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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 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 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.

Health Wonk Review talks turkey

I’ve been a bit remiss the last few days, in that the latest Health Wonk Review came out Thursday, and I’m  just getting around to sharing it now.( Blog carnivals work best when contributors link back to the compilation.) But, better late than never, right?

In that spirit, and in the spirit of Thanksgiving, I invite you to check out Health Wonk Review: The Turkey Edition, hosted by David Harlow on his HealthBlawg. The big stories this time around are all about insurance coverage under the Patient Protection and Affordable Care Act, a.k.a., Obamacare, but there is also an interesting posts about “wrist slaps” given to pharmaceutical executives for allegedly violating drug-marketing laws.

My post at about the American Medical Association belatedly but predictably fighting the impending Medicare penalties for not meeting Meaningful Use makes the cut. I’m particularly proud of the line, “Ruthlessly Defending the Status Quo Since 1847. :)

Check it out, and for those of us here in the United States, have a happy Thanksgiving. I’ll see you after the long weekend.

November 25, 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 extends 2014 MU hospital attestation until end of year

Just days before the clock was to run out on hospitals, including Critical Access Hospitals, hoping to attest to Meaningful Use of EHRs for 2014, the Centers for Medicare and Medicaid Services has pushed back the attestation deadline by a month, until Dec. 31.

In an announcement posted yesterday on the CMS Meaningful Use registration and attestation login page, CMS said: “CMS is extending the deadline for Eligible Hospitals and Critical Access Hospitals (CAHs) to attest to meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 2014 reporting year from 11:59 pm EST on November 30, 2014 to 11:59 pm EST on December 31, 2014.”

Just don’t expect to do so online during a short period in a couple of weeks, as CMS says the site will be down for maintenance from Friday, Dec. 12 at 10 a.m. EST to Saturday, Dec. 13 at 12:30 p.m. EST. CMS also says people “may experience intermittent connectivity” Nov. 30 between 12:01 and 5 a.m. EST.

This extension “will allow more time for hospitals to submit their meaningful use data and receive an incentive payment for the 2014 program year, as well as avoid the 2016 Medicare payment adjustment,” CMS says.


I Written By

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

Podcast: Scot Silverstein talks health IT safety risks

In a sidebar to the September cover story I did for Healthcare IT News, I reviewed some of the work of Scot Silverstein, M.D., who has long been chronicling problems with EHRs and other health IT systems. Unfortunately, he wasn’t available for an interview in time for that report, but he was last week, so I got him for a new podcast.

Silverstein, a professor of health informatics at Drexel University in Philadelphia, considers EHRs to be experimental and, sometimes, less safe than paper records and would like to see health IT subjected to the same kind of quality controls as aerospace software or medical devices. “Suboptimal system design could lead even careful users to make mistakes,” Silverstein said in this interview.

During this podcast, we refer to a couple of pages that I promise links to, so here they are. Silverstein writes regularly for the Health Care Renewal blog, a site founded by Roy Poses, M.D., a Brown University internist who runs the Foundation for Integrity and Responsibility in Medicine. His definitions of good health IT and bad health IT appear on his Drexel Web page.

Podcast details: Scot Silverstein, M.D., on health IT safety risks. MP3, mono, 128 kbps, 33.8 MB. running time 36:59.

1:10 How this interest came about
3:05 His blogging
3:45 His 11 points demonstrating why he believes the FDA should be concerned about health IT risks
5:00 IOM, FDA and ECRI Institute statements on health IT safety
5:50 Comparing EHRs to medical devices and pharmaceuticals
8:35 Lack of safety testing in health IT
9:25 Issues with EHR certification
10:00 Safety validation of software
10:35 EHR’s role in Texas Health Presbyterian Hospital’s initial discharge of Ebola patient
11:50 EHR failure causing medical harm to a close relative
13:10 Poor design vs. poor implementation
14:35 Who should regulate?
15:55 Billions already spent on EHRs
16:45 Threat of litigation
17:40 “Postmarket surveillance” of “medical meta-devices”
18:50 EHRs now more like “command and control” systems
19:30 Movement to slow down Meaningful Use
20:17 Safety issues with interoperability
21:40 Importance of usability
22:30 His role at Drexel
24:18 “Critical thinking always, or your patient’s dead”
25:05 Lack of health/medical experience among “disruptors”
29:30 Training informatics professionals and leaders
31:15 Concept vs. reality of “experimental” technology
32:50 Advice for evaluating health IT
33:55 Guardians of the status quo
35:10 Health IT “bubble”
36:10 Good health IT vs. bad health IT


October 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.

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 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.

Podcast: Greenway Health CEO Tee Green on interoperability, consumerism and more

Health IT vendor Greenway Health recently finished its rollout of a cloud-based EHR to all 8,200 Walgreens stores in the U.S. When I was offered the chance to interview CEO Wyche T. “Tee” Green III about this, I decided to take it a step further.

In all my years of covering health IT, I’ve never met nor even spoken to Green, so I figured a podcast was in order. After all, I had written a piece for Health Data Management earlier this year about how pharmacies are reshaping themselves as true healthcare companies. (This interview also comes in the wake of CVS Caremark ending its sale of tobacco products and changing its name to CVS Health.)

I also had a lot of questions about interoperability issues in health IT and the many criticisms that lately have been heaped on both EHR vendors for perceived usability problems and the federal Meaningful Use EHR incentive program. The timing couldn’t have been better.

Podcast details: Interview with Greenway Health CEO Tee Green, recorded Sept. 8, 2014. MP3, mono, 128 kbps, 25.5 MB. Running time 27:51

1:00 Walgreens rollout and EHRs for “retail health”
3:20 Future expansion to Walgreens Healthcare Clinic locations
4:15 My own experience with lack of interoperability at a CVS MinuteClinic
5:30 Achieving EHR interoperability
7:30 Frustration with slow progress on Meaningful Use
10:30 Data liquidity
12:30 Update on CommonWell Health Alliance
14:25 Addressing criticisms that vendors are hindering interoperability
16:30 EHR usability
18:10 Greenway Marketplace app store
22:15 Patient engagement and slow start to Stage 2 Meaningful Use
24:10 Dealing with the rise of consumerism in healthcare

I’ve been kicking around in my mind the idea of hosting a regular podcast, perhaps as frequently as weekly. If so, what day of the week would you prefer to hear a new episode?

September 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.

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 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”


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.

Adelphi U ad spreads health reform fallacy

The following ad has popped up several times on my mobile Facebook app recently:

Adelphi Facebook ad
That’s from Adelphi University in Garden City, N.Y., and the first sentence of that ad is absolutely false, not to mention poorly written. There is no government mandate for any healthcare facility to go paperless at all, much less by 2015.

As people in health IT and in healthcare management probably know, the federal Meaningful Use EHR incentive program calls for Medicare penalties starting next year for any provider that hasn’t achieved at least Stage 1 of Meaningful Use. But that’s not a mandate; hospitals and other providers still have the option of participating. Those who don’t see Medicare patients don’t face penalties anyway.

Even those that are able to meet all the Meaningful Use requirements still don’t have to be paperless, at least not according to the Stage 1 and Stage 2 rules. Nor have I seen any evidence that Stage 3 would contain such language, and even if it does, that phase does not start until 2017.

There are plenty of reasons why those who start work on a master’s in health informatics this year will be very much in demand next year. Why does Adelphi need to mislead people in an apparent attempt to create demand for its program?

June 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.