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CMS Reveals MACRA Rules

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A CMS … Proposal

[By Andy Salmen]

The Centers for Medicaid and Medicare Services (CMS) have finally released the much anticipated unveiling of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rule proposal.

The goal of this rule is to establish key parameters for the new Quality Payment Program, a framework that includes the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). These two paths for compliance allow doctors more flexibility in achieving compliance.

MIPS

MIPS scores clinicians based measures and activities chosen by physicians and is based on their specialty. MIPS would basically streamline and combine three of the different programs that currently exist under Medicare. These programs are Physician Quality Reporting System, the Value-Based Modifier Program, and the ‘Meaningful Use’ of electronic health records.

There will be four performance categories for clinicians (clinicians include physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, etc.) to be scored on. These performance categories are:

  • Quality
  • Advanced Care Information
  • Clinical Practice Improvement Activities
  • Cost

APMs

CMS proposed implementing an Advanced Payment Models (APM) pathway, allowing eligible clinicians to become “qualified participants”. This means that eligible clinicians will be able to earn statutorily specified incentives for participation.

CMS predicts most providers to initially opt for MIPS. It is expected that participation in APMs, both number of physicians and number of payment models, will grow over time, as this program will qualify clinicians for financial bonuses in exchange for taking the risks associated with providing “coordinated, high-quality care”, according to CMS. 

***

3726de1f-2375-4301-84e0-78447fb496f3-original

***

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EHR Meaningful Use Rules Finalized

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The CMS Modifications

[By staff reporters]

Source: Joseph Goedert, Health Data Management [10/7/15]
***
Centers for Medicare and Medicaid Services
***
The Centers for Medicare and Medicaid Services has issued a 752-page final rule covering three components of the electronic health records meaningful use program. The rule finalizes modifications to Stages 1 and 2; the 2015 edition of electronic health records certification criteria; and Stage 3 of meaningful use.
Modifications
Under the modifications to Stages 1 and 2, eligible professionals have 10 meaningful use objectives, down from 18 previously. In Stage 3, there are 8 objectives for eligible professionals and hospitals, and more than 60 percent of measures require interoperability.
Assessment
The entire rule is available here.
***
MD with eHR
***
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Understanding “Meaningful Use” Attestation Numbers for 2014

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Providers versus Hospitals

By CMS

ME121014_PAGE_16

Assessment

So, what do the hospitals know –  that the doctors do not?

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Are Dentists Satisfied with their EDRs?

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Major Discontent With EHR Adoption

[By D. Kellus Pruitt DDS]

1-darrellpruittUnlike physicians, dentists never complain. That means they are probably 100% satisfied with their electronic dental records.

What do you think, Doc?

MarketWatch 

Recently, the Wall Street Journal’s MarketWatch posted a press release titled, “Physicians Cite Major Discontent With Adoption And Use of Electronic Health Record Systems, Despite Government’s $27 Billion Incentive Program”

http://www.marketwatch.com/story/physicians-cite-major-discontent-with-adoption-and-use-of-electronic-health-record-systems-despite-governments-27-billion-incentive-program-2014-02-07

“CLEVELAND, Feb. 7, 2014 /PRNewswire/ — The $27 billion government experiment to incentivize physicians to convert to electronic health records (EHRs) has not been worth it, according to nearly 70% of physicians surveyed.

Medical Economics 

***

In fact, a national [Medical Economics] survey of nearly 1,000 physicians, set for release on February 10, 2014, shows widespread dissatisfaction related to the functionality and cost of these patient record systems. About 45% of physicians believe patient care is actually worse as a result of adopting EHR technology, two-thirds would not purchase their current EHR system again, and 43% of physicians say these systems have resulted in significant financial losses.

In addition, the current state of technology has not improved the coordination of care with hospitals, physicians say.”

***

It is probably better for HHS that very few dentists were able to participate in the ARRA stimulus giveaway. Otherwise, tax-paying citizens might have learned about the wastefulness of Meaningful Use requirements for dentists – which nobody has the guts to reveal. That pretty much rules out brilliant Meaningful Use ideas.

Those who might patriotically defend the benefits of the tasks would do so, if they were idiots.

So how do dentists feel about their electronic dental records? It’s hard to tell. Over 96% of them are HIPAA-covered entities, making them vulnerable to audits, which can be “random” now. As one can imagine, very few dentists openly discuss EDRs. Do you think the silence is more likely to improve or harm patient care?

doc

Even though thousands of physicians have participated in dozens of national surveys like Medical Economics’ over the last few years, as far as I know, not one survey of dentists’ opinions has ever been published. Perhaps someone can prove me wrong. I doubt it.

The Survey

The results from the Medical Economics survey include:

  • 67% say that system functionality influences their decisions to purchase or switch systems.
  • 48% say that cost is influencing their decisions to purchase or switch systems.
  • Nearly half of physicians say that implementation of EHR systems has made the quality of patient care worse.
  • 69% of respondents say that coordination of care with hospitals has not improved.
  • 45% say they have spent more than $100,000 on an EHR
  • 77% of the largest practices (more than 10 physicians) spent more than $200,000 on an EHR.
  • 38% doubt their systems will still be viable in 5 years.

Assessment

Not long ago, Wisconsin became the first state to outlaw paper dental records, which are both cheaper and safer than digital.

So, is it still too soon for dentists and patients demand more transparency in dentistry? When costs and danger are hidden in dental care, it is always the last in line who suffer the most – clueless, trusting dental patients.

Am I right, Doc?

More:

  1. Sales of Dental Equipment and eDRs Down
  2. Military Electronic Dental Records [eDRs]
  3. Dr. Pruitt Invites Dr. Cohen to Discuss eDRs
  4. Cyber Insurance for Dentists

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More on “Meaningful Use” Requirements

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And  …  Its’ Impact on eHRs

Carol Miller RN MBA millerconsultgroup@gmail.com

The American Recovery and Reinvestment Act of 2009introduced the “Meaningful Use” requirement for EHR systems with three main components:

The Components

1) The use of a certified EHR in a meaningful manner, such as e-prescribing, 2) The use of a certified EHR technology for electronic exchange of health information to improve quality of health care, and 3) The use of a certified EHR technology to submit clinical quality and other measures.

Meaningful Use refers to a set of 15 criteria that medical providers must meet in order to prove that they are using their EHRs as an effective tool in their practice.  There are also 10 additional criteria that are considered a la carte from which only 5 need to be demonstrated by the medical provider.

In total, 20 Meaningful Use criteria must be used within the EHR to qualify for stimulus payments during Stage One of the EHR incentive program.   Each of the criteria were developed and further reviewed by the Office of the National Coordinator [ONC] with public input.

A Five Year TimeLine

Meaningful use will be measured in stages over five years.  Each stage represents a level of adoption.  Many certified EHRS will allow providers to complete all Meaningful Use criteria, whereas others will only certify what is required in the early stages and modify at a later date with any new criteria.

The three stages are:

Stage One:  Essentially, Stage One is using the major functionality of a certified EHR.  This includes documenting set percentages of your visits, diagnoses, prescriptions, immunizations and other relevant health information electronically; using the clinical support tools (warnings and reminders that will be included in a certified EHR); and sharing patient information.  Providers and hospitals must report quality measures and public health information. For providers they must report on 6 clinical quality measures – 3 required core measures and 3 additional measures selected from a set of 38 clinical quality measures.  Eligible hospitals and Critical Care Hospitals (CAHs) must report on all 15 of the clinical quality measures.  Stage One is required in years 2011 and 2012.

Stage Two:  In addition to continuing to use all functionality from Stage One, physicians will be required to use EHRs to send and receive information such as lab orders and results.   Other criteria may be added.  Stage Two is expected to be implemented in 2013.

Stage Three:  This stage will continue fulfilling the criteria from Stages One and Two and will include clinical decisions support for national high priority conditions; emailing patients in a Personal Health Record (PHR); accessing comprehensive patient data; and improving population health.  Stage Three criteria have not been developed to date and the implementation is not expected until 2015.

Assessment

CMS payment penalties for non-compliance to the meaningful use regulations will begin in 2016 with an initial 1% penalty which could escalate to 5% five years later.  Therefore, with these criteria in place, we are likely to see virtually all hospitals attempt to meet the meaningful use criteria to avoid penalty cost.

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Implementing “Meaningful Use” [A True Tale from the eHR Field]

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Maintaining Criteria for CMS Incentives

Anonymous Doctor

[By Anonymous Doctor]

If you qualified for year one … you qualified for year one. Deposit the check and pat yourself on the back. I too worked myself ragged, added a couple of hours to my charting each day … and collected $18,000 for 90 days (actually 6 months) of added stress.

But, I have opted NOT TO continue into year 2 … as $1,000 per month for 365 straight days of compliance is too much to bear. There is no mandatory need to comply until 2015.

I plan to use my software, comply as much as possible, not pull my hair out until 2015 when we have to be 100% compliant, 100% of the time. I know there are those with big staffs, and big overhead who will disagree, and have their assistants do all the charting.

For those of us in solo practice struggling to make ends meet, this burden is NOT WORTH carrying into year #2.

Source: Ann Miller RN MHA

via Name Withheld (FL)

PM Mews #4,382

Assessment

This story was originally a “comment”, but it has been re-published as a “post”, to illustrate the dichotomy between medical practitioners using eHRs and salesfolks recommending and selling them based on the government rebate feature rather than true market competition, efficiency and innovation.

MORE: MU GE Healthcare

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The Federal Strategic Plan to Reduce Health IT Disparities

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[By Staff Reporters]

Working to ensure all Americans benefit from health IT is one of the principles guiding the development and execution of the federal health IT strategy. The Federal Health IT Strategic Plan that was released for public comment on March 25, 2011, states that we will strive to: Support health information technology (heath IT) benefits for all.

All Americans should have equal access to quality health care. This includes the benefits conferred by health IT.: The government will endeavor to assure that underserved and at-risk individuals enjoy these benefits to the same extent as all other citizens.

Health IT Disparities Workgroup

For the past few months, the Health IT Disparities Workgroup — comprised of staff from agencies of the U.S. Department of Health and Human Services (HHS): with strategic and operational programs in health IT and co-chaired by the Office of the National Coordinator for Health Information Technology (ONC) and the Office of Minority Health (OMH) — has led a focused effort to further define the federal government’s strategies and tactics to reduce health IT disparities within underserved communities. The result of this process will reflect our commitment to do more to reduce health IT disparities.

The Health IT Disparities Workgroup is developing a federal plan to reduce health IT disparities.: A draft set of strategies/tactics — aligned with the five goals of the Federal Health IT Strategic Plan — is included below: We hope you will assist us by providing comments on the following questions:

  • What do you think of the draft strategies / tactics listed below?
  • What specific activities would you like to see the federal government take on to reduce health IT disparities?

HIT

Health information technologies — such as electronic health records (EHRs), telemedicine, mobile health, and electronic disease registries — have been identified as effective means of helping to deliver safe, effective, affordable health care services; coordinate care across providers and clinical settings; and provide critical population data that may catalyze further policy and delivery system innovations.

Meaningful Use

The growing adoption and meaningful use of health IT is even more critical within the context of underserved communities. Within both rural and urban underserved communities, access to primary and specialty health care resources can be limited. This scarcity in many instances contributes to reduced quality of health care and of health outcomes for people residing in these communities. Within underserved communities, the use of health IT has demonstrated it can improve health outcomes, both from an individual and community-/system-wide perspective.

Federal Planning

Federal planning efforts focused at reducing health disparities, including The National Stakeholder’s Strategy and the HHS Action Plan to Reduce Racial and Ethnic Health Disparities, highlight the proliferation of meaningful use of health IT within underserved communities as a critical objective. This draft set of strategies/tactics (see below) for the federal plan to reduce health IT disparities aims to ensure that underserved communities realize the full benefits of health IT.

Assessment

Read more: http://www.healthit.gov/buzz-blog/from-the-onc-desk/federal-strategic-plan-disparities/#ixzz1X7U1WnCQ

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“Meaningful Use” for Ambulatory Care Medical Practices

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EHR Objectives and Measures

By Shahid N. Shah MS  

For ambulatory care practices and physicians there are about 25 objectives and measures that must be met to become a “meaningful user”. Keep in mind that meaningful use is not tied to a certified EHR alone; in fact, unless you use the EHR properly and in all the ways the government wants you to, you will not be a “meaningful user”.

Don’t be fooled by EHR vendors guaranteeing that they will make you a “meaningful user” – no vendor’s software, no matter how nice, can get your staff to use the software in the way the government wants. You, as the CIO of your practice, are the only one that can guarantee that. In fact, you don’t even need an EHR from a vendor to meet the requirements – you can even roll your own, use open source, or find any other means.

Fear and Promises

In general, as long as you can attest and send data to the government that they require you can do it in any way that you want. Be aware that some unscrupulous vendors are scaring practices and making promises that they cannot keep.

Final MU Rules

The final Meaningful Use (MU) Rule was published by HHS on July 13, 2010. It defines 24 objectives for and measures eligible hospitals that could be met to become a meaningful user and qualify for incentive funding. There is a “core set” that must be met by all institutions and a “menu set” of from which organizations must implement at least 5 objectives.

Core Set Objectives

These are the “core set” of 14 objectives that must be met by all institutions and a “menu set” of 10 from which organizations must implement at least 5 objectives (at least 1 public health objective must be chosen from that set).

  1. Use Computer Provider Order Entry (CPOE).
  2. Implement drug-drug, drug-allergy, and drug-formulary checks.
  3. Record demographics.
  4. Implement one clinical decision support rule.
  5. Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT.
  6. Maintain active medication list.
  7. Maintain active medication allergy list.
  8. Record and chart changes in vital signs.
  9. Record smoking status for patients 13 years or older.
  10. Report hospital clinical quality measures to CMS or States.
  11. Provide patients with an electronic copy of their health information, upon request.
  12. Provide patients with an electronic copy of their discharge instructions at time of discharge, upon request.
  13. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically.
  14. Protect electronic health information.

Menu Set Objectives

These are the “menu set” of 10 objectives from which organizations must implement at least 5. At least one public health objective must be chosen from this set as well (numbers 8 or 9). Drug-formulary checks.

  1. Record advanced directives for patients 65 years or older.
  2. Incorporate clinical lab test results as structured data.
  3. Generate lists of patients by specific conditions.
  4. Use certified EHR technology to identify patient-specific education resources and provide to patient, if appropriate.
  5. Medication reconciliation.
  6. Summary of care record for each transition of care/referrals.
  7. Capability to submit electronic data to immunization registries/systems.
  8. Capability to provide electronic submission of reportable lab results to public health agencies.
  9. Capability to provide electronic syndromic surveillance data to public health agencies.

Government Agencies and Participants Involved in MU

As you can see in the Figure, the Office of the National Coordinator for Healthcare IT (ONCHIT) is a component of the Department of Health and Human Services (HHS). ONCHIT, usually abbreviated just ONC, is the principal policy group of the Federal Government that defines and manages NHIN.

Figure Link: Figure 

* ONC is responsible for coordinating with the Department of Commerce’s National Institute of Standards and Technology (NIST) on the specifications for the NHIN standards.

* The HIT Policy and HIT Standards Committees are the working groups that advise ONC on what to put in the standards.

* NIST is responsible for coming up with the test materials (assertions, procedures, methods, tools, data, and so on) that will be used to certify working systems 

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On Track for Meaningful Use?

Are we on track to be a huge disappointment to our children’s children – or What?

[By Darrell K. Pruitt DDS]

When our grandchildren get the bill for the Obama administration’s subsidies benefitting primarily the health information technology industry, I bet they’re going to be really, really pissed at us for allowing today’s lawmakers to blow their 28 billion dollars to please HIT advocates who mislead consumers as well as lawmakers about the benefits of EHRs.

The Doctors Speak 

According to physicians who actually do the hard lifting in healthcare, the “meaningful use” requirements that they must prove in order to qualify for stimulus money will arguably increase both the cost and danger of healthcare – all for the benefit of stakeholders rather than principals. For one thing, “meaningful use” is meaningless if it fails to help physicians treat their patients. I think HIT stakeholders’ grandchildren should somehow be held accountable to my grandchildren.

Opposing Opinions  

Just days apart this week, two HIT reporters, Rich Daly from ModernHealthcare.com and Joseph Goedert from HealthDataManagment.com described two opposing letters the Office of the National Coordinator for Health Information Technology (ONC) recently received: One from doctors and one from patients (et al).

On Monday, here is how Daly’s article “AMA to ONC: EHR program doesn’t work for docs” began:

http://www.modernhealthcare.com/article/20110302/NEWS/303029950/1153

“Many physicians—specialists in particular—will not participate in the federal electronic health-record adoption incentive program because it requires them to include patient data that they do not otherwise collect, according to a Feb. 25 letter from 39 medical organizations letter to the Office of the National Coordinator for Health Information Technology”

On Wednesday, Joseph Goedert, writing for HealthDataManagment.com began “Consumer Groups: Hold Strong on MU” with this:

http://www.healthdatamanagement.com/news/meaningful-use-criteria-comments-consumers-42080-1.html

“A coalition of 25 consumer groups and unions is asking federal officials to hold firm on more stringent criteria for Stage 2 of electronic health records meaningful use, and expressing support for going further. For instance, because patients still trust their providers more than other information sources, holding providers accountable for actual usage of a patient Web portal ‘is entirely appropriate and we strongly urge ONC to resist pressure from the provider community to absolve them from responsibility for making these services available and useful to their patients,’ according to a comment letter to the Office of the National Coordinator”

  • AARP
  • Advocacy for Patients with Chronic Illness, Inc.
  • AFL-CIO
  • American Association on Health and Disability
  • American Hospice Foundation
  • Caring from a Distance
  • Center for Democracy & Technology
  • Childbirth Connection
  • Consumers for Affordable Health Care
  • Consumers Union
  • Families USA
  • Family Caregiver Alliance
  • Healthwise
  • Mothers Against Medical Error
  • National Alliance for Caregiving
  • National Coalition for Cancer Survivorship
  • National Consumers League
  • National Family Caregivers Association
  • National Health Law Program
  • National Partnership for Women & Families
  • National Women’s Health Network
  • OWL – The Voice of Midlife and Older Women
  • SEIU
  • The Children’s Partnership

Like the “Record Demographics” MU mandate, this is all for the “common good” I suppose. Consumer Advocasy groups wouldn’t mislead patients, would they?

I doubt many Americans represented by these 25 organizations ever imagined a new federal requirement that doctors record each patient’s demographics. (Notice of Proposed Rulemaking: Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Federal Register / Vol. 75, No. 8 / Wednesday, January 13, 2010 / page 1861; RIN 0938-AP78).

This means that the 25 stakeholder groups are doing their best to help American taxpayers hold physicians accountable to record and share their patients’ demographic information with the US government – private information about me and my family members that I personally don’t trust the government to be given – even if I’m in vulnerable need of health care.

Daly’s Article 

According to Daly’s article, the demands of MU are distractions for increasingly busy doctors and staff whose focus, I believe, should include eye-contact with patients with specific health problems rather than irrelevant data needs of third parties, including consumer advocacy groups.

On the other hand, if consumer advocacy groups have successfully defined for the federal government what clueless patients allegedly need, who will the mandate really benefit? 25 consumer advocacy groups don’t equal one consumer, so their letter isn’t grass roots at all. It’s deception wearing lipstick. Gullible and vulnerable patients are again being misrepresented by HIT stakeholders for a cut of our grandchildren’s 28 billion.

Assessment

Finally, if MU requirements are an arguably expensive and dangerous distraction for physicians, how can the law possibly be any less absurd for dentists? I’ll look at meaningful use as well at the ADA’s apparently flagging commitment to EHRs next. The ADA is abandoning state informatics departments – leaving them exposed to ADA members’ questions they are unable to answer. It looks to me that intra-ADA relationships are deteriorating quickly, but nevertheless, traditional stoicism still hasn’t been broken. “Image is everything” – ADA/IDM slogan.

Dentists

Here’s a teaser, dentists: Chances are, your state ADA organization hasn’t yet shared with you how the MU requirement of CPOE (Computerized physician order entry – page 1858) will change your practice communications. If you are a HIPAA-covered entity with an NPI number and you don’t email instructions to your denture lab rather than include a hand-written note with the relevant patient’s plaster models, you won’t qualify for stimulus money. What can possibly go wrong with that meaningful idea?

Conclusion

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How to Choose eMR and HIT Consultants

Seeking Unbiased – Not Vendor Driven – Advice

By Shahid N. Shah, MS

www.BusinessofMedicalPractice.com

When you choose to implement your medical records technology, you’ll want to be sure that you get sound and unbiased advice. If you think the selections and decisions are too complicated to do by yourself so getting help is prudent. After you’ve learned more about RECs, which can give you free advice and help, look at some paid consultants as well because most RECs will simply choose a few local consultants that marketed themselves well to the RECs and not because the consultants are necessarily good at their jobs.

Consulting Types

The kinds of consultants you will need include:

  • Meaningful Use (MU) Consultant. An MU consultant should only be needed if you’re going after government stimulus funds. This is a person that knows how a medical practice works, inside and out, and all the legal and regulatory details about Meaningful Use. This is not a typical IT contractor or technical consultant; it must be someone who is focused on MU. Because you will not get increased government reimbursements unless you meet MU, the MU Consultant is probably more important than your IT consultant. The MU consultant should help you figure out whether or not you qualify for incentives, how to take advantage of incentive program, how to use RECs, how to ensure that you can qualify for MU without disrupting your practice and losing money, and finally whether you should even care about MU.
  • A good MU Consultant will tell you when to walk away from MU and not implement certain technologies just as readily as when to implement it.
  • Another major thing to focus on when choosing an MU consultant is to be sure that they know your local area’s rules, regulations, and technology providers (not national).
  • Try to make sure that your MU Consultants are paid very little upfront and will share the risk with you as you try to achieve success. They should get paid when you get paid and should not be paid full price unless you get incentive payments from the government. 
  • EMR Consultant. If you’re ready to buy an EMR the MU Consultant can help you pick products but getting advice from an EMR Consultant who knows all the hundreds of packages (and doesn’t just know 1 or 2 that he’s seen before) and which one will be best for you may be worth investing in. Be careful if your EMR Consultant is coming from a REC or a vendor side – ask them to disclose any ties to the products they are helping you select. Some EMR consultants are business focused and others are technically focused; you should pick the one based on what your needs are: for example, if you’re great at technology, choose a business-focused consultant (and vice-versa). 
  • IT Consultant. This is something that’s obvious but you need excellent advice on hardware, software, inter-office networking, Internet connectivity, bandwidth analysis, and a whole host of other technology needs. 
  • Integration Consultant. Most people forget this consultant because it’s not obvious but in order to make sure that all the medical records data you’re collecting can be shared in between your systems, your hospital, and with the government you need an integration consultant. Their job is to know all the relevant standards like HL7, DICOM, CCR, CCD, XML, etc. along with things like HL7 routers and tools that can share medical data records between your EMR, practice management system, and health information exchanges (HIEs).

Assessment 

Front Matter BoMP – 3

Conclusion

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Is ARRA Stimulus Money for Dentists?

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Now is the Time to Say “No Thank You” to the ADA

[By D. Kellus Pruitt DDS]

A few days ago on Twitter, @techguy said: “@Dentrix, Are you guys helping dentists get access to the ARRA EHR Stimulus money?” This morning I “retweeted” his question to the electronic dental record giant: “That’s a great question, @Dentrix. What are you doing to help dentists receive stimulus money?

Of Faded Promises  

Dentrix officials no longer shop faded promises of free stimulus money to help dentists purchase their software. The truth is, without taxpayer help, Dentrix’s product offers dentists no return on investment, and it’s unlikely that the profession will ever see a cent of stimulus money. In fact, if American Dental Association President Raymond Gist wants to be a national hero, now would be the time to purchase a press release to tell the nation, “American dentists graciously decline your offer of stimulus money, taxpayers. We say, let our grandchildren keep it for themselves.” The deficit-weary public is very interested in that kind of good news these days. But, the ADA’s PR opportunity has a shelf life. The sooner they jump on this minor deception the more generous American dentists will appear. A year from now, the chunk of faux-generosity won’t work.

Too Late for Cash Give-Aways 

For one thing, it’s simply too late for dentists to take part in the cash giveaway. And even if there was time for a significant number of dentists to convert from paper to digital before September 2011, to receive promised stimulus money, a dentist’s practice has to be 30% Medicaid. That qualification rules out almost all dental practices right off, and here in Texas last week, Governor Perry threatened to opt my state out of Medicaid (and stimulus money) completely. A year ago, Perry threatened secession from the Union. It sounds to me like you are softening him up, Washington.

Meaningful Use Requirements 

That’s not all. Before a dentist can qualify to be reimbursed up to $44,000 dollars, the practice must show “meaningful use” of certified electronic dental records. However, meaningful use of digital records in dentistry has not yet been determined and perhaps does not actually exist. Nevertheless, the best minds in the ADA and HHS are searching for the next best thing – humorous rationalizations. For example, imagine the convenience of the speed-dial on the telephone compared to logging on to a highly secure, password-protected, HIPAA-compliant, encrypted computer just to tell the lab you have a pick up – just to show the Department of Health and Human Services that you are making “meaningful use” of your Dentrix product and spending taxpayer money wisely.

Assessment 

Do you know what is scary about the leadership in my profession? I’m apparently the only dentist in the nation who dares admit that as far as ARRA stimulus money goes, American dentists are out of luck and clueless. Even @techguy is in the dark for crying out loud!

Conclusion

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Brief Summary of “Meaningful-Use” for eHRs

Objectives Listed

By Shahid N. Shah MS

www.BusinessofMedicalPractice.com

In 2009, the ARRA HITECH bill coined the term “meaningful use” and was a game-changer in the healthcare IT industry. In a series of regulations, the Recovery Act specifically required the following.

Summary of MU

Here are the substantive Meaningful Use objectives of the new ARRA HITECH bill:

  • Use Computer Provider Order Entry (CPOE).
  • Implement drug-drug, drug-allergy, drug-formulary checks.
  • Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®.
  • Maintain active medication list.
  • Maintain active medication allergy list.
  • Record demographics.
  • Record and chart changes in vital signs.
  • Record smoking status for patients 13 years and older.
  • Incorporate clinical lab-test results into EHR as structured data.
  • Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, and outreach. This is a common feature in EHRs.
  • Report ambulatory quality measures to CMS or the States.
  • Implement 5 clinical decision support rules relevant to specialty or high clinical priority, including diagnostic test ordering, along with the ability to track compliance with those rules.
  • Check insurance eligibility electronically from public and private payers.
  • Submit claims electronically to public and private payers.
  • Provide patients with an electronic copy of their health information upon request.
  • Capability to electronically exchange key clinical information among providers of care and patient-authorized entities.
  • Perform medication reconciliation at relevant encounters and each transition of care.
  • Provide summary care record for each transition of care and referral.
  • Capability to submit electronic data to immunization registries and actual submission where required and accepted.
  • Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
  • Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities
  • Generate and transmit permissible prescriptions electronically.
  • Send reminders to patients per patient preference for preventive/follow-up care.
  • Provide patients with timely electronic access to their health information within 96 hours of information being available to the EP.
  • Provide clinical summaries for patients for each office visit.

Conclusion

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On e-Confidentiality Conflicts in Medicine

Understanding the Potential Role of eMR Compromise

By Render Davis MHA CHE

www.BusinessofMedicalPractice.com

Whether it is an employer interested in the results of an employee’s health screening; an insurer attempting to learn more about an enrollee’s prior health history; the media in search of a story; or health planners examining the potential value of national health databases, the confidential nature of the traditional doctor-patient relationship may be compromised through demands for clinical information by parties other than the patient and treating caregivers. 

Impact of eMRs

In addition, without clear safeguards the growth in use of electronic medical records may put personal health information at risk of tampering or unauthorized access.  Clearly, employers and insurers are interested in the status of an individual’s health and ability to work; but does this desire to know, combined with their role as payers for health care, constitute a right to know?  The patient’s right to privacy remains a volatile and unresolved issue.

Assessment

Counter to this concern is the recognition that electronic records may dramatically improve communications by offering greater accessibility of information to clinicians in the hospital or office potentially reducing medical errors through elimination of handwritten notes, increased use of built in prompts and clinically-derived triggers for orders and treatments, and development of pathways for optimal treatments based on clinically valid and tested best practices.

Conclusion

And so, your thoughts and comments on this ME-P are appreciated. What do you think about this confidentiality conflict and the role of eMRs? Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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More About Regional Extension Centers

RECs Explained

By Shahid N. Shah; MS 

www.BusinessofMedicalPractice.com

The Meaningful Use and Certification requirements along with the myriad of government regulations around Medicare and Medicaid reimbursements will be too complicated for most physicians to understand and manage on their own. To help out small practices, one of the interesting things funded by the HITECH Act was the creation of the Health Information Technology Extension Program. Via that program, the Department of Health and Human Services is required to invest in Regional Extension Centers (called “RECs” and pronounced like “wrecks”). RECs are designed to offer consulting and technical support to physicians in order to help accelerate adoption of Electronic Health Records (EHRs).

Purpose

The purpose of the RECs is to provide guidance on which products to buy, help reduce prices of software through group purchase agreements, and give technical assistance on implementation and deployment. These services will be free of charge to physicians. However, keep in mind that all RECs are non-profit organizations and most have little or no inherent knowledge about EMRs, EHRs, implementations, deployments, computer skills, etc.; initially they are groups that responded to the grant request in a manner that fulfilled documentation required by the government and will be provided government money to help Physicians become meaningful users [MUs].

No Cost Advice

In the short run no RECs will be very good because they will all be inexperienced. Over the long run, some RECs will become very good at their jobs while other RECs will be mediocre or not good at all; only time will tell which ones will be superb and helpful vs. not. Since RECs will be paid by the government for each physician they sign up, RECs will be very eager to approach and conduct outreach to sign you up. And, it will not cost you anything to sign up and the advice and assistance will be free to MDs.

Assessment

Keep in mind, though, that whenever something is free to you, always think about why it’s free. What does the organization get out of providing you free advice, assistance, knowledge, etc. – in the case of RECs, it’s is money from the government. The good news is that RECs are being told by the government that will only be paid if you become a “meaningful user.” However, the bad news is that some RECs will not be able to do a good job and may give you bad advice.

Conclusion

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More on the Meaningful Use of eMRs

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Final Meaningful Use Rules Released by HHS on July 13, 2010.

[By Shahid N. Shah MS]

Link: http://shahid.shah.org

For ambulatory care practices and physicians there are about 25 objectives and measures that must be met to become a “meaningful user”. Keep in mind that meaningful use is not tied to a certified EHR alone; in fact, unless you use the EHR properly and in all the ways the government wants you to, you will not be a “meaningful user”. Don’t be fooled by EHR vendors guaranteeing that they will make you a “meaningful user” – no vendor’s software, no matter how nice, can get your staff to use the software in the way the government wants. You, as the CIO of your practice, are the only one that can guarantee that. In fact, you don’t even need an EHR from a vendor to meet the requirements – you can even roll your own, use open source, or find any other means. But, in general, as long as you can attest and send data to the government that they require you can do it in any way that you want. Be aware that some unscrupulous vendors are scaring practices and making promises that they cannot keep.

Final MU Rules

The final Meaningful Use (MU) Rule was published by HHS on July 13, 2010. It defines 24 objectives for and measures eligible hospitals that could be met to become a meaningful user and qualify for incentive funding. There is a “core set” that must be met by all institutions and a “menu set” of from which organizations must implement at least 5 objectives.

Core Set Objectives

These are the “core set” of 14 objectives that must be met by all institutions and a “menu set” of 10 from which organizations must implement at least 5 objectives (at least 1 public health objective must be chosen from that set).

  1. Use Computer Provider Order Entry (CPOE).
  2. Implement drug-drug, drug-allergy, and drug-formulary checks.
  3. Record demographics.
  4. Implement one clinical decision support rule.
  5. Maintain a problem list of current and active Dxs based on ICD-9-CM or SNOMED CT.
  6. Maintain active medication list.
  7. Maintain active medication allergy list.
  8. Record and chart changes in vital signs.
  9. Record smoking status for patients 13 years or older.
  10. Report hospital clinical quality measures to CMS or States.
  11. Provide patients with an electronic copy of their health information, upon request.
  12. Provide patients an e-copy of discharge instructions at time of discharge, upon request.
  13. Exchange key clinical e-information among providers and patient-authorized entities.
  14. Protect electronic health information.

Menu Set Objectives

These are the “menu set” of 10 objectives from which organizations must implement at least 5. At least one public health objective must be chosen from this set as well (numbers 8, 9, or 10).

  1. Drug-formulary checks.
  2. Record advanced directives for patients 65 years or older.
  3. Incorporate clinical lab test results as structured data.
  4. Generate lists of patients by specific conditions.
  5. Use certified eHR technology to identify patient-specific education resources and provide to patient, if appropriate.
  6. Medication reconciliation.
  7. Summary of care record for each transition of care/referrals.
  8. Capability to submit electronic data to immunization registries/systems.
  9. Capability to provide electronic submission of reportable lab results to public health agencies.
  10. Capability to provide electronic syndromic surveillance data to public health agencies.

Assessment

As can be seen in the link below, the Office of the National Coordinator for Healthcare IT (ONCHIT) is a component of the Department of Health and Human Services (HHS). ONCHIT, usually abbreviated just ONC, is the principal policy group of the Federal Government that defines and manages NHIN.

  • ONC is responsible for coordinating with the Department of Commerce’s National Institute of Standards and Technology (NIST) on the specifications for the NHIN standards.
  • The HIT Policy and HIT Standards Committees are the working groups that advise ONC on what to put in the standards.
  • NIST is responsible for coming up with the test materials (assertions, procedures, methods, tools, data, and so on) that will be used to certify working systems.

Conclusion

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Ease Up – Managing Editor Bob Mitchell

By Darrell K. Pruitt; DDS

[picapp align=”none” wrap=”false” link=”term=doctors+computers&iid=131173″ src=”0127/4caf5e52-a89a-4ddb-a0b2-bf4b6789c92b.jpg?adImageId=11344576&imageId=131173″ width=”414″ height=”413″ /]

Two days ago, ADVANCE for Health Information Executives’ managing editor Bob Mitchell publicly criticized the author of last week’s Parade Magazine article, “Electronic Health Records Face Critics.” Personally, I thought it was cowardly for the editor to accuse Drew Jubera of journalistic recklessness without mentioning his name.

http://community.advanceweb.com/blogs/hx_1/archive/2010/03/16/critics-ehrs-don-t-save-money.aspx

According to Jubera

Jubera wrote:

“A new Harvard Medical School study suggests that electronic health records do not save hospitals money—and in fact often end up increasing costs. The Obama Administration has allocated $19 billion in federal stimulus funds to facilitate the shift from paper to electronic records – a move the Rand Corporation has projected could save up to $80 billion a year. Yet the Harvard study found no evidence of savings so far and little evidence that electronic records improve care.”

http://www.parade.com/news/intelligence-report/archive/100314-electronic-health-records-face-critics.html

Dis-Respects Harvard

Incredibly, Bob Mitchell discounts the Harvard Medical School study as being dated research – even though it is less than 5 months old. “I did some research and found that this study was released back in November 2009, even before meaningful use of an eHR had been defined by [ONCHIT] – or the Office of National Coordinator of Health IT.” As if defining meaningful use was meaningful! That’s humor.

Dis-Respects Parade

Furthermore, editor Mitchell has taken on the responsibility to shield his readers from harm caused by Parade Magazine authors whose ethics fall short of acceptable.

He writes:

“I’m concerned that the public is not being served and they will get the wrong impression of computers in health care, especially if it’s being reported by Parade, which reports celebrity, entertainment and health news.”

Of Healthcare Providers

Not so fast with those tricky pronoun phrases, Bob. Rather than being merely a healthcare stakeholder like you, I’m actually the healthcare provider whom you would have fund your enthusiasm. I think your broad statement that “all of us in healthcare know that digital is much better than paper” is journalistically foolish. In addition, your creativity threatens society much more than alleged exaggerations in Parade Magazine. You not only write about HIT as a career, but people generously call you a managing editor.

eMRs in Dentistry 

The next time you feel important enough to quietly insult writers on behalf of providers like me, remember that eMRs in dentistry will not save money over paper records and will unnecessarily increase the risk of identity theft for my patients … unless you disagree.

It would thrill me if you want to publicly debate the value of electronic dental records (How much do you know about dentistry?)

Assessment

For example, do you realize that if a computer containing thousands of patients’ identifying data is stolen in a burglary, and the dentist, or physician, does the right thing and reports the data breach, he or she will likely be bankrupt even before the HIPAA inspections and lawsuits?

The Ponemon Institute estimates that it will cost about $50 per record just to notify affected patients. A few weeks ago, the HHS was obligated to release information that a burglar stole a computer containing more than 9,000 records from a Missouri dental practice. Just to notify the affected patients will cost the practice almost half a million dollars. But wait. That’s not all. Since the loss involves over 500 individuals, news of the breach must be provided as a press release to the local media. As goes the dentist’s reputation, so goes the dentist’s career – all because of a simple burglary.

Conclusion

So what were you saying about dangerous, biased articles in Parade Magazine? The author whose ethics you criticize has a name. It is Drew Jubera. He’s an award-winning staff member of the Atlanta Journal-Constitution, in Atlanta GA – home of this ME-P.  I’ll make sure he also gets this message.

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Electronic Medical Records and Dentistry

A Note to Diane Rehm

[By Darrell K. Pruitt; DDS]

Dear Diane Rehm,

I always enjoy your show.

You add value to my drive to work.

As a dentist, I was especially interested in your March 10 show “Electronic Medical Records.”

http://wamu.org/programs/dr/10/03/10.php?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+WAMU885DianeRehm+%28WAMU%3A+The+Diane+Rehm+Show%29&utm_content=FaceBook#30598

In all the excitement that surrounds the 19 billion dollars our grandchildren have unwittingly granted to physicians and hospitals for “meaningful” adoption of certified eMRs, you probably haven’t noticed that nobody is talking about including dentistry in the conversion from paper to digital. Do you find that odd?

Small and Mid Sized Practices

Like small and mid sized physicians’ practices, small dental practices are intended to be part of the federal mandate for interoperable eMR adoption – even without the help from stimulus money that physicians receive. You probably weren’t aware that the stimulus money will run out before HHS gets around to defining “meaningful use” of eMRs in dental office. That would be impossible, but nevertheless, I anticipate that the attempts will be entertaining. Physicians in small practices typically have tens of thousands of paper charts as thick as phone books. On the other hand, a busy solo dental practice, like the majority of practices in the US, might have 5,000 files that are very thin in comparison to files that involve the whole body instead of just the bottom third of the face. That makes sense, doesn’t it?

Marginal Benefits May Not Exceed Marginal Costs 

I listened to your guest Dr. Carol Horn, who practices internal medicine in private practice, as well as others involved in the actual delivery of healthcare. They list not only the benefits of eMR adoption, but in fairness, they also described the expense and liability of digital records that continue long after the tedious and dangerous conversion from paper to digital. In other words, it appears that the benefits for physicians barely make the effort worth the price, even with 19 billion dollars in help.

Editor’s Note: In economics, we say that the marginal benefits may not exceed the marginal costs; all things being equal.

Assessment 

And so, it occurs to me that if dentists are to be included in the plans for digital interoperability, we will be very, very slow adopters for natural reasons: like eMRs in physicians’ offices, eMRs in dentists’ offices are more expense and trouble than they are worth – even before considering the bankruptcy-level liability of a data breach.

Most of those who champion eMRs for the entire healthcare system in the nation don’t realize that the bottleneck in dental offices isn’t the front desk. It’s the dentist who is hopefully taking his or her time providing care with those hands instead of working a keyboard.

Conclusion

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Asking Uncle Sam – Why Health IT?

Let ONC and CMS Explain

By Staff Reporters

On December 30, 2009, CMS and ONC issued proposed regulations on the definition of meaningful use and the initial set of standards, implementation specifications, and certification criteria for EHR technology.

According to the DDHS

Health information technology (health IT) allows comprehensive management of medical information and its secure exchange between health care consumers and providers. Broad use of HIT has the potential to improve health care quality, prevent medical errors, increase the efficiency of care provision and reduce unnecessary health care costs, increase administrative efficiencies, decrease paperwork, expand access to affordable care, and improve population health.

Improving Patient Care

Furthermore, according to the DHHS, interoperable health IT can improve individual patient care in numerous ways, including:

  • Complete, accurate, and searchable health information, available at the point of diagnosis and care, allowing for more informed decision making to enhance the quality and reliability of health care delivery.
  • More efficient and convenient delivery of care, without having to wait for the exchange of records or paperwork and without requiring unnecessary or repetitive tests or procedures.
  • Earlier diagnosis and characterization of disease, with the potential to thereby improve outcomes and reduce costs.
  • Reductions in adverse events through an improved understanding of each patient’s particular medical history, potential for drug-drug interactions, or (eventually) enhanced understanding of a patient’s metabolism or even genetic profile and likelihood of a positive or potentially harmful response to a course of treatment.
  • Increased efficiencies related to administrative tasks, allowing for more interaction with and transfer of information to patients, caregivers, and clinical care coordinators, and monitoring of patient care.

Assessment

Is the above really true in light of these two recently released reports on meaningful use?

More information is available at http://healthit.hhs.gov

Conclusion

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Ask an Advisor about “Meaningful-Use”

Do dentists qualify for “meaningful use” incentives under ARRA?

By Ann Miller; RN, MHA

[Executive Director]

Chairman's Seat

A simple and direct query asked by an ME-P subscriber.

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Conclusion

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About MeaningfulUse.org

Join Our Mailing List

A Dedicated Terminology Website

By Staff Reporters

Understanding and defining the new era of healthcare information technology in America.

The ARRA and HITECH concept of “meaningful use” for e-MRs is nebulous and ill defined. This new website is intended to be a collaborative destination site in order to promote the national dialogue and education around the term, “meaningful use”, by providing the HIT community a single-central location to access resources, influence and discuss the definition of “meaningful use” and learn how to take advantage of the HITECH stimulus funds.

HDSAssessment

According to the site, registration for the www.MeaningfulUse.org discussion board is only used for the purpose of posting and will not be used for any marketing purposes. The site is supported by the Association of Medical Directors of Information Systems (AMDIS) and sponsored by Compuware Corporation.

Conclusion

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