Readers Write 3/26/12

Submit your article of up to 500 words in length, subject to editing for clarity and brevity (please note: I run only original articles that have not appeared on any Web site or in any publication and I can’t use anything that looks like a commercial pitch). I’ll use a phony name for you unless you tell me otherwise. Thanks for sharing!

If You Did It, Enter It in the EHR
By Mitch McClellan

I was recently asked the following by a colleague:

We know that every organization has some physicians who just will not fully use the EHR. They will have nurses, MAs, and other clinical staff do all of the data entry. They may just hand the staff a piece of paper and have them enter the problem list. A specific example would be the MU requirement for weight counseling – do you think it is acceptable for an MA to indicate in the record that the physician did the weight counseling? Clearly it makes sense to have nurses and other clinical staff enter medications and even other orders and even start notes, but where do you draw the line?

This question certainly walks the line between facilitating accurate data entry vs.what is appropriate.

If an organization is truly going to embrace this much-needed change in healthcare, they need to enforce that their clinicians do the right thing. In this case, it would be physicians taking 100% ownership of entering the documentation specific to weight counseling. They are the ones actually provided the counseling.

I understand that is a black-and-white response, but I strongly believe that if an organization’s culture accommodates physicians who choose not to do their complete EHR responsibilities (e.g. not documenting the counseling that YOU provided), then it defeats the entire purpose of what we’re doing.

The EHR revolution is strongly driven by the fact that paper is not efficient and creates too many points of failure. Not only is the medium (paper) antiquated, so are many of the policies and processes that support those paper workflows (e.g. documenting a note that you then pass on to someone else to then "document a note" on your behalf).

Unfortunately, I believe most physicians are put into a "get it done now vs. a get it done right" scenario due to the payers’ stringent reimbursement policies. I completely understand the time demands on these physicians. But the rule I try to instill with all of my groups is that, "if you did it, then you must enter it in the HER." Otherwise, the effectiveness and efficiencies of an EHR are lost if the old way of doing things is still embraced.

The groups that I’ve worked with would require the physician enter that piece of documentation themselves instead of the MA. The only groups that I’ve worked with that would allow this scenario to happen would be if it was the physician’s nurse — not an MA –entering the documentation. To me, the issue is twofold. The first is workflow (reasons already stated), the second is the lack of credentials of an MA. I know I’d want a higher-credentialed healthcare provider entering that information if it’s not the physician themselves.

Mitch McClellan is manager of implementations at MBA HealthGroup of South Burlington, VT.

Optimization
By Dave Vreeland

Cumberland brought together a select group of HIT executives from some of the nation’s leading health systems for a recent breakfast discussion The topic: optimization.

Now that many are on track for Stage 1 Meaningful Use and other compliance deadlines, the focus is beginning to shift beyond go-live toward getting the most out of HIT systems. The panel, made up of Cumberland’s Brian Junghans, HCA’s Dr. Divya Shroff, and Memorial Healthcare System’s Jeff Sturman, shared how non-profit Memorial and industry giant HCA are tackling optimization.

The takeaway: success largely hinges on solid communication and the collaboration of two very different worlds – IT and clinical. Clinicians are arguably the keystone in achieving effective system adoption and long-term optimization.

Junghans points out that IT folks tend to think in terms of projects, which have a defined beginning and end. When it comes to IT implementation projects, the end is go-live. In contrast, optimization is an ongoing effort.

Dr. Shroff points out that clinicians have more of an optimization mindset, with a continuous focus on improved quality of care, optimal patient outcomes, and best practices.

With techies and clinicians in different mindsets, speaking two different languages, communication issues are common. HCA has success placing physicians and other clinical professionals like Dr. Shroff in clinical transformation roles. Valuable insight and hands-on experience makes these clinicians effective ambassadors for both the IT and clinical teams. 

Sturman and the Memorial team have incorporated clinical aspects into their approach to optimization. The team makes regularly scheduled rounds to observe workflow, system usage patterns and identify opportunities for improvement throughout each of their six hospitals, clinics, and ambulatory practices.

The importance of a clear distinction between IT support and optimization teams was also stressed. HCA trains the IT support team to triage incoming calls, address specific break/fix issues, and refer optimization matters to the optimization team.

Both organizations have seen success with various efforts to improve clinical/IT relations and are on track with current and long-term efforts toward optimization.

In addition to a number of lessons learned and critical success factors to consider during and after the implementation process (summarized in our presentation Beyond Go-Live: Achieving HIT System Optimization), it was interesting to hear this room of executives from diverse organizations, representing both the clinical and IT fields, reinforce the significant impact collaboration between the two worlds has on the success of end-user adoption and achieving true optimization.  

Dave Vreeland is partner with Cumberland Consulting Group of Franklin, TN.

Stage 2: The Vendor View
By Frank Poggio

On March 7, 2012, a draft for comment on the new Stage 2 rules was published in the Federal Register. Actually there were two separate parts to the rules. They are:

1. The CMS part that is aimed at provider requirements necessary to meet Meaningful Use, and
2. The ONC piece that addressed proposed changes to the certification process for EHR vendors.

On the provider side, there are innumerable blogs and Web sites that are covering the provider issues, which deal mostly with a few added MU criteria such as electronic medication administration records, menu options in Stage 1 that are now mandatory in Stage 2, greater emphasis on exchanging patent care information across care levels, and greater patient access to care information.

This article will focus on the “second side” of the regulations — the elements that most impact the system suppliers, with emphasis on the impact to niche or best-of-breed (BoB) vendors.

The full text of the new ONC Certification proposed rules can be found at here.

Before we hit the high (and low) points of the rules keep in mind these are proposed rules. If there is anything you don’t like about them, have suggestions for improvements, etc. you have from now until June 7 to post comments on the federal Web site. Speak now or forever hold your price! (No that is not a typo … see the Ugly).

Here’s the Good, the Bad, and the Ugly of proposed certification changes for vendors.

The good news:

Privacy and Security — will it go away?

EHR Module certification gets a little easier for niche and best-of-breed vendors (BoB). The big change here is that Module certification no longer requires you to address any of the privacy and security criteria. In the past, there were eight P&S criteria (number nine was always optional), and in our working through many ATCB tests, if you said the right phrase, you could get a waiver on three others (Integrity, General Encryption, and HIE.) Proposed under the Stage 2 as a niche/BoB vendor, you can ignore all the P&S criteria. To get certified under Stage 2, it would seem all you will need to do is pass any one Inpatient, Ambulatory, or General criteria, just ignore the P&S criteria, and you’re home free.

ONC said they made this change because many of the smaller firms complained that the P&S criteria did not apply or were too burdensome. This may sound too good to be true. Maybe it is. Read what ONC says in other parts of the document:

Finally, we propose to require that test results used for the certification of EHR technology be available to the public in an effort to increase transparency around the certification process. We believe that there will be market pressures to have certified Complete EHRs and certified EHR Modules ready and available prior to when EPs, EHs, and CAHs must meet the proposed revised definition of CEHRT for FY/CY 2014. We assume this factor will cause a greater number of developers to prepare EHR technology for testing and certification towards the end of 2012 and throughout 2013, rather than in 2014.

This is classic ONC. They say you don’t have to get certified. There is no law that says any vendor MUST – even a full EMR vendor. They believe the market will tell you. And by the way, ONC will be publishing the details of your certification so the world can compare you against your peers.

As we tell our clients, the MU criteria you choose to test on is dictated more by your competition and clients, not by the ONC.

Gap certification for Stage 2

A question that we have heard frequently was if I was certified on 20 criteria for Stage 1, under Stage 2, would I have to be tested again for those same criteria? Under the proposed Stage 2 rules, you would not need to get re-certified on Stage 1 criteria. You will only have to be tested on new criteria you select, and tested on Stage1 criteria that has changed or been revised by ONC.

A good example is the encryption P&S test. The focus now will be on encryption for data at rest. They state:

EHR technology presented for certification must be able to encrypt the electronic health information that remains on end user devices. And, to comply with paragraph (d)(7)(i), this capability must be enabled (i.e., turned on) by default and only be permitted to be disabled (and re-enabled) by a limited set of identified users.

So if you tested out on encryption under Stage 1 and want to carry it forward into Stage 2, you’ll probably have to show how you default encryption for user devices.

Component EHR vs. Complete EHR

A typical misunderstanding we came across many times during past year taking our clients through the certification process was a CIO at a hospital would say to the vendor that he/she believed they had to install a full EMR from a single vendor to meet all the MU criteria. In the proposed regulations, ONC has clearly addressed this question. On page 104, they say:

Certified EHR technology means: 1. For any Federal fiscal year (FY) or calendar year (CY) up to and including 2013: i. A Complete EHR that meets the requirements included in the definition of a Qualified EHR and has been tested and certified in accordance with the certification program established by the National Coordinator as having met all applicable certification criteria adopted by the Secretary for the 2011 Edition EHR certification criteria or the equivalent 2014 Edition EHR certification criteria; or ii. A combination of EHR Modules in which each constituent EHR Module of the combination has been tested and certified in accordance with the certification program established by the National Coordinator as having met all applicable certification criteria adopted by the Secretary for the 2011 Edition HER certification criteria or the equivalent 2014 Edition EHR certification criteria, and the resultant combination also meets the requirements included in the definition of a Qualified EHR.

In effect, a provider could meet the MU criteria using as many suites of BoB systems as they believe necessary. They do not have to be from one or the same vendor.

Now some bad news:

Criteria components

Many BoBs struggled with the make up of the criteria for Vitals and Demographics and several other clinical criteria. On the surface, they seemed easy to pass. The problem was they contained some data elements that were not typically found in BoB systems. For vitals, the hurdle was growth charts. For demographics, the hurdle is date and time of death. To pass these criteria, some vendors would use user-defined fields or create new inputs that they knew their clients would never use. Repeatedly I was asked by niche and BoB clients, “Why would you ask a patient during a registration process, ‘When did you die?’” Now there’s a comforting dialog!

Keep in mind several or the participants in building the HITECH/MU program were academics and researchers who would find that piece of information critical to their retrospective medical data analyses. Also, vendors of full EMR systems would easily have that piece of data readily available in their medical record abstract system. But for an ancillary or niche vendor, not likely. As far as I know, there were no niche or BoB vendors represented on any of the HITECH Policy or Standard Committees.

You may wonder why any firm would go through the trouble of adding a useless data element. Again, keep in mind what ONC said above: market will require certification. It can be virtually impossible to sell an ancillary system such as surgery, ICU monitoring, therapy, anesthesia, etc. if you had to tell your prospect your product was not certified for vitals.

Unfortunately this issue is still there for BoBs. The big change is on the provider side. ONC has greatly liberalized the granting of exceptions to providers for MU attestation if the MU criteria (or element of the criteria) do not apply to their practice of facility. As an example, a psychiatrist does not have to do growth charts for his patients — an exemption will be readily available. But the vendor who sold him the system still must!

Continuing this topic, in a recent interview Dr. Mostashari chided EHR vendors who "aren’t making meaningful use of Meaningful Use." Instead of attempting to seamlessly incorporate MU standards into their interfaces, Mostashari said "vendors did what vendors do—they slammed in the criteria and got certified.”

I submit that ONC slammed these regulations into being as fast as they could due to Congressional and Executive pressure, so one good slam deserves another. Maybe if ONC took a moment to look at the impact of certification on niche and BoBs — which are mostly the smaller, more innovative developers — and adjusted the criteria, we all could stop slamming.

And now the ugly:

As I mentioned in an earlier HIStalk post, ONC wants comments on vendor product price transparency. Here’s the ONC statement:

During implementation of the temporary certification program, we have received feedback from stakeholders that some EHR technology developers do not provide clear price transparency related to the full cost of a certified Complete EHR or certified EHR Module. Instead, some EHR technology developers identify prices for multiple groupings of capabilities even though the groupings do not correlate to the capabilities of the entire certified Complete EHR or certified EHR Module. Thus, with the transparency already required by §170.523(k)(3) in mind, we believe that the EHR technology market could benefit from transparency related to the price associated with a certified Complete EHR or certified EHR Module. We believe price transparency could be achieved through a requirement that ONC ACBs ensure that EHR technology developers include clear pricing of the full cost of their certified Complete EHR and/or certified EHR Module on their websites and in all marketing materials, communications, statements, and other assertions related to a Complete EHR’s or EHR Module’s certification. Put simply, this provision would require EHR technology developers to disclose only the full cost of a certified Complete EHR or certified EHR Module.

As a former CFO, I know that the through definition of ‘full cost’ would take at least another 500 pages in the Federal Register. After the vendors in the audience come down off the ceiling, you’d probably like to share your reaction with ONC. Just click here.

Frank L. Poggio is president of The Kelzon Group.