013 had the delay not been implemented—everyone was already entitled to 2 years of meaningful use at Stage 1.
What I find interesting about all the hoopla that has accompanied the announcement is the spin the government put on the decision. According to the press release from HHS, “To encourage faster adoption, the Secretary announced that HHS intends to allow doctors and hospitals to adopt health IT this year, without meeting the new standards until 2014. Doctors who act quickly can also qualify for incentive payments in 2011 as well as 2012.”
Isn’t it a bit late for a provider to decide to adopt health IT this year? In reality, this announcement is too last-minute to change any adoption-related behavior or to accelerate EHR adoption. The announcement continued, “Perhaps most importantly, we want to provide an added incentive for providers attesting to meaningful use in 2011.” Apparently, the goal is to accelerate attestation rather than adoption—to encourage physicians who were already using certified EHR technology in a “meaningful way” to attest and to collect an incentive payment this year, instead of holding off attesting until 2012. This would create a potential PR benefit for the incentive program, which currently boasts nearly 115,000 registered providers, but reports that only 10,155 (9%), have successfully attested.
The benefit of the schedule delay accrues only to the early adopters, who now can earn 3 years of incentives under the less stringent requirements of Stage 1 (only, however, if they are willing to forego their 2011 Medicare ePrescribing bonuses—not a worthwhile trade-off for high-revenue physicians with large Medicare volumes). In its statement, HHS acknowledged the pushback from providers regarding how challenging even the Stage 1 requirements are. Perhaps, it would truly spur program participation and EHR adoption if all providers—not just the early adopters—were entitled to 3 years of meaningful use under Stage 1 rules. Also, if CMS has so little confidence that physicians will succeed at Stage 2, shouldn’t it reconsider how much it plans to raise the bar?
Last week’s EMR Straight Talk post, “Are EHRs Being Oversold,” hit a nerve, judging by the number of readers and the volume and intensity of comments submitted by physicians. Sadly, for every one of the physicians who took the time to write, there are scores of others enduring similar experiences. The following excerpts from their comments are reflective of their frustrations:
Every one of these stories breaks my heart as a staunch EHR proponent—particularly since the situations could have been easily avoided.
The Root of the Problem
The problem lies in the EHR selection process. When it comes to dispensing medications, for example, no physician prescribes without knowing the success rate for that particular drug for that particular type of patient and problem being addressed. Yet, typically, physicians do not make EHR purchase decisions in the same way that they make clinical decisions—using empirical evidence and data to predict outcomes.
I’d wager that for each of the disillusioned physicians above, the EHR selection process was nearly identical:
Why does such an exhaustive and time-consuming selection process so often lead to failed EHR implementations?
Preventing an EHR Failure in Your Practice
To prevent an EHR failure in your practice, the flawed selection process must be altered. The first thing to understand is that the rosy experience of one or two handpicked vendor references will not guarantee a similar experience for you and your colleagues. If a vendor has sold its EHR to 100 practices and has as few as 5 successful implementations, you will be referred to one of these 5 practices. A visit to 1 or 2 of these 5 successful practices may leave you with a warm and fuzzy feeling and the expectation that, because they were successful, your success is virtually assured. In this case, however, your real probability of success would only be 5%.
Separating the Wheat from the Chaff
So how do you quickly eliminate vendors with lackluster success records before you and your staff waste hours watching slick sales demonstrations of sexy software with “must-have” features? Separating the wheat from the chaff is simple—just ask all your initial set of EHR vendors for lots of references. If a vendor cannot produce at least 2 references for each year they have been in business, run the other way. Do not accept any excuses for being unable to provide you with the number of references that you seek. (A common excuse is that the vendor wishes to protect the privacy of its clients.) If they had lots of references, they would give them to you in a heartbeat—happy customers are always willing to show their successes to others.
Many of the initial vendors chosen will not be able to produce a satisfactory number of references. This should narrow down the number left for you to consider, and it will save a tremendous amount of valuable physician and staff time.
Statistically Significant Reference Checking
At this point, your list of vendors will likely include just the one or two that have provided you with a meaningful reference list. You may have to accept the bias created by the fact that the references are carefully handpicked by the vendor(s), but it is imperative that you do not limit your inquiries to the specific physicians identified by the vendor. Typically, these are the practice administrator and one or two physicians who had spearheaded the EHR purchase for the practice; as a matter of pride, they are more likely to paint a rosy picture of the EHR than to acknowledge its shortcomings. The only way to avoid this trap is to speak with other physicians at the reference practices. This is easy to do. When you get the reference list from an EHR vendor, ask them to include the practice websites, then randomly choose physicians to call from the physicians’ bio pages. These physician-to-physician calls should be short (only 10 minutes each) and you should ask specific questions about cost, efficiency, and number of patients seen. The American Society of Cataract and Refractive Surgery (ASCRS) has an excellent set of questions on page 5 of their EMR selection guide .
How much of your time should this type of random reference checking take? Not much! Ten 10-minute calls (less than 2 hours of time) to randomly chosen physicians will yield more valuable data on your chances of success than having a slew of vendors demo their products to your doctors and staff for hours on end. Only after having conducted the due diligence described above will you be able to derive real value from spending your time seeing demos—because you will only be seeing demos of the one or two EHRs that you now know are likely to deliver success.
I am a firm believer in the tremendous value that the right EHR can deliver to physicians, so the historic dissatisfaction with the EHR industry—as reported in studies and anecdotal conversations—has long disturbed me. The alarming intensity of this dissatisfaction was brought home by visitors to my company’s booth during the recent AAO (American Academy of Ophthalmology) meeting.
I was truly appalled by the abject frustration and anger expressed by numerous physicians about their EHRs. One visitor described his experience by saying, “It has taken the joy out of practicing medicine.” Another said that he felt like he should put a picture of his face on the back of his head so that his patients could see him—because he was forced to focus on the computer and enter data while the patient provided information. Physicians universally complained about the “productivity-killing” impact.
Why is this so? I know there are good EHR products in the market that physicians enjoy using and that enhance, rather than reduce, their productivity. Why are physicians not more successful in finding these?
The answer is that EHRs are being oversold. There are many EHRs that are marvels of software, capable of doing incredible things, but the selection process that physicians typically employ is flawed, and the sales process capitalizes on this shortcoming. The salesperson dazzles them with a demo, or they take prospective purchasers to see a physician—typically just one or two—who adeptly uses the software. This creates a false sense of ease-of-use, and the physician prospect leaves the site visit expecting that he or she will be able to use the EHR just as successfully. But not all physicians are alike—they may all be very intelligent and have tremendous medical expertise, but they are not all equal in technological inclination or skills. Their success—or lack thereof—with a particular EHR will vary significantly.
This brings us back to the importance of doing due diligence—something I have talked about before. Call and/or visit a variety of physicians who represent a wide spectrum of proficiency. Go to the reference practice’s website and select physicians on your own—don’t rely on the vendor’s selection. Ask the kind of questions listed in the last EMR Straight Talk. This is the only way to increase the odds of a successful EHR experience, and to avoid making a painful and costly mistake.
I’ve written frequently about the unique needs of specialists and how these have been overlooked by the government and by EHR vendors. Since many ophthalmologists are heading off this week to the AAO (American Academy of Ophthalmology) Annual Meeting in Orlando, I thought it appropriate to comment on the proactive advocacy and advisory role that this particular professional society has adopted on behalf of its members, and to encourage other academies to step up their efforts similarly.
AAO has been quite active on the meaningful use front. This week’s HIT Policy Committee’s Meaningful Use Workgroup meeting focused on how make meaningful use more meaningful for specialists in Stage 3. AAO was one of only two specialty societies represented in the public comments at the end of the meeting—the Academy’s representative pleaded that measures irrelevant to ophthalmology be replaced with those that would add value for these specialists, and offered the Academy’s assistance to accomplish this.
In addition to providing its members with otherwise unavailable, ophthalmology-specific direction on how to meet meaningful use, AAO has also offered much-needed guidance regarding the selection of an appropriate EHR for ophthalmologists—meaningful use aside. Recognizing that their unique specialty-specific workflow and data needs are not effectively addressed by most EHRs—because of the typical primary-care focus—AAO charged its Medical Information Technology Committee with the identification of a set of ophthalmology-relevant EHR specifications. A group of authors led by Michael Chiang, M.D., identified a set of features and attributes that ophthalmologists would find particularly valuable, and published their recommendations in an article titled “Special Requirements for Electronic Health Record Systems in Ophthalmology.”
While features and functionality are important, feedback from colleagues who actually use the EHRs is even more critical. The advice that AAO has given its members on how to make the most out of site visits will serve all physicians well, regardless of their specialty, and I am therefore sharing it with you below. It is reprinted from the publication “Electronic Medical Records: A Guide to EMR Selection, Implementation, and Incentives.”
ASK COLLEAGUES THE RIGHT QUESTIONS:
EHRs are here to stay, and will play an increasingly important role in medical practices. A major investment, EHRs can dramatically impact practice operations and productivity—positively or negatively. It is my hope that, like AAO, the medical academies will use their clout and speak out more aggressively to protect the interests of their members.
The Centers for Medicare and Medicaid Services (CMS) yesterday clarified that a 1988 law setting up national quality standards for medical testing labs does permit the labs to electronically exchange test data, an essential feature of the administration’s health IT adoption plan.
In issuing guidelines on the Clinical Laboratory Improvement Amendments (CLIA), CMS aimed to clear up confusion about the impact of the law on fledgling health information exchanges and networks.
“We have the concern that the interpretation of CLIA has sometimes stood in the way of easy info exchange,” said Dr. David Blumenthal in remarks made yesterday at the Healthcare Information and Management Systems Society annual conference in Atlanta.
In some cases, for instance, providers said they believed the law permitted only physicians who ordered a test to receive the results, according to hearings conducted last year by a panel of the Health IT Policy Committee, which advises Blumenthal.
In its revised guidance, CMS said lab results could be sent to the ordering physician as well as others designated by the physician. That includes providing patients access to their lab data unless a state specifically prohibits it, CMS said.
Experts predict a surge in the number of physicians using electronic medical record systems
By dangling as much as $20 billion in front of physicians to encourage their adoption of electronic medical record (EMR) systems during the next few years, Congress has created a new and expensive challenge for the nation’s clinical laboratories. That challenge is the need for every pathology laboratory to establish a high-function interface from its LIS to the office-based physician’s EMR.
John Halamka presents his ideas about the major issues for 2012..
ICD10 - John predicts 25% of IT capacity will be consumed by ICD10 this year. Not good...
Meaningful Use Stage 2 including inpatient clinical documentation - now this is exciting. Potential criteria will likely include improvements to clinical records that improve care coordination and communication between providers. John suggested use of templates and social-networking like group documentation.
ACO Planning - The reform changes for ACOs will include focus on prevention and wellness. New business intelligence (BI) and clinical decision support (CDS) capabilities will be helpful in meeting these goals.
Compliance - Compliance issues will include "conflict of interest tracking, learning management systems for compliance education, and enhanced revenue cycle systems that provide decision support."
Security - yes, the past year had a long list of data breaches, malware, and mobile devices so security of PHI must be improved, particularly if we intend to move clinical decision support to the bedside or engage in Health Information Exchanges.
NPR topics presents a summary of the impact to the Affordable Care Act in a discussion between Audie Cornish and Noam Levey of the Los Angeles Times.
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Recently the ONC posted on the Health IT Buzz Blog about the "challenges providers face in achieving Meaningful Use of electronic health records (EHRs)."
The concept of "useability" has long been known in other industries where new technology or applications enter the workplace. Some time ago I wrote about usability of health IT, however I expanded the definition to include a few more "E-bilities" as shown in the following graphic contained in the post: Part 4 of The Value of the Internet for Improving Healthcare.
This is the last post in the series and it focuses on capabilities, or "e-bilities" of technology to improve healthcare. Regardless of the mode of use (e.g. email or internet), technology must be easy to use, secure, reliable, and accessible.
For the past year, the SHARPC-Project 1 has focused on making use of technology easier for clinicians. One ONC staff member, Jacob Reider, MD had some interesting comments that focused on "The User Experience." His comments spanned the continuum of User Experience with a framework for how tools and/or applications can/should evolve.
Functional (it does what it is claimed to do)
Reliable (it works consistently)
Usable (it works in a way that is consistent with the user’s expectations)
Meaningful (it does something important or valuable)
Pleasurable (it is enjoyable to use)
So, I will end with one thought. Even if the system meets "Useability" standards for clinicians, achieving quality health data analytics still requires that accurate, timely and quality data is entered into the EHR avoiding the Garbage In-Garbage Out phenomenon.
This article in Healthcare IT News caught my eye. A white paper written by the Care Continuum Alliance described significant market movement toward accountability and value driven healthcare outcomes as a result of collaborative models, such as ACOs. However, there are 8 key issues that could affect population health management in 2012:
Each of these items contains a plethora of complex issues that will require agreement, alignment, and cooperation between distinct parties. In order to simplify my thoughts on this topic, I offer the following.
Accountable care and collaborative models certainly provide the opportunity with electronic records to capture and disseminate research and/or de-identified clinical data for surveillance. The link to "accountability" also provides the impetus to develop predictive analytics, a personal favorite.
It is well known that mobile technology, including smart phones, are changing the nature of "computer use" and internet access. According to the article the author stated that "a patient-centered, consumer-empowered, pull-rather-than-push model will dominate, with social media in a position of importance."
Reducing re-admissions? Well, we should already be doing this, unfortunately the quality of healthcare in certain situations, or the variable factors in a patient's condition and care makes this a tough goal to reach all the time. However, Medicare tracking is looking a 3 conditions - heart failure, acute myocardial infarction and pneumonia.
Finally, the other items tout the value of competitive forces in healthcare resulting from support of "insourced programs," development of health insurance exchanges in 2014, and the single idea that is near and dear to a nurse - support for prevention and wellness!
Prevention and wellness has not been a priority for most clinicians due to its non-reimbursable status. Let's hope that changes. Since the Prevention and Public Health Fund is under discussion, Medicare added annual wellness visits and expanded coverage of obesity and cardiovascular disease prevention services.
2012 brings a year of great change and challenge. Best wishes to all for a safe, happy, and prosperous new year!
As clinicians, do we ever wonder how excellent patient care can be achieved? Do we become too involved in our deadlines, our tasks, or our own needs and lack the time to reflect and to improve? It is certainly an issue in today's healthcare environment as the delivery of care changes in the path to Meaningful Use...
Well, I watched this video today, posted by Brian Ahier. It is an epic portrait of how one individual came up with an idea that would provide quality care/experience to customers.
Click this link to watch the video - a moving and heart-felt story.
May you have a Happy and Safe Holiday Season!
The HIPAA Survival Guide's Privacy Rule Under HITECH Webinar will help get you up to speed on how the HITECH Act has impacted the HIPAA Privacy Rule and how marketplace trends are impacting it as well. The webinar will walk you through the Privacy Rule and discuss the effect that the HITECH Act has had under three major sections: 1) uses and disclosures of PHI contained in sections §164.502 through §164.514; 2) the Patient's Bill of Rights contained in sections §164.520 through §164.528; and 3) the Administrative Requirements contained in Section §164.530.
Date: December 13, 2011.
Time: 2:00 to 3:30 EST.
To register CLICK HERE.
Looking for best of breed HIPAA Training?
To stay current on the HITECH Act and its quickly changing regulatory scheme visit the HITECH Survival Guide website and/or sign up for our free monthly compliance newsletter. Also, check out our FREE EHR Checklist.