As you may know by now, a long-awaited Notice of Proposed Rule Making was issued on December 30^th by CMS to outline the criteria for providers to show “meaningful use” of electronic health records. It is perhaps the most important news from the government for our industry since ARRA was signed into law last February. We produced several resources to help providers navigate the criteria and work towards qualifying for ARRA stimulus payments: 

• Getting to “Meaningful Use” - an online guide that walks providers through six critical steps toward becoming meaningful users of EHRs, including tips and advice on: researching EHRs; what to look for in product demos; planning a timeline for selection and implementation of the EHR; and preparing their staff for change.
• NextGen Community Forum - a public discussion board for providers to post comments and questions about meaningful use criteria. NextGen Healthcare will incorporate the feedback in its official response to CMS.
• Economic Stimulus and Healthcare Reform Update – a bi-monthly webinar series where you can learn how to maximize your stimulus incentives.
• Inside Health Reform - a stimulus portal with case studies, videos, white papers, and an EHR revenue improvement calculator.
• Grants Resources Center - valuable information about Beacon Communities, SHARP and other funding being made available as part of ARRA, and how NextGen can support your application submission.

I hope you find these resources helpful. We’ll keep them updated with fresh, actionable content that will help you get to meaningful use.

Last week we saw the release of $851 million in grant funds to the nation’s community health centers. Selected centers may choose to allocate some of their grant funding towards either the adoption or expansion of health IT solutions. This being the first of the major grants distributions from the American Recovery & Reinvestment Act (ARRA), it can also be viewed as a reminder to all general practice physicians that the time for them to be eligible to receive qualified funding is nearing.

In the most recent NextGen HIT Stimulus Update video I stated that physicians should be making their HIT purchasing decisions now. Physicians should not be lead astray by possible confusion around meaningful use, but rather take the information they do have and make the best-informed decision they can for their practice. The CHC grant release announcement is proof that this is the case Why would the government release such a large portion of money for HIT investment if it was not comfortable that there was sufficient information on meaningful use for providers to select the right IT solutions- remember CHC’s have to comply with meaningful use as well.

Whether a CHC or an independent medical provider, begin your selection process now- 2011 is only 18 months away.

I am very happy to report that today, as was thought, the Office of the National Coordinator released some additional recommendations to help define “meaningful use” for physicians. Clarification around this term is key for physicians who have been on the fence of the health IT purchase.

The meaningful use preamble and matrix are available on the NextGen Stimulus page. You can view the documents at:
Meaningful_Use_Matrix_6-16-09.pdf
Meaningful_Use_Preamble_6-16-09.pdf

What are your thoughts on this first glimpse into meaningful use criteria?

The Federal Government is close to weighing in on the definition of meaningful Use. We expect news on specific criteria imminently, maybe as early as tomorrow.

Still, even as we inch closer to receiving clarity, physicians should not let any confusion around this term keep them on the sidelines of the HIT decision making process. Physician practices and hospitals can be using what they know today to determine which HIT solution is best for them.

Some specific questions I’d recommend you’d ask the various HIT providers whose product you may be include:

·      Is their product certified under the current CCHIT program and, if so, in what year?

·      Is their solution capable of electronic prescribing?

·      What type of support will your practice receive as you go through the cultural change of switching from a paper to an electronic-based system?

Each of these key considerations will not only be important as you look to complete a smooth transition, but are also factors in the level of incentive funds you receive back from the Federal government for the HIT purchase, implementation and quality reporting.

You can also see more by viewing a recent video that looks to provide information and guidance for physicians as they start the HIT buying process. http://digg.com/d1tdg5

There are still a lot of questions swirling around about ARRA and the EHR stimulus dollars. Will CCHIT remain the certifying body? What is meaningful use? Does your EHR need to be live in 2010 for you to get money in 2011? How will the money be paid?

These are all good questions but they address concerns for the practice and not for the patient. So what can the patient expect out of the EHR provisions in ARRA? It is quite clear that interoperability will be a large part of the mix so patients can expect that they will have to agree to have their information shared. Whether that is an opt-in or opt-out process is not clear, but they will be offered a choice as to whether their data can be shared. Sharing of information will allow physicians to see medications prescribed elsewhere and this can result in fewer drug interactions occurring. It allows information to flow directly from your primary care physician to your specialist, reducing the number of questions you need to answer when you see the specialist. It also allows your primary physician to see what other physicians are planning in real time rather than weeks later as can occur with dictation, paper reports, and standard mail.

If the concept of the Patient Centered Medical Home (PCMH) takes hold, patients can expect that they will be able to communicate electronically with their physicians for administrative items (appointments, refill requests), medical questions, and for treatment for minor illnesses that do not require a face to face visit. This should result in much more convenience, time saving, and money saving. This model allows the patient to know they have one trusted source who can guide them through the healthcare maze similar to how a concierge practice functions now. Because insurers pay for the physician to coordinate the care, they have time to provide these services.

There has been a great deal of talk in recent years about how this country spends more on health care per capita than any other, but the measures of the quality of care that we provide (infant mortality, overall mortality, preventive care delivered) fall short of other industrialized countries. So, patients can expect that their physicians will be partially paid based on the quality of care he or she provides and that the quality of the practice will be publicly reported. Patients would then have the opportunity to review how well a practice does on quality metrics relevant to them. A patient could also expect that there will be more outreach and effort on the part of the practice to be sure that they are compliant with preventive services and are trying to lead as healthy a lifestyle as possible. So, they can expect more education, encouragement, and nagging on topics such as diet, exercise, and smoking cessation.

There is the potential to get some serious money in the upcoming stimulus package if you use an EHR. Of course, you'll actually need to have an EHR and use it "meaningfully" (whatever that ends up meaning). For some background, I am the CMO at Crystal Run Healthcare in upstate New York. We implemented NextGen 10 years ago when we had 15 or so doctors and around 40 employees. Crystal Run is now a multispecialty medical practice with 12 locations, over 150 physicians and nearly 1000 employees. I firmly believe that the EHR helped us to grow rapidly and improve the care we deliver. It's not easy, but it's worth it. Maybe more on that at another time.

The ARRA money will help with the costs of setting up an electronic office. If you are ready to go by 2011, a total of $44,000 over 5 years per provider could be had. This is also some of the first money that allows early adopters to get something back for their investment. Grant monies in the past for EHR's have tended to follow the adage: the early bird catches the worm, but the second mouse gets the cheese- most incentive programs pay new comers rather than rewarding early adopters.

If you're coming in to the EHR picture now, I wouldn't wait too long to get started. It takes quite a while to get to the point where you'll start to use the EHR to see patients. Certainly to use the product "meaningfully", you'll want to be fully implemented as soon as you can.

Coming off of the HIMSS Annual conference where the big talk was on the American Recovery and Reinvestment Act (ARRA), the major discussion now must center around what the government will be determining as a certified HIT solution for the medical providers to be able to show meaningful use. There are many opinions circulating around these two concepts. I will offer my opinions here.

The only logical program for the government to pursue - given the timeframe in the law to have a set of standards in place by 12/31- is to start with the CCHIT process as of CCHIT 2008. However this is not enough because the interoperability criteria and the data reporting components of meaningful use must be built from there. So, beyond CCHIT 08 we must move quickly.

Any HIT solution that is not starting from this set of criteria today, will not be supporting the government’s position to address meaningful use in a complete way. To help focus this dialogue, the Electronic Health Record Association (EHRA) is working on a position paper to begin the discussion. I encourage all to review this document, once it becomes available and offer comment.

One might say that I am completely biased –coming from an HIT provider that is a member of the EHRA and is already CCHIT 08 certified. I would suggest that if we are truly embarking on an automation plan as designed in the ARRA, and we want to keep patient care foremost in our mind, there is no other course of action.

However, to be fair, I would invite the reading public to offer alternatives – either on this blog or on others- so that the patient consumer can be assured that the taxpayer money in the ARRA is being put to the best use. Patient care needs to be first, the ability of the clinician to use automation properly for enhanced patient care needs to be considered second and then the perspectives of the HIT providers can be discussed third.

Well HIMSS is over. There was good attendance considering the economy and the Chicago location (with snow on Sunday) but not quite as good as last year. Not surprisingly, the question on everyone's mind was how meaningful use would be defined. Physicians and administrators wanted to know so they could make informed buying decisions and vendors wanted to know so they could assure buyers that they would meet the requirements. Unfortunately Dr. Blumenthal does not take office until next week so we had sessions with the outgoing National Coordinator, Dr. Kolodner, but not the incoming one who will be making many of the decisions. Currently, there were many people who feel they know what will be required but of course that remains to be seen. Most of the opinions were that CCHIT would remain the certifying body, at least for now, and that quality reporting, and interoperability would be major components. Each stakeholder group is busy writing up their recommendations for the incoming ONC and Secretary of HHS. The confirmation hearings will not come to a vote until after the Senate recess.

What should not be surprising any time there is a large amount of money at stake is the number of people who wish to get a cut – there is $18 Billion to be directed towards the purchase and meaningful use of EHRs. There are those who would be intermediaries in the process to help physicians select and implement systems (for a fee), those who think that bits and pieces of various electronic tools should qualify a physician for the incentive rather than the use of a full featured EHR. Since the amount of the incentive is approximately the cost for a physician to purchase a fully functional certified EHR, I have to assume that is what the Congress intended but when language is left vague such as it is with the term meaningful use, these things will all be subject to a great deal of lobbying. So not surprisingly, many physicians are holding off on purchasing for the short term until there is a more complete definition. They should not delay too long though as it does take time after going live with a system to have enough data entered to be able to report quality measures and 2011 is just around the corner.

Some doubt the need for government incentives for the adoption of health information technology thinking that current products are either not ready for use or that these incentives stifle innovation. Note today’s article in The New York Times.

Doctors Raise Doubts on Digital Health Data

I strongly disagree. It has been well documented that the majority of the benefits of health information technology do not accrue to physicians who bear the burden of purchasing them but rather to the patient and the payer. This has contributed to the low rate of adoption of HIT among physicians. These incentives remove the financial disincentive and the legislation also allows for regional centers to help physicians make the best use of their EHRs. While HIT in and of itself cannot improve the quality of care, high quality care cannot be provided in an efficient fashion without their use. The current certification process for CCHIT assures that certified EHRs are interoperable so information can be shared, lowering the risk of adoption to physicians should they wish to change to another more innovative product at a later date. Certification also means that the key functions necessary to meet the goals of improving quality of care with clinical decision support, guidelines, and reporting capability. Rather than stifling the market, this incentive has stimulated many new EHR companies to seek certification. While the idea of open source software is appealing, the resources needed to develop a comprehensive EHR capable of certification are beyond what one could expect to be available by a volunteer community of developers.

CCHIT has accelerated their plans for advanced certification in several areas. The core certification remains on its usual schedule determining the requirements that an electronic health record must have in the areas of interoperability, functionality, privacy, security, and compliance. These advanced certifications will help physicians select products that have more advanced capabilities in the areas of interoperability, security, clinical decision support, and quality reporting.

Many practices want to move to the higher level they anticipate may be required to meet the mandates for "meaningful use" of an EHR and qualify for the incentive payments. We do not have details on exactly what that will mean as that determination will be made by the new secretary of HHS in consultation with the recently named National Coordinator of HIT, Dr. David Blumenthal. Many experts do think that central to that definition will be enhanced interoperability and tools that provide decision support at the point of care and can easily report quality measures.

Currently interoperability requirements for certification include the ability to receive lab results electronically, to e-prescribe, to link to a PACS system, and to import and export a CCD. Advanced certification may include more codified data being sent and received using the CCD document, it may include bidirectional lab interfaces or reporting to immunization registries or quality registries. Clinical decision support is already included in the requirements so advanced CDS may mean linkages to online decision support or making the CDS presented to the end user actionable. Advanced quality may mean reporting of more complex measures or reporting electronically to a registry or CMS.

The volunteers who make up the workgroups will determine these requirements along with stakeholder who participate in the public comment process. The more people participate, the better the work product. It is especially important for practicing physicians to make the time to participate since these decisions have a tremendous impact on the software that is available for their purchase. You may apply to be a workgroup member at www.cchit.org by the end of the week.