LighthouseView

November 29, 2012

Do You Intend to Avoid the Medicare EHR Claims “Payment Adjustments” (Penalties)?? I have an important alert for you.

I trust by now that my readers know that any entity, that is eligible for the Medicare EHR Incentive, that fails to be a meaningful user (MU) by 12/31/2014, will be subject to a payment reduction of 1% on ALL professional claims paid by Medicare. Continuing failure to be a MU’er in 2016 means a 2% reduction, and 2017 and thereafter means a 3% reduction.

The EHR Stage 2 final regs, released on 9/4/12 clarified when these meaningful use calculations must occur, and it may be earlier than some folks had been thinking. Generally, the entity’s status 2 years prior will determine if a penalty will apply. So:

As 2015 will be the 1st penalty year, one’s MU status in 2013 will serve as the determinate

When we consider the implications of this, it is important to remember that the Medicare incentive requires that, once you have achieved MU status, you must continue to meet MU criteria to receive the incentive in each of the 3 subsequent years.

Back to the implications:

• If you 1st achieved MU in 2011, you must do so in 2013 as well
• If you 1st achieved MU in 2012, you must do so in the following year as well
• If you are seeking your 1st year of MU in 2013, you can select any 90 day period, including the final quarter in the year, to achieve MU and avoid the penalty in 2015.

The feds have created a special provision on the Medicare payment penalties for entities who are making their 1st attempt at MU during the year just prior to the penalty year. Regarding the 2015 penalty year, you can avoid the 2015 penalty if you achieve your 1st year 90-day MU status (and complete your attestation reporting) prior to the final quarter of 2014.

• Because hospitals use the federal FY, in 2014, the achievement date will be July 3, 2014. This means their reporting window in 2014 would start no later than April 2, 2014

• Because the EPs use the calendar year, in 2014, the achievement date will be October 1, 2014. This means their reporting window in 2014 would start on July 3, 2014

If you are receiving the Medicaid EHR incentive from your state AND submit federal claims under Medicare for those program eligibles, your MU status under the Medicaid EHR incentive can affect your vulnerability for the Medicare payment penalty.

• If you achieved Medicaid A/I/U status in 2012, you were technically not yet a MU’er. So, your 1st year status as a Medicaid MU’er must be achieved in 2013 to avoid the penalty on your 2015 Medicare claims.

If you have been able to follow all of this (and this kind of thing generally takes more than one pass), you may be asking yourself why you cannot, as a Medicaid EHR incentive participant, be allowed to have the early part of 2014 to achieve your 1st year Medicaid MU Status and avoid the Medicare 2015 payment penalty. I have the same question. Once I get some clarification, I will produce another blog post.

Comments anyone???

March 25, 2012

Whose Data Is It Anyhow?

Filed under: Uncategorized — HankMayers @ 9:45 pm

As most of my followers know, I am a strong proponent of Application Service Providers (ASPs) as the best approach for securing an EHR, especially for the smaller sized physician practices.

While I continue to believe that the ASP is the option that most fully off-loads the technology burden inherent in using an EHR, I am hearing more and more frequently that it can be impossible to retrieve your patient records when it comes to “divorce time” with your ASP provider. Given that 500+ certified EHR vendors cannot survive the inevitable vendor shake-out in the EHR market, this lack of data portability is poised to become a very large problem a few years out.

It is my view that the federal EHR program agencies (the CMS, the ONC, and the Policy Committee) ) are in the best position to raise this issue and provide the necessary motivation for the vendors to be able to provide their clients with their patient records. And what I mean here is producing an electronic file that (1) includes the entire patient history that was recorded on their product for all practitioner patients, and (2) one that is structured so it can be used as a transaction driver on another vendor EHR product to build those past patient records.

Most assuredly, the technological considerations here are not minor. But they are most definitely not impossible. If the feds are going to penalize Medicare providers for not being EHR Meaningful Users, then they really are obligated to make the vendors deal with this important consideration.

Comments anyone?

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!

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?

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