LighthouseView

February 16, 2012

Date Changes Could Be Coming For A Number of Federal HIT Initiatives

Filed under: CMS, EHR Incentive, ICD-10, PQRI — HankMayers @ 1:55 pm

As many of my followers probably already know, the AMA recently wrote to HHS Secretary Siebelius and House Speaker John Boehner to complain over the numerous federal HIT expectations (PQRS, E-Prescribing, EHR Incentive, ICD-10 conversion, etc) and how they are cumulatively creating an unmanageable burden for physicians. The AMA was smart enough to not say they object to any of these undertakings. They simply insisted that the government make some choices as to priority, etc.

Even for those of us who are strong supporters of extensive application of HIT to improve the quality and effectivness of health care, it was understood that a great deal was indeed being expected of an a fairly conservative industry. The AMA letter was hardly a surprise, though its timing was a bit later than I expected.

Many of us know that statements made in governmental circles usually require some analysis to be able to undertand what they truly mean. The relevant portion of the official released statement from HHS is as follows:

“ICD-10 codes are important to many positive improvements in our health care system,” said HHS Secretary Kathleen Sebelius. “We have heard from many in the provider community who have concerns about the administrative burdens they face in the years ahead. We are committing to work with the provider community to reexamine the pace at which HHS and the nation implement these important improvements to our health care system.”

With no disrespect intended, in government-speak, a “re-examination” can mean lots of things. Some adjustment MUST result to at lease confirm that the government was listening. The pressure from the other direction is the oft-referenced need to “bend the cost curve in health care.” The 17% of GDP that is health care, plus the continually growing annual health care cost increases at the federal and state levels are truly unsustainable. HIT is universally seen as a significant factor in costs reduction and care quality improvement. So HIT implementation MUST keep moving, and moving at an agressive pace.

So, it is my view that physicians that are hoping for a major let-up in the pace and expectations for HIT innovation are going to be sorely disappointed. How HHS finally responds here is going to be a very interesting illustration of statesmanship at the national level. And, HHS cannot overlong analyze this. All of us need a fairly quick decision.

November 7, 2011

Secrets For Coming Up With the HIT Solution With the Best Fit

Filed under: EMRs, Uncategorized — HankMayers @ 10:46 am

Recently, I got into an exchange with a colleague that was bemoaning the fact that healthcare entities frequently find thyemselves having to adjust to a vendor’s HIT product, rather than being able to use a solution specifically built for their needs.

I thought I’d further share my thoughts here on my blog…..

The conundrum that the industry faces is that any vendor HIT product has to be built with a vision of what the users need. The “users” in this case are the entire market. As a for instance, in the ED space, that means such products are built for most EDs of a particular scale. Yet such generalizing also means that the design is based upon design presumptions. If the vendor worked with an empowered user design team (regrettably, often it is a single medical adviser, or the product author), we can expect a design that will make sense to most of that market.

Even so, there will be compromises and the ultimate users will have to adapt to the product nonetheless. Otherwise, modifications to the product must be made to fit a particular customer’s ED, and either the customer takes over the maintenance of this customized product, or outsources this maintenance work to the vendor. As of right now, very few healthcare organizations are willing to make this kind of financial commitment. And given the current healthcare cost containment policy fixation (government, employers, and consumers), this financial limitation will be with us for a very long time.

It is my view that the upshot of all of this is that successful implementations of vendor products will require: (1) investment of serious/substantial effort by users in the evaluation selection of the vendor product (to find the least-disruptive solution), and (2) careful/adequate current state and future state process analysis by the clinical side under the watchful eyes of the CMO/CNO/CMIO, and (3) realistic resource (clinical staff time and funding) allocation so that the clinical organization is truly ready for the implementation.

There is an all-too-frequent tendency for the clinical side to simply pile on these kinds of assignments to current clinical staff who get no relief from ongoing care delivery duties. Because there are ALWAYS daily operational crises in healthcare, adding project duties to staff guarantees that the organization will not be adequately ready for implementation.

When we consider the nature of these business-intensive technologies, it is only natural that the “business” (clinical organizations) side be expected to make this kind of investment of its resources. However, most of our organizations are not used to thinking about information technology projects in this way. And, it’s not like the clinical organizations are flush with staff. Nonetheless, this is one of the implied commitments that are unavoidable with the newer, more valuable, clinical HIT solutions.

October 25, 2011

Cudos to GE for their forthright handling on MU problems

Filed under: Uncategorized — HankMayers @ 3:56 pm

It seems that the EHR market has experienced its first acknowledged serious customer problem, and the vendor, GE, has shown integrity in dealing with it.

According to Joseph Conn, at Modern Healtcare.com, a GE Centricity customer discovered that the MU reporting feature of their newly-implemented EHR was not working correctly and generating innaccurate attestation reports. GE, subsequently also discovered errors in data submission/recording for some patient demographics in the EHR.

After assessing the client’s concern, GE’s Vice-President, Michael Frigueletto, promptly advised its clients of the finding, and also advised the ONC and CCHIT. He has promised a fix by the end of November.

There will surely be other vendor missteps along the road to meaningful use. Let’s hope that everyone follows GE’s example of quickly and candidly responding to such events.

Comments anyone?

September 26, 2011

The CY2011 EHR Incentive Payment Deadline Fast Approaching

Filed under: CMS, EHR Incentive, Meaningful Use — HankMayers @ 10:57 pm

Well, for eligible practitioners (EP) who would like to earn a 2012 EHR Incentive payment, they’d better be meaningfully using their EHR. That’s because starting on October 3, 2011 is the final 90-day window to satisfy the Meaningful Use criteria to earn an incentive payment for 2012 in either the Medicare or Medicaid programs.

If the EP fails to meaningfully use its EHR for all 90 days to 12/31/11, they’ll need to try again. Truth is, if the EP discovers that s/he fails to meet the criteria during part of that window, s/he can start over then – reset the clock. The EP’s 90 window is not limited to any particular window of time. That is, it does not have to neatly fit an annual quarter or whatever. It is 90 days after you set your start day.

So, if a late-starting EP trips during this last quarter of the year, the only loss is the cash flow of the practice. While that can be a serious consideration for the practice, they are not looking at any federal funding loss – just a delay until they get their meaningful use performance nailed down.

By the way, if a Medicare provider waits till 2012 to implement, and waits to start meaningfully using the EHR on 10/1/12 AND then fails to satisfy the Meaningful Use criteria for the entire 90 days to 12/31/12, then his 1st payment will be earned after 2012, and that means he will receive $5,000 less over the 5 year window than if he had met Meaningful Use by 2012. This loss only happens in the Medicare program.

August 10, 2011

Why I Am Passionate About Healthcare Information Technology

Filed under: EMRs — HankMayers @ 11:19 am

As most of my followers know, I have spent the past few years engaged in motivating physicians in adopting electronic medical records and particiapting in opportunities to electronically integrate their care (and their electronic records) with other practitioners caring for their patients. Like most people in this field, the persisting lower-than-predicted adoption rates can be rather discouraging and financially disappointing. However, as I recently experienced the risks that the world of paper records create for anyone receiving care in today’s paper-based healthcare system. I thought I’d pass it along as an energy booster-shot for those of us pushing the HIT ball up the steep hill of physician adoption.

Because of my professional knowledge of the risks associated with today’s largely paper-based inpatient care system, I take a very active role in monitoring the care and recordkeeping of any loved one who I visit at a hospital (with my aunt, I have MDPOA). My aunt, who suffers from a life-long mental illness, was recently admitted to a hospital with pneumonia. Midway thorugh her stay, my aunt’s provider was going to restore my aunt’s Zyprexa dosage to her ambulatory norm of 10mg/day (from the earlier 5mg per day), I was curious to make sure that it had actually occurred. I found that her paper Medical Administration Record indicated that her order had indeed been increased – to 10mg 4 times/day. I oversee all care provided to my disabled aunt, so I knew this was an extraordinary level of medication. The 1st 10 mg dose had already been administered, and she was due to get the 2nd in 3 hours.

Upon arriving home, I jumped on the web and confirmed that was a dangerous situation. I immediately called the nurse’s station at the hospital and directed that they not administer the next dose until after they personally spoke with my aunt’s psychiatrist who was part of the official care team (I was adamant that the hospitalist would not be sufficient). I then placed an urgent call with the psychiatrist’s service as a precautionary measure. 20 minutes later I received a call from the nurse that my aunt’s MAR and chart were being revised to reflect 10mg per day.

Being a firm believer in the importance of modern HIT, I returned to the hospital the next day to see how this error happened. My conversation with the nurse, who was very helpful, revealed that someone had interpreted a 10mg qd sig (Yes, it was a hand written order, though not particularly indecipherable) as 10mg 4 times a day (qid). One of the particularly surprising side elements of this story, is that the hospital has a modern in-patient pharmacy system that should have fired a dosing alert to the pharmacy staffer that filled/dispensed the order. If it did, there was no chart record of a clinical warning having been waived.

One interesting post-script: While the nurse was most apologetic, I never received an apology from someone in management at the hospital.

Anyone have a similar story they’d like to share?

July 29, 2011

EHR Funding for Community Mental Health Centers?

Filed under: Uncategorized — HankMayers @ 10:47 am

On June 17, 2011, CMS published its proposed rules for Medicare regulations [Conditions of Participation (CoP)] for Community Mental Health Centers [ http://www.regulations.gov/#!documentDetail;D=CMS-2011-0123-0001 ]. CMS specified 6 CoPs, one of which was the requirement of a quality assessment and performance improvement program. Within that CoP, CMS refers to its acceptance of “an IT performace improvement project that allowed the CMHC to invest in information technology..” The wording goes on to say”… investment and development of an IT system that was geared to to improvements in patient safety and quality, as a QAPI project.”

While an EHR generally has significant potential to improve the quality of care, one could also simply invest in a whole lot less IT, such as a patient registry solution. Indeed, an EHR would directly further the achivement of at least 3 of the other 5 CoPs. Will CMS allow/encourage the pursuit of comprehensive EHRs under this rule?

Opinions, anyone?

May 28, 2011

Meaningful Use is Hip?

Filed under: EHR Incentive, EMRs, HIEs, Meaningful Use — HankMayers @ 10:09 am

Hi Friends,

Check this site our for a little EHR entertainment!

http://www.youtube.com/watch?v=dUiARwgKzi0&feature=youtu.be

Cheers

May 21, 2011

EHR Incentive Money Begins to Flow & Adoption Patterns Begin to Emerge

Filed under: CMS, EHR Incentive, EMRs, Meaningful Use — HankMayers @ 9:09 pm

CMS has just released stats on how the EHR Incentive enrollment is going, as well as how the dollars are flowing:

Total Medicare Physicians Registering – 40,379
Total Medicaid Practitioners Registering – 2,014

Medicaid has paid out $5,525,000.00 to 260 practitioners for AIU-level activity
Medicare has not yet paid out any funds to physicians, as we are only now reaching the time window where 90 days of meaningful use could have been achieved in CY2011.

For the skeptics, please take notice that the federal funds are actually being disbursed!

The low rate of enrollment of Medicaid practitioners is probably a confirmation of the market claims that a Medicaid patient load of 30% generally means such a practice is running in the red. Most practitioners I have talked with foresee themselves as only eligible for the Medicare incentive.

A further interesting piece of data is that, of the 2,014 incentive registered Medicaid practitioners, only 260 are seeking AIU eligibility. The remaining 1,754 appear to be registering for full Meaningful Use. It would seem to follow that, at least up to April 2011, very few Medicaid practitioners are choosing to launch an EHR initiative as a result of the Medicaid EHR incentive dollars. Rather, the incentive is going to practitioners that already have an EHR. This piece of data warrants very close observation by Medicaid incentive program administrators who are committed to motivating their practitioners into EHR technology.

As the state RECs have generally shifted from marketing to service delivery, as of 1/1/11, it would seem that they could provide additional “pipeline” data on Medicare and Medicaid practitioners launching EHR initiatives. Hopefully, they’ll make such data available on the ONC website soon.

Nonetheless, it is good to see evidence of the EHR Incentive flowing.

Comments anyone?

April 13, 2011

The Physician EHR Incentive Does Not Have To Be Taxable to the Physician

Filed under: EHR Incentive — HankMayers @ 3:42 pm

Now that more of the EHR incentive application process is known, I have discovered one piece of very encouraging news:

Under certain circumstances, the EHR Incentive payment may NOT be taxable to the physician as personal income! Here is how it works:

Essentially, the physician can assign his/her incentive payment to any party, including a practice PLLC. This is accomplished by, when registering for the incentive, the physician would provide the PLLC’s TIN (generally a FEIN) as the party to which the payment is to be made. The incentive becomes a business income item, to be taxed in the normal course of the costing etc and taxation liabilities of the practice. For many physicians, this will make a big difference.

Or, the physician can also select the FEIN for the group practice that is incurring the HIT/EHR expense for the entire practice. This arrangement should be documented via a formal agreement between the practice and the physician.

The physician can make a TIN designation each year, but only once per year. This allows a re-designation for a subsequent year in the event that the physician changes practice. To be able to continue to receive the incentive when the TIN changes, there must be a certified EHR in operation at the new location, and the physician must remain a meaningful year for the rest of the “move” year.

March 21, 2011

New HIT Resources: How Deep Must Entry Experience Be?

Filed under: EMRs, HIT Workforce Training — HankMayers @ 9:24 pm

I just scanned some posts on a LinkedIn group focusing on the new Workforce Training programs funded by the ONC. Generally, the comments were very critical of the design and assumptions of the program. As I am an instructor at one of the community college, delivering this program, I was struck by how different some of the programs appear to be.

A noted real Achilles-heel to the program is its short duration. While the hours required (classroom time plus readings, plus on-line events, and test taking) is rather substantial (tho the duration is short: 20 weeks or so), the broad array of material means that the graduates will not have great depth on the topics. HOWEVER, I think all of us must get a bit more realistic about the competency levels that should be expected of the new entrants into the HIT field. Healthcare has always been rather demanding over the depth of background it expects of its entrants into the field. HIT staffing has generally had the luxury of acquiring fairly experienced staffing from the served departments or ancillaries within the hospital. For instance, I challenge anyone to find any HIT job posting where the minimum experience level required was less than 3-5 years! And where does one go to get that initial experience?? Frequently, it was vendor or contract personnel that were ready to give up the road.

As I see it, the rapid escalation of demands for HIT resources that we can foresee for the next 3-5 years means that (1) we need to accept that new hires will have lower levels of healthcare experience, and (2) that OJT, combined with more rigorous levels of immediate supervision, is essential to succeed in the coming years.

The ONC-funded workforce training is going to produce a wave of individuals who have a good grounding in how healthcare operates, how HIT is being harnessed (and why) in such places as hospitals and ambulatory practices, and a good starting knowledge base on such things as project management, or work process (especially clinical) engineering, or technical support services, or user training. But these individuals will frequently have limited healthcare experience. [It should be noted that current healthcare employees make up significnat percentages of some of these classes]

If the Lansing, Michigan program is typical, I can also tell you that most of these students are individuals with considerable workplace experience and evident excitement at the prospect of becoming part of their local healthcare delivery system and making HIT projects happen.

The remaining challenge is to plug these high-potential resources into jobs that will both challenge them AND provide them with the kind of resources and guidance that can assure everyone’s success.

I witnessed the remarkable ramping up of non-IT background resources into effective entry-level HIT resources for Y2K software remediation and client-server applications during the late 1990’s. The parallels for the current HIT industry are substantial. If we are not prepared to launch similar efforts within our respective healthcare entities, we face the real prospect of failing to meet the urgent needs of our clinical colleagues.

Comments anyone?

Hank

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