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CMS publishes Stage 3 Meaningful Use proposal

The rumor I heard this morning was true. CMS has published its proposed rules for Stage 3 of Meaningful Use, once again waiting until late on a Friday to release a major document. Stage 3 will start no earlier than 2017.

Simultaneously, ONC released its proposed update to EHR certification regulations, to be known as the 2015 edition.

Both documents will appear in the Federal Register March 30, triggering a public comment period. CMS will take comments on the MU rule through May 29, while ONC will do so on the certification plan through June 30. Expect to see final rules before the end of the year.

From an HHS e-mail announcement:

Together, these proposed rules will give providers additional flexibility, make the program simpler and reduce burden, drive interoperability among electronic health records, and increase the focus on patient outcomes to improve care.

The proposed rules are one part of a larger effort across HHS to deliver better care, spend health dollars more wisely, and have healthier people and communities by working in three core areas: to improve the way providers are paid, improving the way care is delivered, and improving the way information is shared; to support transparency for consumers, health care providers, and researchers; and to strengthen decision-making.

“The flow of information is fundamental to achieving a health system that delivers better care, smarter spending, and healthier people. The steps we are taking today will help to create more transparency on cost and quality information, bring electronic health information to inform care and decision making, and support population health,” said HHS Secretary Sylvia M. Burwell.

The Meaningful Use Stage 3 proposed rule issued by CMS specifies new criteria that eligible professionals, eligible hospitals, and critical access hospitals must meet to qualify for Medicaid EHR incentive payments (Medicare incentive payments end in 2016). The rule also proposes criteria that providers must meet to avoid Medicare payment adjustments (Medicaid has no payment adjustments) based on program performance beginning in payment year 2018.

The 2015 Edition Health IT Certification Criteria proposed rule aligns with the path toward interoperability – the secure, efficient, and effective sharing and use of health information – identified in ONC’s draft shared Nationwide Interoperability Roadmap. The proposed rule builds on past editions of adopted health IT certification criteria, and includes new and updated IT functionality and provisions that support the EHR Incentive Programs care improvement, cost reduction, and patient safety across the health system.

The Stage 3 proposed rule’s scope is generally limited to the requirements and criteria for meaningful use in 2017 and subsequent years. CMS is considering additional changes to meaningful use beginning in 2015 through separate rulemaking.

Enjoy perusing the 301 pages of the Stage 3 proposal and 431 pages of the certification proposal this weekend!

March 20, 2015 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

Stage 3 Meaningful Use proposals at White House for final review

Why do these things always seem to happen late on Friday afternoons? At least this time it’s not right before a holiday. Actually, with a bit more inspection, I see that it did happen right before a holiday.

HIMSS is reporting today that the White House’s Office of Management and Budget is “in its final stages of review” of the proposed rules for Stage 3 of the Meaningful Use EHR incentive program. OMB always goes over proposed and final regulations to measure the fiscal — and, presumably, political — impact before allowing executive-branch agencies to make public releases.

A peek at OMB’s reginfo.gov site indicates that the MU Stage 3 proposal from CMS and related ONC plan for certification of EHRs are indeed at OMB for final review.

“We are proposing the Stage 3 criteria that [eligible professionals], eligible hospitals, and [Critical Access Hospitals] must meet in order to successfully demonstrate meaningful use under the Medicare and Medicaid EHR Incentive Programs, focusing on advanced use of EHR technology to promote improved outcomes for patients. Stage 3 will also propose changes to the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use. These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements,” CMS states in a rule summary on the OMB site.

A placeholder date (“02/00/2015 “) on the same page suggests that the proposal will be published in February. However, a placeholder date on the page for the forthcoming ONC certification standards indicates that the plan was supposed to come out in November.

And the date the two notices appeared on the reginfo.gov? Dec. 31, when pretty much everyone was already checked out for the extended New Year’s weekend.

Stage 3 is scheduled to start no earlier than Oct. 1, 2016, for hospitals and Jan. 1, 2017, for individual providers.

 

January 9, 2015 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

Breaking: ONC’s Judy Murphy leaving for IBM job

Judy Murphy, R.N., Director of the Office of Clinical Quality and Safety in the Office of the National Coordinator for Health Information Technology, and the ONC’s chief nursing officer, is stepping down Oct. 17 to become CNO of IBM Healthcare Global Business Services.

Murphy has been with the ONC since December 2011 after 25 years as a nursing and informatics expert at Aurora Health Care in Wisconsin; she had led Aurora’s EHR program since 1995. Most importantly to those of us in the media, she has never been afraid to speak her mind and provide good quotes. Now that she’s moving back to the private sector, she won’t be hamstrung by political and considerations when she gives public presentations.

According to National Coordinator Karen DeSalvo, M.D., health IT specialist Jon White, M.D., will be on part-time detail from the Agency for Healthcare Research and Quality to serve as interim head of the Office of Clinical Quality and Safety and acting ONC chief medical officer until those positions get permanent replacements. (Former ONC CMO Jacob Reider, MD, is now deputy national coordinator.) Andy Gettinger, M.D., of Dartmouth Hitchcock Medical Center, will head up patient safety efforts at the ONC on an interim basis.

Judy’s CNO responsibilities will be entrusted to the other nurses at ONC until a replacement CNO can be named,” DeSalvo said in a memo to ONC staff.

October 3, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

Infographics: Health IT leadership and salaries

It’s infographic time! In fact, it’s time for two infographics.

The first is from HIMSS, celebrating 25 years of the organization’s annual health IT leadership survey. Some interesting findings, as pointed out by a HIMSS publicist:

  • 1991- 75 percent say their institution’s financial health is helped by computers
  • 1994 – 14 percent predict that digital patient information will be shared nationwide in 1-3 years
  • 2000 – 70 percent of respondents say HIPAA is a top business issue.

 

The second infographic comes from HealthITJobs.com. Not surprisingly, the most lucrative jobs are in consulting, and those with experience get paid significantly more than newbies.

September 18, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

EHRs and patient safety

If you wonder where I’ve been, I’ve, for one thing, been blogging a bit for (very little) pay over at Forbes.com and writing a lengthy cover story for the September issue of Healthcare IT News.

The Healthcare IT News piece actually breaks down into a fairly short lead story and several sidebars, which aren’t all that evident from the traditional Web version. (The digital edition has everything.) For the sake of convenience, here are links to all elements of the cover package:

Main story: “Patient safety in the balance: Questions mount about EHRs and a wide range of patient safety concerns”

Sidebars:

The issue also contains a reprint of my May 2012 blog post, written just a week after my father’s death: “Medical errors hit home.”

Happy reading, and happy Labor Day weekend.

August 29, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

APSO vs. SOAP, continued

A couple weeks ago, I had a story in Healthcare IT News about the growing use of the “APSO” notes for documenting patient encounters. APSO flips around the traditional SOAP format (subjective, objective, assessment, plan), ostensibly making it easier to view progress notes in electronic health records.

As I reported, APSO is in wide use at University of Colorado Health and at Lucile Packard Children’s Hospital in Palo Alto, Calif. Baystate Health in Springfield, Mass., found that hospitalists focused most of their attention on the “impression and plan” sections of patient records, essentially the AP part of APSO/SOAP. Physicians at Epic Systems, according to University of Colorado’s Dr. C.T. Lin, are recommending APSO as a best practice.

Yet, the inventor of the SOAP note, Dr. Larry Weed, still believes his format is superior. You saw his comments in the Healthcare IT News story. But every time I have the privilege of speaking to the nonogenarian Renaissance man, he always has more to say than I can fit into the average article. I often can’t keep up in my note taking, but, fortunately, in this case, Weed and his son/occasional co-author Lincoln, took the time to put their thoughts in writing for me.

I left most of their comments out of the story due to space limitations. I don’t have that problem here, so I present their entire statement to me:

The following represents our collective thoughts, including references to relevant portions of Medicine in Denial [their 2012 book].

The supposed advantage of the APSO alternative — that it begins with the physician’s assessment rather than data — is actually a failing. This sequence tends to make the note provider-centered rather than patient-centered, and judgment-based rather than evidence-based.  In contrast, beginning the progress note with data disciplines the provider’s assessment. The provider must think in terms of specific data, specific problems on the problem list to which the data relate, and the interrelationship of each problem to the other problems on the list. Moreover, it’s important to begin the progress note with subjective (symptomatic) data from the patient rather than so-called “objective” data,  As Medicine in Denial states (p. 168):
“… progress notes should begin with subjective data, because progress should be assessed from the patient’s point of view.  Practitioners should be alert to discrepancies between subjective and objective data (for example, where the patient does not feel better when lab results show improvement). These discrepancies may signal an error in data or misstatement of the patient’s problem.”
In short, provider thinking can be disciplined with problem-oriented SOAP notes as a standard of care. Yet, regulators and academics who are in a position to act on this issue have shied away from the whole notion of standards of care for organizing data in medical records. See our comments on ONC’s Stage 2 regs and our comments on the PCAST Report.
The need for standards of care in medical records goes far beyond the SOAP vs. APSO issue in progress notes. In fact, that issue is secondary. Two more fundamental issues for medical records are the following:
  1.  Determining initial inputs to the record. Initial inputs are determined by selection of data needed for the patient’s problem situation, and once the data are collected, analysis of the results.  Both selection and analysis are fatally compromised when determined by the physician’s clinical judgment. External standards and tools, based on a combinatorial standard of care, must govern the selection and analysis. Once that happens, then judgments of patient and practitioners (not just physicians) may supplement the combinatorial minimum standard.  See Medicine in Denial, pp. 53-61, 69-79, 136-37, 145-52.
  2.  Organizing the medical record around the problem list. Once initial data are collected and a complete problem list is defined, then care plans, orders, and progress notes should be problem-oriented, that is, labeled by the problem(s) to which they relate on the problem list. This disciplined practice is essential to justifying provider actions in terms of defined patient needs. Yet this practice is not followed or enforced with consistency. Indeed, some EHR systems do not even enable electronic links between the problem list and care plans, orders and progress notes. See Medicine in Denial, pp. 134-35, 144, 159-60, 166-67.
Like so much else in medicine, medical record practices are a Tower of Babel. Medicine need standards of care for managing clinical information (knowledge and data) no less than the domain of commerce needs accounting standards for managing financial information. This failing is a primary root cause of the health care system’s failures of quality and economy.

For that matter, Lin had more to say than what you saw in the story. He discussed the supposed importance of the subjective and objective elements. “That’s true in cases where there is diagnostic uncertainty,” Lin said. But he added that those components are still there for reference, jut not up front.

Lin called SOAP “a phenomenal innovation,” but suggested that EHR complexity sometimes makes it difficult to find the assessment and plan. For example, he said that a non-Epic EHR in the emergency department at UC Health has as many as 17 different screens for progress notes. “At least with APSO, you would collect the assessment or plan in the first half,” Lin said.

Because SOAP is so entrenched, Lin ran into much resistance when he proposed switching to APSO at 40 affiliated practices. He, of course, heard the tired, “But we’ve always done it this way” defense.

“I learned myself about culture change very acutely,” Lin said. “I was literally shouted out of the room by our physician leadership.” He had neglected to prepare the heads of various departments and clinics for the change in advance of the meeting where he announced the plan.

He subsequently had to have individual conversations with all 40 practice directors. And then Lin dropped a great quote from none other than Niccolo Machiavelli (speaking of Renaissance men): “Those who benefited from the old order will resist change very fiercely.”

Yes, that’s absolutely perfect for an industry as resistant to change as healthcare. But is APSO superior to SOAP? I’d love to hear your thoughts.

May 20, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

Digital health at the Mid-America Healthcare Venture Forum

In case you haven’t seen the official announcements or caught my tweets, later this month I will be moderating a panel at the Mid-America Healthcare Venture Forum, an event being put on by MedCity News, April 22-23 at the J.W. Marriott hotel in Chicago.

The panel is called “Opportunities (and Challenges) in Digital Health. Per the official description: “Digital health — and its business models — are coming of age. Promising young companies are integrating into healthcare and, in some cases, beginning to find exit partners. But that’s also meant new scrutiny from everyone from investors to the FDA. Learn about the challenges, opportunities and promising new markets in digital health.”

Panelists include: Amy Len, director of Chicago-based accelerator Healthbox; Julie Kling, director of mobile health at Verizon Wireless; and Jack Young, who heads the Qualcomm Life Fund for Qualcomm Ventures. I’ll just be there to keep order, and, of course, to cast my usual, skeptical eye on the field and continue to wonder why investors are throwing so much money at me-too fitness trackers and countless direct-to-consumer products that don’t stand a chance in an industry where nearly everything is paid for by third parties. Or at least that’s my thought at the moment, until we have our conference call next week. :)

The session is scheduled for Wednesday, April 23, at 8:55 a.m. CDT. The hotel is located at 151 W. Adams St. in the heart of the Financial District. Years ago, I worked about two blocks west of there, so I know it’s about 40-45 minutes away from me by public transit, and I’m not a morning person. This could get  interesting. (If any MedCity people are reading this, I’m kidding. I’ll be there on time. Hopefully.)

Our session follows a keynote from James Rogers, chairman of Mayo Clinic Ventures. After the panel is a break, then breakout sessions featuring presentations to investors from startups in digital health, medical devices and pharma/biotech. I hope I don’t prematurely burst anyone’s bubble with too much of a reality check. But, in honor of this week being the 25th anniversary of the release of the great Gen X satire, “Heathers,” I offer this quote from the movie: “Heather told me she teaches people ‘real life.’ She said, real life sucks losers dry.”

Wait, was that too cynical?Let me just say that the panel just got another thing to talk about today, as the FDA, FCC and ONC just released their proposed health IT regulatory strategy, as called for by the Food and Drug Administration Safety and Innovation Act (FDASIA). To nobody’s surprise, they recommend a “risk-based framework” to regulation of health IT and digital health. Now to figure out if there are any details people should be concerned about…

In the meantime, you can register for the conference here.

April 3, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

Video: Farzad Mostashari on patient engagement, ‘physician ACOs’

As I alluded to earlier, I was leaving the press room one afternoon at HIMSS14, and there I see former national health IT coordinator Dr. Farzad Mostashari hanging around Gregg Masters and Dr. Pat Salber of Health Innovation Media. It turns out, Masters and Salber had just pulled Mostashari aside to do an interview on video, but they didn’t have anyone to interview him on camera, so they asked me right there on the spot to be the interviewer. Here is the result.

Mostashari, now a visiting fellow at the Engelberg Center for Health Care Reform at the Brookings Institute in Washington, discussed how the years of searching for a business model to coordinate care and engage patients is finally starting to pay off. Always the champion of the little guy in healthcare, Mostashari also brought up the notion of physician-led ACOs, or, as he called it, the “Davids going up against the Goliaths.”

 

I had pretty much no preparation for this interview. It probably shows. I still think it worked out well.

Here’s a link to Salber’s post about the interview because I don’t want to steal page views. :)

March 14, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

All my HIMSS coverage in one place

The last of my 10 MedCity News stories from HIMSS14 has been posted. It’s a nice mix of news, features, analysis and commentary. Here are links to all of them, in chronological order.
NantHealth launches Clinical Operating System – biggest of big data startups – with $1B (Feb. 25)

Body + biology + behavior: Intel exec explains how technology is making N=1 care possible (Feb. 26)

Tavenner: 2014 is your last chance for a hardship exemption for Meaningful Use 2 (Feb. 27)

HIMSS crowd skeptical of promise for flexibility on MU2 hardship requests (Feb. 27)

Google Glass startup expecting third healthcare client in less than 6 months (Feb. 27)

DeSalvo: True EHR interoperability – and a national HIE – is possible by 2017 (Feb. 28)

DeSalvo meets and greets – briefly – while Tavenner keeps her distance at HIMSS (March 3)

HIMSS Intelligent Hospital tracks patients, pills and clinicians in completely connected loop (March 5)

Interoperability Showcase uses car crash to show how connected data really can improve patient care (March 5)

Athenahealth’s first inpatient product isn’t quite an EHR, but a ‘Trojan horse’ into hospitals (March 10)

 

March 12, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.

CMS clarifies MU2 hardship exemptions

As I reported for MedCity News at HIMSS14 nearly two weeks ago, CMS Administrator Marilyn Tavenner announced plans to provide unspecified flexibility in claims for Meaningful Use Stage 2 hardship exemptions this year. Tavenner then left without speaking to the media.

The news left a lot of people scratching their heads and waiting for some details. Today, CMS issued some clarification, confirming that there would be exemptions for healthcare providers unable to have EHRs certified to 2014 standards in place for the 2014 reporting year. This is particularly important now because Medicare penalties for not achieving Meaningful Use take effect next year, but they are based on the 2014 reporting year (Oct. 1, 2013-Sept. 30, 2014 for hospitals, the 2014 calendar year for physicians and other individual “eligible providers.”)

The guidance confirms that CMS is aware of the problems caused by the slow pace of certification to the new, 2014 standards that Stage 2 requires. As of today, according to the ONC Certified Health IT Products List (CHPL), there are 3,736 ambulatory and 1,200 EHRs and EHR modules certified to 2011 standards, but just 899 total that meet 2014 certification.

Here’s the one-page CMS guidance for hospitals/critical access hospitals and the one for eligible providers.

March 11, 2014 I Written By

I'm a freelance healthcare journalist, specializing in health IT, mobile health, healthcare quality, hospital/physician practice management and healthcare finance.