Curbside Consult with Dr. Jayne 10/13/14

We are in the process of adding a variety of self-directed learning options to our EHR training. Up until now, we have had formal classroom training for clinical support staff and practice-based group training for providers.

Although we’ve had good outcomes from training, our paradigm is fairly resource-intensive. Additionally, providers complain about the time they spend in training sessions since it often cuts into their office hours even though we offer sessions before and after typical practice schedules.

One of the advantages of a resource-intensive training program is that it is the resources are intensely involved. When we train in small groups, we can provide individualized attention and can monitor who is catching on and who might be struggling. We can also ensure immediate follow up if attendees don’t pass our competency exam.

In turn, our learners can provide feedback on the effectiveness of our curriculum and presentation style so that we can modify it if needed. This is important when we bring new specialties live that our trainers might not be as familiar with as they are with other specialties.

We’ve had online refresher training for the last several years. It’s largely in the form of recorded web presentations, although we have a number of clips that were done with Adobe Captivate. They’re tied to our learning management system so we can see how many times each piece has been viewed and whether a particular employee is taking advantage of the resources. Managers can access a report of their employees’ activities, but the sessions are not required.

Our goal was to create some 5-10 minute segments that people could watch if they were having difficulty with a particular functionality or a new feature. Feedback has been good.

Given the budgetary pressures facing healthcare organizations, we’ve been asked to enhance our online offerings with a goal of reducing classroom training time. Staff will now be required to view a core set of e-learning offerings and managers will be responsible for tracking compliance.

I’m in favor of e-learning because it can be completed at the employee’s preferred time and location. However, I’m concerned that since reduced training time is the goal, that employees will be shortchanged. I can’t see some of our managers carving out protected training time for new employees. In particular, I know some of them will expect employees to jump right into patient care and learn the EHR on the fly.

Those same managers are likely to expect employees to complete the sessions on their own time even though that’s a violation of company policy. Staff working on uncompensated time might rush the training, or worse, multitask their way through it, diminishing mastery. We have a plan to gather data on whether the new strategy is effective, but based on the number and frequency of new hires, it will likely be six months or more before we know if it’s equivalent to our current platform.

I don’t like the idea of experimenting with our practices. We’ve worked hard to have a successful program and our practices get up to speed very quickly with only rare exceptions. Although we pull new hires out of the office for several days of training, when they return to the practice, they’re able to hit the ground running.

I guess my biggest concern is that there’s really no way to shortcut the material. A trainer — whether in person, recorded, or as part of an e-learning platform — can only impart information so fast. In turn, learners can only absorb so much in a given amount of time.

If this was an experimental drug, we’d first have to experiment on healthy subjects (or those who didn’t really need the training) to make sure it was safe. If it passed those tests, we’d have to experiment on more subjects to determine if it was more effective than placebo. Finally, we’d have to have a limited head-to-head trial against current training standards to determine if we should switch to it or not. Only if it passed certain statistical tests would we use it to replace our current training platform.

Since this is mostly about saving money, you can bet we didn’t have the opportunity to really study the new approach, let alone have an actual pilot or trial. We are being forced to switch everyone over without proof that it’s not going to lead to problems. As normally happens in healthcare IT, we were given a short deadline and limited budget to get it ready.

We’ve been in the business of delivering the impossible for a long time, however, so we’re up to the challenge. As for outcomes, only time will tell.

Have you been able to pare down training and maintain quality? Have great ideas? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 10/6/14

Given the recent events at Texas Health Presbyterian Hospital Dallas, the Ebola virus is all our hospital can talk about. We’ve been combing through our infectious disease protocols and scheduling education sessions to ensure people have access to all the resources available.

It’s daunting to think of what might happen should the disease get a toehold in the US. Many of our hospitals are already taxed with the usual communicable diseases. During flu season last year, one of the local pediatric hospitals had to put a M*A*S*H style tent in the parking lot to handle all the cases coming in.

Although Ebola is statistically less infectious than other diseases (including HIV, SARS, mumps, and measles), the lack of available treatments and high mortality rate frighten the average person. NPR had a great graphic that we’re using to help educate staff and patients about the need to ensure we have appropriate precautions in place to treat all communicable diseases, not just the most worrisome ones.

We have measles outbreaks in our community every couple of years due to some concentrated populations who do not vaccinate. Measles has a fatality rate of around 25 percent in underdeveloped nations, compared with an average fatality rate of 50 percent with Ebola (although specific outbreaks have ranged from 25 percent to 90 percent). For readers who don’t have a clinical background, the World Health Organization fact sheet provides good information about what your clinical co-workers are contemplating.

According to WHO, single travelers have spread the disease to countries including Nigeria and Senegal, which adds to the worry around a traveler bringing it to the US. Unfortunately, the early phases look a lot like other viral illnesses – fever, fatigue, muscle aches, and headache.

I probably saw 10 patients with those symptoms in the emergency department during my last shift. If we had treated each one like a potential carrier, it would have brought our patient flow to a screeching halt. From an epidemiology standpoint, IT resources are going to be critical for surveillance and identification of potential cases in the US.

I’m glad Texas Health Resources released a clarification on their earlier statement that cited a “flaw” in the EHR as contributing to the release of the patient at his initial presentation. Ultimately, it’s up to the physician to take a detailed history and physical. We all know that even with the best nursing protocols, patients will occasionally add details when a second (or third) interviewer talks with them.

It used to drive me crazy as a student when a patient would tell the resident (or worse, the attending) a detail that they had omitted even when I asked specifically about it. It may be the time between evaluations that makes the patient think about other details, or maybe one feels more empowered and able to formulate thoughts after telling the story previously.

My initial response to their statement about a flawed EHR was to take offense on behalf of their physicians. It was almost like saying their physicians aren’t responsible for thinking about elements not prompted by the EHR, or that they’ve totally given themselves over to cookbook medicine. I reached out to a friend on staff there who shared my opinion. Whether there was pressure from Epic to update the press release or whether it was from the medical staff, it was the right thing to do.

Now I’d like to see their root cause analysis on why the history was not taken fully into account and whether the presence of scribes was contributory. I’d also like to know what kind of providers saw the patient and whether there were other circumstances at play, such as shift change, a full patient board, staff who called out sick, etc. Those factors have led to mistakes at my institution and they’re much harder to place solutions around than making sure the EHR fires alerts and that personal protective equipment and isolation rooms are readily available.

I’m curious as to what other institutions are doing to prepare themselves for a potential outbreak. Are you modifying your EHR workflows? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 9/29/14

As a CMIO, I often feel my attention is all over the place. I’m dealing with clinical documentation needs for various constituencies while trying to ensure compliance with a host of federal, state, and other quasi-regulatory standards bodies. I’m also trying to implement tools to measure patient, physician, and employee satisfaction while maintaining my sanity in what seems like an upside-down healthcare world.

Given that background, you can’t imagine the serendipity I found when Dr. Andy’s recent CMIO Rant coincided with my weekend project to review E&M coding.

Due to some discrepancies in coding volumes after a recent ambulatory EHR upgrade, our compliance officers asked for a thorough review of the system’s E&M calculation tools. There are quite a few nuances to how the system codes and we’ve also had some recent coding education outside of the EHR, so I wasn’t convinced we weren’t dealing with another variable.

Our system is flexible and allows physicians to choose either 1995 or 1997 guidelines for each encounter. What if the recent coding class had physicians making different choices than they did previously? What if they were scared by the gloom-and-doom predictions of a RAC audit and undervalued their documentation?

I had been sitting for several hours with my trusty-rusty paper coding review forms, scoring visit documentation based on the guidance from our coding and compliance team. Once a visit was scored, I compared the results to the EHR’s calculations. Our EHR breaks down its coding suggestions parallel to E&M guidelines, so it is fairly easy to compare the bullets it counted vs. what I counted on paper.

Fortunately, our system does not advise on the level of Medical Decision Making, but rather requires providers to select that coding component. I can’t imagine how controversial the review would be if the EHR was prompting it.

There’s so much going on with HIStalk I tend to get behind from time to time. When I couldn’t handle any more bullet-counting, I took a break to catch up on HIStalk Connect and HIStalk Practice. Imagine my delight when I found Dr. Andy’s response to the AMA’s comments on EHR design. His first counter-request for the AMA is for them to help us fight “regulations that require overly detailed physician documentation, like the CMS E&M coding guidelines, which really set a floor of complexity below which we cannot sink.”

I laughed out loud, as I do every time I receive an email from CMS advocating their brand of “administrative simplification,” which has to be the biggest oxymoron ever. Just that morsel would have been enough to make my day, but then he covered their seemingly contradictory request for EHRs to lower cognitive workload while requiring them to enable dozens more tasks than we ever handled on paper. “Massive cognitive workflow” were the words he chose. Having had a 40+ patient clinic day this week, I can attest to the massive nature of the volume of information I had to process to care for them.

Note that I didn’t say data. Data implies the information is in the EHR or another accessible system that I could theoretically review. The reality is that physicians have to handle information on a much broader scale – the patient’s history, family members’ version of the same events, stories about what the patient read on Google, the physical exam itself, in-office testing, and more – on top of the actual electronic data available. Add to that mountain of information the fact that we’re now caring for patients in the office that would have been cared for in the hospital five years ago and it would be easy to become buried.

Reflecting on this massive cognitive workload inspired my new and improved “guidelines” for E&M coding. I didn’t have enough time (or martini fixings) to flesh out the entire scheme, so let’s confine our thoughts to established patient office visits.

Traditional E&M coding poses five levels of service – 99211, 99212, 99213, 99214, and 99215. The value of the visit (and thus the payments) increase as the level of service increases. Typically 99211 and 99212 are not used to bill actually physician services, so I threw them out. Talk about administrative simplification – I just slashed the number of things I have to think about by 40 percent.

Looking at the rest of the codes and what you have to have to justify documentation in the traditional coding construct, I identified some sample visits that were reflective of the codes even by conservative standards. They fell into nice groupings based on the amount of information the physician had to interact with during the visit. I’m not just talking about information that one would have to review, but also information one might have to deliver. Out of ten charts reviewed for each level of coding, I had a 90-100 percent concordance when using the “information burden” scheme to value my efforts.

Here’s how it works.

99213 – Now called “Mild Information Burden”

• Patient has fewer than three issues he/she wants to be seen for today.
• Patient has been seen at fewer than three healthcare facilities/providers in the last three months.
• None of today’s issues will cause death or serious consequences if left untreated.
• Determination of proper treatment requires review of fewer than three data sources (EHR, clinical data warehouse, HIE, antibiogram, CDC bulletin, guidelines website, Sanford guide, discussion with colleague, etc.)
• Treatment requires fewer than three instructions, outside orders, or documents (patient education handouts, prescription, therapy order, referral, prior-auth, FMLA papers, etc.)
• Visit requires less than 15 minutes for documentation.

99214 – Now called “Moderate Information Burden”

• Patient has more than three issues he/she wants to be seen for today.
• Patient has been seen at three or more healthcare facilities/providers in the last three months.
• At least one of today’s issues will cause death or serious consequences if left untreated.
• Determination of proper treatment requires review of three or more data sources.
• Treatment requires three or more instructions, outside orders, or documents.
• Visit requires more than 15 minutes for completion, including documentation.

At this point, based on my “rules of three” and the two levels of coding, you could quit. However, neither category covers what I had to manage for several patients seen in this week’s clinic. I decided to reserve the highest coding level for those special circumstances, but in keeping with the rules of three:

99215 – Now called “Severe Information Burden”

• There are three or more non-office personnel in the exam room (patient, family members, children, interpreter, etc.)
• Patient has been seen by facilities/providers that are members of three or more ACOs.
• At least one of today’s issues will lead to hospitalization in the next three months.
• There are three or more possible ways to treat one of today’s issues, depending on the patient’s insurance status and/or ability to pay for non-covered services.
• More than three separate logins and passwords are required to access the data needed to care for the patient.
• Visit takes long enough that it requires cutting three or more subsequent appointments short in order to catch up.

Maybe it’s just me, but those rules would be much easier to follow than what we currently have. I’d rather use my cognitive skills to deliver quality care and build relationships with patients than to remember whether I’m supposed to be documenting by organ systems or body areas. What does “expanded problem focused” mean anyway? Or “detailed”? I like to think that all my visits are detailed, if not comprehensive. Current E&M coding turns those perfectly good words into something incomprehensible.

Give it a shot – pull a couple of visits and see whether my proposed coding system holds up under the stress of your clinic day.

Do you dream of a world without E&M coding? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 9/22/14

A couple of weeks ago, we performed a major upgrade on our ambulatory system. Officially we’re now ready for both Meaningful Use Stage 2 and ICD-10, with all the bells and whistles installed. As upgrades go, this wasn’t my first rodeo. It went smoothly with only one minor IT concern and no significant incidents for the end users.

Since no good deed should go unpunished, management is now looking to cut our personnel resources for the next one. They can’t seem to understand why several hundred hours of work went into the upgrade because clearly it was “no big deal.” Mind you, these are not old-school IT managers, but members of our ambulatory operations team who want to avoid having super users out of the office.

We rely on the participation of super users, not only from the ambulatory practices, but also from our central business office, central scheduling department, and central referrals department. No one knows end user workflows like the super users who work with them day in and day out. We have detailed test scripts for our internal testing, but we need real-world expertise to tease out the smallest bugs. Like any organization, our users have some creative workflows that we don’t train, and if we don’t have their participation, we won’t find those issues until go-live.

We’ve been using the same upgrade methodology for half a decade, which is usually goes off without a hitch. It’s a belt-and-suspenders approach, with some duct tape and baling wire thrown in for good measure. We do a dry-run upgrade just prior to the super user testing so that we can get our timing down pat for the main event. The upgrade weekend playbook has some elements timed to the minute and there is a single upgrade commander responsible for ensuring every step is completed and communicated.

Because of the need to involve a couple of third-party vendors to handle some data migrations that we wanted to perform while we had the system down, timing for this one was even more critical. There were numerous handoffs among DBAs, access management, application analysts, build analysts, internal testers, and end-user smoke testers in addition to the third parties. Although we don’t make everyone sit on a bridge line and talk through their work and the hand-offs, we do require people to notify the team when they complete a step or if they’re running behind so that we can adjust if necessary.

The lead analyst that usually quarterbacks our upgrades had an unexpected medical issue a handful of hours before we were due to take the system down, so I ended up co-managing it with one of our analysts. This meant being on call overnight for issues, which doesn’t bother me. Once you’ve been on trauma call or managed an ICU full of patients overnight, being on upgrade call doesn’t seem very scary. Still, you never want to hear that phone ring in the middle of the night. Shortly after midnight, I decided to grab some sleep since we weren’t expecting a handoff until early morning.

When the phone rang at 3 a.m., my heart was pounding. The tone in the tech’s voice wasn’t reassuring as she apologized for calling. Apparently the upgrade was running nearly three hours ahead and she wasn’t sure if she should wake someone up to tell them or not. I have to say, seeing an upgrade run ahead, especially by that much, isn’t something you see every day. I shuffled out of bed and we walked through the checklists to make sure nothing had been missed. I cruised the error logs as well. Nothing was amiss, so we had to chalk it up to the production server being faster than our test platform.

We must have our share of either insomniacs or nervous Nellies on our team because a couple of people were showing available on our instant messenger service. They were happy to launch the next few steps early. Despite the call being a non-issue, once your adrenaline is flowing, it’s hard to get back to sleep. I curled up on the sofa with some journal articles, which thankfully did the job. By our 8 a.m. status call, I was rested up and eager for the build and testing teams to get to work.

Even though everyone has remote capabilities, we require the regression testers and analysts to be on site. We’ve learned the hard way that people are sometimes less attentive when working remote on the weekends. Sometimes it’s just better to have two sets of eyes looking at the same screen together (without a WebEx lag or dogs barking in the background) for troubleshooting. It’s a sacrifice for the team to come in, but we try to make it as fun as possible. The kind of team-building you get from an event like this is often priceless. It’s also important for the end user and analyst teams to work closely together and build mutual respect.

In response to the questions about why we spend so many hours preparing and delivering an upgrade, I’m going back through the last couple of months and highlighting some key milestones that may have been riskier with a leaner team. We have multiple people trained to do each task, which was clearly helpful when our quarterback unexpectedly sat out the game. I’m also working to quantify the intangible benefits of having disparate teams work together.

We ended up being able to re-launch the system two and a half hours early, which meant less downtime procedural re-work for the patient care sites that are open on weekends. Due to the diligent prep, we also had fewer phone calls Monday morning than we’ve ever had. That’s got to be worth something as well. The question is whether the Administralians will agree with our analysis. If they don’t, maybe we can let them run the next one and see what happens. We’ve already documented our lessons learned and updated the project plan, so it’s ready to ride.

Ever jumped in when someone said “Cowboy up?” Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 9/15/14

I was having a pretty pleasant week until one of my group’s more challenging physicians walked into my office with a copy (printed, of course) of an article entitled, “Physicians report losing 48 minutes a day to EHR processing.” Once again, Medical Economics uses an eye-catching headline to remind us why EHRs are evil.

When looking at patient care, my colleagues will sit in Journal Club and rip scholarly articles to shreds, dissecting them and discussing why they do or do not apply to our patient population and care paradigm. They’ll argue about the composition of the study population as well as the methodology. Only when they’re fully convinced as to the integrity of the data and the statistical analyses performed will they agree to add the paper’s recommendations to their clinical protocols.

When there’s disparagement of EHRs to be had, however, they take the article as gospel without a single moment of review and pass it all around the physician lounge. This is the same physician who barged into a meeting last year with a survey of EHR satisfaction, demanding we replace our system. He didn’t both to notice that fewer than 20 respondents use the same EHR as us and are likely not in the same situation.

He took the same approach with this article and wouldn’t listen to anything I had to say, ultimately storming out when I wouldn’t feed into his negative energy. For anyone who does want to listen, however, here is my critical review of the article.

First, the article cites a survey by the American College of Physicians as the source of the data. Key points cited in the Medical Economics article included:

• 89.9 percent reported at least one data management function was slower with EHR
• 63.9 percent reported that note writing took longer
• 33.9 percent said data review took longer
• 32.2 percent said it took longer to read electronic notes

In digging deeper, the survey results were published in a letter in the Journal of the American Medical Association’s Internal Medicine. They weren’t published as part of a peer-reviewed study, which is an important distinction.

In looking at the letter itself, I’m not following the math. They said they sent the survey to 900 ACP members and 102 non-members. That’s 1,002 people by my math. In the next paragraph, they talk about “845 invitees.” Since 485 opened the email, that gives them a contact rate of 62.5 percent. But if you divide by the original 1,002 people to whom the survey was sent, I get 48 percent. Either way, only 411 of the responses were valid.

The survey also found differences in the time “lost” by residents vs. attending physicians differed – 48 minutes vs. 18 minutes, respectively. They suggest “better computing skills and shorter (half-day) clinic assignments” as possible contributing factors. I found the last sentence of the results section particularly interesting: “For the 59.4 percent of all respondents who did lose time, the mean loss was 78 minutes per clinic day.” Pulling out my handy math skills again, that would seem to indicate that 40 percent of respondents did not lose time.

The fact that this data was self-reported makes it less reliable than observer data. Their methodology relies on physicians remembering what their days were like a year ago (or two, or three, depending on when they went live on EHR) and comparing it to the present. I don’t know about you, but my clinical time is significantly harder for a lot of other reasons other than the fact that I’m on an EHR.

I’ve used EHRs for more than a decade and have to say that the Meaningful Use program (with its many required data elements) alone increased the time I spend charting. It wasn’t due to the EHR per se, but due to the required data. It’s kind of like when E&M coding was introduced – notes took longer because the volume of required data increased.

They authors seem to acknowledge this with their statement: “The loss of free time that our respondents reported was large and pervasive and could decrease access or increase costs of care. Policy makers should consider these costs in future EMR mandates.”

I also find it interesting that they didn’t mention results of any questions asking about how many data functions were faster with EHR. From my own experiences (across eight or nine different platforms) there are always areas that work faster and better in EHR and others that were faster on paper. But faster doesn’t equal safer, more reportable, or higher quality – it simply means faster. You can’t look at speed alone as a marker of EHR value, but I’ll take my EHR’s telephone message system over chart pulls and little pink pieces of paper any day.

When our medical group initially went live on ambulatory EHR, we actually did the time and motion studies pre-EHR and at multiple points post-EHR. We had data that showed that the EHR was neutral for time as well as for revenue. It didn’t matter that we had good data, however, because physicians naturally assumed that we “cooked the books” on it to show the EHR in a favorable light. That kind of bias is hard to overcome.

Looking at some of the raw data from our observations, we found the presence of a computer during documentation to be a confounder. Physicians were more likely to access other resources, such as UpToDate,  formulary information, or our system’s clinical repository, while reviewing data and documenting. Those resources were simply not available to them in the paper world. It’s hard to separate that kind of computer use from the actual use of the EHR product when you’re considering how long it takes to complete your notes.

I would much rather take a little longer because I spent a few minutes validating something in UpToDate than to simply finish faster. I also spend time in the EHR making sure patients get appropriate personalized education handouts, which I couldn’t do in the paper world. A survey cannot control for these other types of computer usage within the context of the EHR. Because of single sign-on and CCOW, half of my physicians would be unable to tell you where the EHR proper ends and the rest of our data universe begins.

What’s the bottom line? Although this survey has scholarly trappings, if other research was conducted this way, it would have holes like a block of Lorraine Swiss. The fact that review and documentation takes longer may not necessarily be a bad thing.

I’m interested to see what readers thing about the publication of this letter. Have thoughts about it? Or a favorite Swiss of your own? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 9/8/14

Our EHR implementation team is in full swing again, thanks to a mad rush of acquisitions. Like many health systems, we’ve been frantically snapping up practices as we try to tighten our grip on market share.

Although it makes sense that we’d want to build the membership in our accountable care organization, it doesn’t mesh with the quality of some physicians we’ve decided to employ. At this stage in the game, if you’re not employed, you generally fall into a handful of groups: successful independent practice; member of an IPA or other group bargaining arrangement; renegade individualists (such as direct primary care providers); or disasters.

Although we’ve purchased a couple of the former, we’ve apparently acquired some of the latter. It’s easy to see why these disasters would want to be employed in the current economy. The medical group takes over credentialing, HR functions, operational management, billing, marketing, managed care negotiations, and the all-important provision of medical liability insurance. In return, the medical group stamps out competition and gets a captive patient population to add to its ancillary services pipeline.

Usually when practices are acquired, it’s a race to get the physicians migrated to employed status as well as to bring them up on our EHR. For the more savvy practices that have already been on an EHR, we’ve gotten pretty good at conversions. As long as there is data integrity in the source system, we’re able to do a fairly seamless transition. In this round of acquisitions, though, we’ve had a disproportionate share of practices coming off of paper or transcription.

As we race to get them started in our system, there is often little involvement by the operational teams to really look at the practice’s workflow and habits. The EHR implementation team is often sent in as the shock troops with the assumption that they’ll get the practice in line. I’ve fought for years to try to get operational management to understand that you can’t use the EHR as a weapon to beat physicians into submission. If there are serious issues with their office processes or habits, those need to be addressed first. At the current breakneck, pace those concerns are consistently being cast aside.

What do you do, then, when an EHR implementation uncovers serious problems in a practice? I joked to my CEO that if I could file as a Medicare whistleblower, I could retire on my share of the recovery for what I’ve seen this year. Although some of them are “typical,” such as phone messages on sticky notes and passwords taped to the monitor, others are much more serious:

• A provider with over 1,000 un-dictated visit notes over a 90-day period (all of which were billed out already).
• Lab tests and medication refills being ordered by unlicensed phone receptionists and front desk personnel without standing orders or a verbal order (otherwise known in many states as “practicing medicine without a license”).
• Paper controlled substance prescriptions being signed by staff (otherwise known as forgery).
• Loose pills in a desk drawer (gross as well as inappropriate).
• Inappropriate web surfing (and it wasn’t online shopping).
• Inappropriate office relationships (leading to one of my trainers, for the first time ever, abandoning a training session due to the behavior taking place).

I continue to be amazed that district practice managers and other leaders expect us to not only look the other way when we find these issues, but also to figure out how to successfully implement a practice where these happenings are commonplace and accepted.

Just dealing with the first example of un-dictated charts – if the provider was 1,000 charts behind using dictation, there is no way he is going to be able to document visits in the EHR in a timely fashion. I know if I don’t finish my charts as I go, I can barely remember some visits by the end of the shift. There would be no way I could try to dictate a day or two later, let alone three months down the road.

I am also amazed (although I guess I shouldn’t be) that our hospital organization is willing to stoop this low, acquiring practices that are known to have issues just because they want the market share. It’s not like these offices are hiding these behaviors. Even a casual observer could have uncovered them. I can’t imagine someone doing due diligence before purchasing a practice would have missed them.

We’ve also had to work recently in a practice that has what I would consider basic hygiene issues – trash not being emptied regularly in patient care rooms, exam tables not being sanitized, filthy physician white coats, food in the lab, things like that. If a practice is that cavalier about the basics of patient care, it would be difficult to assume that they’re going to be star performers when we start applying standardized workflows and patient care algorithms through the EHR.

I met with our senior leadership to discuss strategy for these situations. Although everyone was wringing their hands and making the right statements, no one agreed to take action. Essentially, the EHR team was told to figure out how to deal with it and to get them live and ready to attest prior to October 1.

In the past, we’d have jettisoned these practices after a year or so, but now that they’re part of our MU payment base, I wonder how it will play out. I can’t imagine them being successful attesters on such a short timeline, so maybe their lack of performance will help them out the door.

It’s no secret at my organization that I’m job hunting. It’s challenging enough to be a CMIO, living in the middle ground between the CIO, CMO, and CEO, all of whom have opinions about how you do your job. It’s another thing entirely to be asked to overlook (if not enable) fraud, illegal activities, and poor patient care.

I know from chatting with colleagues that I’m not the only one seeing these issues, although I may be in the minority in that my organization refuses to take a stand.

Are you a CMIO on the brink? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 8/25/14

I usually start my day with a bagel and the local news, courtesy of a newspaper website. Once I catch up on homefront happenings (the comments are usually more entertaining than the articles they accompany) I hit a couple of national websites.

In the course of my usual surfing, I came across a link to “The End of Absence: Reclaiming What We’ve Lost in a World of Constant Connection.” I was able to find a couple of reviews and it looks like it will probably be one of my next reads.

Author Michael Harris looks at people born before 1985, namely because they “know what life is like both with the Internet and without.” For non-IT professionals and the general consumer base, I’d broaden that to include those that experienced life BC and AC: before computers and after.

I enjoy history, but never thought of myself as having lived through a major transformation. Don’t get me wrong — there have been many sociopolitical changes in the last few decades, but I missed out on the moon landing and other key “tech” touchstones.

I remember thinking some years ago about my great grandfather (who was born in the late 1800s and died in his 90s) and all he had seen in his life: from the Wright Brothers to the Concorde, and from Sputnik to space stations. He also saw the progression from the crank-powered phone to the cell phone and many other advances. At the time I thought of how cool that would be – to see that kind of change – and I also remember thinking that technology had come so far that I couldn’t fathom something that revolutionary.

Back then, broadband Internet was available, but it wasn’t a fixture in peoples’ daily lives like it is now. There was no Facebook, no Twitter, no cell phones in every person’s pocket. The iPod had barely been invented and it was for music only. We didn’t know we were on the cusp of an information revolution.

I was talking about this idea with a friend of mine over lunch yesterday. She has kids in middle and high school and was joking about the classic “back in my day, we rode dinosaurs to school uphill both ways” sayings she finds herself throwing at them. We talked about when we were exposed to our first computers (Commodore 64, anyone? TI-99? Apple II?) and what kids of today would think if they saw them in action compared to the smartphone firepower in everyone’s pockets. It used to be a major undertaking to put a computer lab in a school and now it’s expected.

Still, there are completely different sets of issues that today’s kids are dealing with involving technology and its appropriate use or lack thereof. At my friend’s local school, some teachers demand that students use technology in the classrooms and others ban it. I can only assume that the pre/post Internet generation gap might have something to do with it.

In thinking about my physicians who complain about the EHR, I don’t see a clear line age-wise. At least in our group, some of the older physicians tend to be more forgiving of the software’s shortcomings, perhaps because they expect less than the more tech-savvy physicians who tend to be younger. It would be interesting to do some actual research on their attitudes and opinions regarding technology in general as well as the EHR, but I’m not likely to find the time (or funding) to do something like that anytime soon.

One of the other concepts the book addresses is how people now use technology to quantify their self worth. I know the HIStalk team enjoys seeing how many Facebook friends, LinkedIn connections, and Twitter followers we have, but we don’t let it drive who we are.

I’ve seen multiple discussions on physician forums looking at teenagers who have significant psychological issues that stem from interactions with social media. One might infer that those of us in the “before” column had established our own sense of self independently of that kind of input, where those in the “after” column “lose the ability to decide for ourselves what we think about who we are,” according to the review’s interview with Harris.

I mentioned my own run-in with the “quantified self” after my running GPS was waterlogged. Being able to translate subjective experiences such as daily activities into actionable numbers is a powerful thing. It’s made a tremendous difference in my health and well-being, but I can see how data points might be overwhelming or discouraging to some. I can’t run a half marathon as fast as I could three years ago, but I can chalk that up to a bad knee and an uncooperative training schedule rather than letting it get me down.

Harris ends up taking a month off from the Internet while writing the book. Most of us could never do that for occupational reasons, but I like the idea of the challenge. As a physician, I frequently ask patients to limit “screen time” for their children. For many adults, it might be time to do the same. A quick search of ICD-10 codes fails to reveal much Internet-specific pathology, but we’ll have to see what ICD-11 brings.

Who’s with me for some time off the ‘net? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 8/18/14

Thanks to Bianca Biller, who shared information about the new Practice Management System Accreditation Program (PMSAP).  The accreditation was developed through a partnership between EHNAC and WEDI. Three vendors (GE Healthcare, Medinformatix, and NextGen Healthcare) will be participating in a pilot program.

The program’s web page says the program “reviews the key functions of portability, interoperability, clinical integration, compliance monitoring, billing, reporting, and industry certification/accreditation” and that it will serve “as a baseline standard for providers in the process of PMS vendor selection and KLAS reviews.”

Although I like the idea of a program to ensure practice management systems meet the baseline needs of practices, I worry about yet another certification program whose hoops vendors will have to jump through. They can barely keep up with Meaningful Use, ICD-10, and CMS rules. Now we’re going to throw another set of requirements at them.

I also wonder whether practices will really find the separate certification of practice management systems to be meaningful. Many sites use systems that have combined practice management and EHR features. I doubt the lure of PM certification would be enough to convince physicians to consider changing systems when they are still struggling to attest for Meaningful Use. For those who may use separate EHR and PM systems, interfacing is a challenge that most wouldn’t want to repeat with a new vendor.

There are also the vendors that don’t allow interfacing with other systems. Others require you to purchase their PM system with the EHR and most physicians don’t have enough spare cash lying around to purchase a separate PM and interface it. On the other hand, if there is anyone who wants to make a change in their systems, transitioning from one PM system to another is often easier than trying to do an EHR conversion.

I downloaded the criteria document. Some of its elements include:

• A diagram of “all sites that create, receive, maintain, or transmit PHI for the delivery of the services provided, whether company sites or outsourced organizations.”
• Determination of the candidate’s status as a Covered Entity, Business Associate, etc. under HIPAA.
• PHI disclosure and protection policies.
• Controls against malware.
• Documented customer service and escalation policies.
• Minimum availability and redundancy to assure 98 percent system access.
• Capacity monitoring and plans for handling peak load.
• Compliance with applicable federal and state requirements and regulations.
• Offsite six-month backup archive, storage, and retrieval capacity for all batch transactions with progress toward a seven-year back-up archive.
• Ability to regenerate transactions going back 90 days within two business days.
• Intrusion/attack monitoring capabilities.

One of my favorites is the requirement that “candidate must have sufficient qualified personnel to perform all tasks associated with accomplishment of the stated mission.” In speaking with most of my ambulatory-based colleagues, many feel their vendors are understaffed and overwhelmed most of the time. It’s a good thing that particular element isn’t mandatory for certification.

I find it interesting that the certification program only targets practice management systems. In my experience (both clinical and administrative), the inpatient financial systems are much more in need of supervision than their outpatient counterparts.

What do you think about the new PMSAP certification program? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 8/11/14

Several readers were in contact this week to share their stories of what is going right in healthcare IT as well as to sympathize with my experiences in the trenches. Others tried to guess the location of the lighthouse – no one has nailed it yet and I’m reluctant to give up my favorite beach just yet.

From Northern Lights: “I wanted to share what we are doing based on big data. Evidence has shown the outcomes are better if the mother carries the baby for at least 39 weeks. We’re working to reduce the number of elective births before 39 weeks to zero statewide! My little ‘ole community hospital captures the expected due date from the mother at the first maternity encounter. Then we programmed the scheduling system to not allow scheduling of elective inductions or C-sections before the 39-week threshold. Rocket science, I know, but our hospital hasn’t had elective early deliveries in over a year.” She went on to say that a couple of the providers were afraid this would cause problems with vacation schedules, but accepted it once they saw the evidence. These are the kinds of interventions we should be doing with big data. I appreciate your sharing it with me.

From The Other Jane: “I saw Mr. H’s post about OBs having to take down the photos of the babies they’ve delivered, even when the photos in questions have been provided by the babies’ mothers. It’s sad that HIPAA is so restrictive.” I agree – I hadn’t seen that article before I read the Monday Morning Update. Most of our OB offices still have a baby board, so I forwarded the article to a couple of my colleagues. I thought our compliance offers were uber-conservative, but they haven’t caught onto this one yet. I doubt they read HIStalk and I’m going to pretend that I didn’t see the article.

I forwarded it to a couple of friends out of state as well. One sent back a copy of the consent form they keep on the checkout desk for parents who want to drop off a picture. Another said they’re skirting under the premise of implied consent and the parents have to physically place the picture on the bulletin board. The article mentioned fertility clinics not wanting to “out” parents who used an egg donor. I’m guessing that parents in that situation might not be so apt to give their infertility specialist a picture to post in the first place if they have that concern.

As a family doc who had a solo practice in a small town, I had to get used to patients who didn’t care about showing off their problems in the supermarket checkout lane. Patient privacy took a back seat to impromptu consultations or the chance to avoid a co-payment.

My favorite privacy violation took place one year during the Founders’ Day parade, when I was riding on the hospital’s float. A patient’s wife called over the crowd to tell me how much better her husband’s hemorrhoids were doing. No one batted an eye or looked shocked, which tells you a little about life in a small town.

Over on HIStalk Connect, Dr. Travis has written a fair amount about mobile fitness trackers and applications to promote health and wellness. I have used Garmin devices to track my runs for nearly five years. Unfortunately, my current one’s specifications for being waterproof didn’t stand up to my recent beach activities. I tried to resuscitate the patient using a Tupperware container full of rice, a Ziplock bag with silica gel, and even prayer, but it could not be saved.

I only use a fraction of its capabilities and use the same routes all the time, so I thought I’d test drive using a regular sports watch and manually logging my activities on the GarminConnect website. Even though I had the same data points, there was something less satisfying than having all the details for each unique run. I hadn’t realized how much I had subconsciously bought into the concept of the quantified self until I could no longer track my activities.

I could have done an out-of-warranty replacement for my GPS, but I decided to instead go for something newer and smaller. The process of trying to find the “right” device was daunting to say the least. One of my vendor friends turned me on to the DC Rainmaker blog, which had some great device comparisons that ultimately helped me make up my mind. I’ve never used a Fitbit or any of the other activity trackers, but ended up selecting a running watch that also has those capabilities. It was actually the battery life that made me choose that device over a similar one, but I thought I might have fun with some of the other features.

I braved the back-to-school tax-free shopping madness and it’s on the charger for tomorrow morning. I can’t wait to wear it to work. The inactivity indicator tells you to MOVE when you’ve been sitting more than an hour. I think that feature might become an integral feature for Meeting Monday.

What do you use to track your activities or quantify yourself? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 8/4/14

I took some much-needed time off this week to try to gain perspective on where my career is going. What was once a pretty fun job has become a bit of a grind.

Ten years ago, we felt like we were doing cutting-edge work to transform patient care and help physicians deliver better outcomes. We were in the EHR business for the all the right reasons and were able to implement systems and functionality we needed when we needed them.

A good chunk of my responsibilities have been taken over by Meaningful Use. In our world, this has caused us to take workflows that were already improving patient care and then micromanage them to death. Maybe it’s the actual Meaningful Use certification requirements or maybe it’s the way our vendor has implemented them, but we may never know which is to blame. It’s probably a combination of both.

Either way, physicians and end users are unhappy with the volume of documentation they now have to do. They complain that it’s not really helping them in daily patient care.

As the CMIO, I take those concerns seriously and often personally. Although I have workflow experts and an advisory board backing me up, I’m the one who ultimately approves all clinical workflows before they’re implemented and all clinical system changes before they’re coded. If our vendor’s workflow is clunky and we don’t identify the potential problem before it goes out the door, that’s on me.

Our administration understands that sometimes we’re going to miss problematic content. They also understand that some of the MU requirements are so specific there’s just not a way to make them less annoying.

Our physicians are less understanding, however. I’m the one who has to deal with their concerns, complaints, and threats to quit. That’s not something they really train us to deal with anywhere along the CMIO training path, assuming we’ve actually been trained other than in on-the-job fashion.

I’m still relatively early in my career, but I’m wondering if I can take another 10 or 15 years of this. Considering my particular hospital situation, the bloom is definitely off the rose. I’m thinking about throwing my hat into the ring at another health system. The thing that makes me somewhat hesitant, though, is the thought that it could be just the same, if not worse, anywhere else.

How do you truly screen a potential employer or supervisor to know if they’re really visionary or just saying what they need to in order to get a position filled? I’ve had a couple of bosses that I would walk through fire for. It’s difficult to top that. At this point, however, I’d settle for someone who knew what he was doing and had the conviction to do the right thing rather than the easy thing or the politically expedient thing.

We’re in the middle of evaluating vendors for a massive system overhaul. I’m not sure our current leaders will survive, depending on which vendor is selected. That could be an opportunity for me to help move the remaining players around in a way that will rejuvenate some of our key players. Or it could be a reason for team members to jump for fear that they won’t make the cut. I’ll know more about what this is going to look like in six or eight months. Right now, we’re in a special kind of limbo.

It was good to get away, but increasingly difficult to completely unplug. There’s so much going on that it’s tempting to just peek at email, but I know better. One minute will quickly become one hour if you let yourself look.

When I got back in town last night, I had multiple voice mails from one ambulatory director with increasing anxiety in her voice because I wasn’t calling her back or returning her emails. Apparently she didn’t listen to my outbound message or pay attention to my out-of-office message that I wasn’t going to be on the grid.

I picked out two books before I left and they were an interesting contrast. I like southern fiction and the first one, The Hurricane Sisters, was available from my library’s e-book site. I checked it out for my iPad. It started with a lot of key southern elements, but I was shocked when I reached the point where Google Glass played a role as a significant plot device. Times are certainly a-changing! It was a quick read, not the best book ever, but good in the moment. I was pleased with my choice and it took my mind off things as I headed out of town.

The second one, On Call in Hell: A Doctor’s Iraq War Story was not exactly your typical beach read. It’s pretty graphic as only a book about Marines in combat can be, but I was amazed at the ability of the author and his colleagues to maintain their humanity and occasionally a sense of humor in the ultimate adverse conditions. Regardless of your feelings about war in general, reading about the experience puts everything in a different perspective.

One of the ideas that author Richard Jadick emphasizes is to be constantly improving one’s situation, whether it’s basic survival (sandbagging the forward aid station so you don’t get shot while caring for casualties) or figuring out better techniques to treat the wounded. It’s a powerful concept. It’s not about finding solutions to the chaos all around, but about figuring out your own sphere of influence and improving what you can within that space.

I’m taking that thought back to the office with me this week to see what I can do with it. I’ve already got a list in my head of what’s in my sphere of influence and what’s not, and some ideas on what we might be able to change for the better. I’m feeling pretty rejuvenated, but all that will change Monday morning when I finish tackling my inbox.

Have a transformative vacation story? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 7/28/14

I had a chance to catch up with an old friend this weekend. He’s an OB/GYN, and as an employed physician, he’s had EHR in both the hospital and ambulatory settings for years.

Their efforts have resulted in massive amounts of data that can be mined to improve patient care. Surgeons can easily access their own outcomes data and compare morbidity and mortality data when incorporating new techniques (such as robotic surgery) into their practices.

There’s a dark side to that big data, however, and it’s starting to rear its head.

Although most laypeople are aware that babies are going to arrive when they’re going to arrive, administrators at his hospital may have missed that part of health class. They’re creating reports looking at delivery times and labor lengths under the guise of optimizing patient care. The seedy undercurrent of their research, however, is a desire to reduce staffing costs. Although they haven’t overtly said it, he suspects they’re on the verge of asking physicians to start acting in the hospital’s best interest rather than the patient’s.

I delivered babies at the beginning of my career. When you’re caring for a mother in labor, it can be hours of waiting punctuated by moments of terror. Although delivering a child is a natural human process, in the US, we’ve medicalized it for a variety of reasons. As a result, over the past quarter century, we’ve seen an increase in the percentage of babies delivered surgically (it sounds a little scarier when you say it that way, rather than “by C-section”) and there have been concerted efforts to try to reduce this trend.

It’s not just a problem in the United States. The World Health Organization has set a goal of 15 percent C-sections as realistic number for the procedure. In the US, it’s at about 28 percent, in Britain it’s 25 percent, and in Brazil, nearly 80 percent of women delivering in private hospitals have C-sections. Some blame cultural factors for the rise in the procedure. The ability to deliver “on schedule” is certainly a plus for some women as well as for their physicians. Others blame our medical payment system, because reimbursement is higher for a surgical delivery.

It’s not just C-sections, though. We’ve seen a rise in labor inductions, where drugs are used to start labor, often before the due date. Although there are definitely medical reasons when this might be indicated, it had become so prevalent (one in every five women) that ACOG, the OB/GYN professional organization, issued revised guidelines to try to ensure appropriate use of medical interventions.

Why would someone want to electively deliver a baby (through induction or C-section) anyway? Some blame the risk of litigation in the case of a poor outcome. Others blame physicians who want to deliver babies at their convenience. In my practice, I had a fair number of women request induction because they live far from their families and wanted to schedule the delivery to ensure relatives could travel to assist with the baby or help with young children at home.

In countries that spend a lot of money on post-partum home visits or in-home assistants, this may be less of an issue, because women may feel more supported at home after a delivery. Data is shared between community-based caregivers and coordinating physicians so that care can be delivered outside of the hospital. That kind of care has a cost, though, and isn’t an option for many US women, hence the request for inductions.

When thinking about cost controls, however, the idea of asking physicians to intervene in the labor and delivery process to try to better match facility staffing capacity is just too much to accept. Using data in this way sets us on a very slippery slope. What’s a little extra Pitocin? We can convince ourselves that it would be better for the baby to be delivered sooner than later, and if it happens so we can deliver before shift change, so much the better. Looks like the extra drugs may be creating some fetal distress, better prep the OR.

I haven’t delivered a baby in years, but I can’t imagine the stress of having my labor and delivery management decisions questioned by someone who has motives other than reducing maternal and neonatal morbidity and mortality.

Pregnant women are some of the most empowered patients I see in practice. They have more time to research various options and choose the best for themselves and their families, unlike patients facing cancer, injuries, and other unexpected issues. They share the knowledge of how to fight back against the medical establishment (as proven by anyone who has had a patient arrive with a 20-page Birth Plan) and are increasingly demanding of alternatives to the hospital birth experience. Many women in my area are using Doulas and Labor Coaches to have a dedicated patient advocate with them if they do deliver in hospitals. Some can cite the labor and delivery data and the risks of interventions better than a med student prepping for boards.

If the hospital is serious about this, I hope the physicians and nursing staff stand their ground. Better yet, I hope the patient community gets wind of it and reacts strongly.

As for my friend, he’s trying to work from the inside to convince hospital leaders that this is the wrong way to use big data. I hope he’s successful, but I also know he’s fearful for his job as an employed physician.

Have any other examples of misuse of Big Data? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 7/21/14

A lot of people are talking about the recent JAMIA article that looked at whether Stage 2 Certified EHRs are ready for prime-time interoperability. It concluded that four key areas need to be addressed to improve CCDA quality. One area is “terminology vetting” for the multiple vocabularies used including SNOMED, LOINC, and RxNorm. Another area is reducing the amount of data that can be “optional” with a product still receiving certification.

I agree with both of those, as well as the paper’s assertion that document quality needs to be assessed in “real-world clinical environments.” However, it’s highly focused on the technical aspects of document exchange rather than the actual intellectual quality of the document being exchanged. I wrote about the quality (or lack thereof) of some physician notes a couple of weeks ago. Unfortunately, there are more elements besides the provider’s narrative and abbreviations that are problematic.

My health system is the ultimate best-of-breed nightmare, so I can attest to the fact that some vendors’ incorporation of the clinical problem list into the CCDA reads like one of those “choose your own adventure” novels. Is it an active problem, chronic problem, recurrent problem, or something that just happened once in the past? With some of our documents, I just cannot tell what it is trying to depict. I often feel like I have chosen a path to nowhere, just like the books.

There are fundamental differences between how physicians and other clinicians are trained to sort information. When I trained at a fairly “classical” medical school, we were taught that all of the patient’s problems were part of the Past Medical History, even those that were not truly past such as chronic hypertension, diabetes, obesity, etc. When I helped bring our organization into the EHR universe more than a decade ago, it took while for providers to get used to the idea of a chronic problem list being different from the PMH because many providers still wanted to include everything in the PMH.

Now we’re at the point where we have to educate them on the SNOMED-codified Problem List and how it differs from the ICD-10 Assessment List, even though there may be two codes that represent a single disease. I have finally gotten over it, but many of our physicians are still struggling with the concept despite having been trained two or three times.

Some of the CCDAs seem to comingle the two. It’s maddening. I’m tired of opening vendor support tickets to try to figure out if they’re functioning as designed or just messy. They must meet the letter of the law to receive certification, but that doesn’t necessarily mean they’re good for patient care or educating the patient on the conditions noted in his or her record.

Whether or not Eligible Providers are meeting the letter of the law or the spirit of the law with Meaningful Use is another hot topic. Lately, my running habit has been taking a toll on my feet, which prompted a trip to my favorite foot specialist. He’s a good friend of mine and part of a husband and wife team practice. They’re fiercely independent and have successfully deployed a Certified EHR over the past couple of years. We always chat about EHRs and where they stand.

I knew they were getting ready for attestation when the rooming technician came in with a wrist blood pressure cuff. In practice, I’ve found those kinds of cuffs to be notoriously unreliable, so I asked him if he wanted me to just self-report some numbers that would be accurate. He declined my offer and proceeded to document the 141/87 that the cuff read out. My blood pressure hasn’t ever been that high, but now it’s in my chart. When my colleague came in, I asked him what he thought about it. He wasn’t thrilled and said it sounded like some coaching was in order.

We talked a little bit about integrated vital signs monitors that would make things easier. He then he admitted that they’re thinking about throwing in the towel on MU. Their vendor has been doing a good job helping them dot the Is and cross the Ts, but the thought of an audit scares them. With all the points that must be perfect for an honest attestation, they are wondering if it’s worth the risk. Right now their patients are happy, their staff is happy, and their practice is running well enough from a business standpoint, so why upset the apple cart?

I don’t disagree with them. At times it doesn’t seem like it’s worth it. A lot of practices are just operating out of fear of future penalties or fear that commercial payers will adopt the CMS standards. Fear isn’t really a healthy way to run a business, however.

Since we’ve been friends for a long time, I offered to do a peer audit for them using my knowledge of MU to see how close to compliance they are. There are plenty of professional consulting firms that will do practice audits and they may want to ultimately do that, but are interested in seeing where they sit from a friendly point of view.

In the olden days (or in a truly free market economy) we could have traded some consulting for a free cortisone shot or something like that, but the insurers would take a dim view of that, I’m sure. Given my CMIO role, I also have to be careful about doing anything that could be interpreted as a donation from the health system so I don’t run afoul of any anti-kickback rules. When all is said and done, it will be interesting to see how many providers end up opting out of MU and what percentage of them are independent physicians.

Are any of your providers opting out of MU? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 7/14/14

I wrote a few weeks ago about my adventures with the CMS physician portal. Since the reporting of payments and gifts from drug and device manufacturers to physicians is now mandatory, physicians are wise to make sure the information is accurate because it is going to be released to the public.

I had gone on the site and registered for basic portal access in June, but had read that I would have to return in July to register specifically for access to the Open Payments data. Once I went to the Open Payments link (thank goodness the website at least has a decent breadcrumb trail at the top), it asked me to create my profile. It also allows physicians to nominate “authorized representatives” to handle physician information.

It also requires entirely too much other information that CMS should already know about us from our NPI, Medicare, and other applications: NPI, license number, practice type, specialty code, DEA number, etc. The first words that popped into my head (of course in a snarky voice) were “administrative simplification.”

Rather than have the specialty codes on a pick list, I had to launch a 359-page PDF to figure it out. Finally, Page 212 had a link to Appendix C, where the answer was still nowhere to be found; the appendix had a link to the CMS taxonomy crosswalk. I’m not sure why they couldn’t have hooked up the link on the actual application to the crosswalk in the first place.

Even though the crosswalk lists my specialty code as “08” in the column that says “Medicare Specialty Code,” what they actually wanted was the code in the “Provider Taxonomy Code” column. Don’t bother trying to cut and past the 10-digit code into the form because it won’t work right. I was able to finally get through all the steps, only to learn that I won’t be able to do anything else until my profile is “registered” after my identity as a physician is confirmed. I’m surprised they didn’t ask for my blood type.

When I write about my initial experience, I also asked for a good martini recipe to help me get through it. Weird News Andy was happy to oblige with one that plays to my literary passions:

Charles Dickens Martini

1) Make a martini as you see fit

2) Add an olive or twist

I’m still laughing. There are so many Dickens titles that seem appropriate for healthcare IT: Great Expectations, Hard Times, and Bleak House, to name a few. It looks like my attempts to see my Open Payments data are turning into either a serial or a novel.

Have a literary suggestion that meshes with our lives in the IT trenches? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 7/7/14

I enjoyed some R&R over the holiday weekend. It was good to have a break from the normal routine. As an added bonus, most of our IT staff disappeared the day before the holiday, whether sanctioned or not. I had a grand total of one email after noon on Thursday and it had to do with something administrative.

I know this reprieve will be short-lived since we start implementing practices again tomorrow. At least we’ll be heading into the fray well rested.

Quite a few readers chimed in on last week’s Curbside Consult discussion of poor-quality EHR documentation. Several readers mentioned the purpose of the note as a key concept. While visit notes were traditionally for the benefit of the provider in documenting the patient’s condition, exam, and what was done, they have been co-opted by payers and regulators who equate documentation volume with value.

Notes are increasingly the purview of patients. Our health system does release visit notes directly to the patient through our patient portal. Most of our primary care physicians do a great job with patient documentation because they know the patients might actually be reading it. Our subspecialists who have been on EHR a long time also do fairly well.

The new practices are struggling more than those groups. It’s hard to tell how much they’re struggling with the actual documentation process vs. the concept of being part of an employed medical group and being told what to do.

As to who has the authority to take corrective action against “bad actors,” in our organization, it isn’t the CMIO, but rather the CMO and the president of the physician group. Both of them received formal notification of the specific concerns I found during the special project. I also included a request to authorize a more thorough and comprehensive audit by our internal Compliance department. If some of the documentation is as bad (and potentially fraudulent) as it seems, we’re going to need a better sample size and multiple independent auditors to prepare the documentation ahead of disciplinary maneuvers.

When I created my CMIO role here, I intentionally excluded physician discipline from my purview. To be successful within our culture, I needed to be seen as an advocate rather than someone who could get them in trouble. Additionally, I felt that in the case of EHR misuse, I would be seen as inherently biased towards defending the EHR and the IT group whether or not it was true.

Our leadership agreed. So far, the splitting of authority has worked. I think it will work well in this case also once we have evidence of documentation patterns across the group.

I laughed at SpoonEHR’s suggestion to create a macro “Signed but not read.” It’s unfortunately all too true. Back in the days of in-house transcription, I quit using a consultant whose letters came back “Dictated but not read, signed by transcriptionist to expedite” or some similar nonsense. If I can’t trust someone to read, edit, and sign their notes, I certainly don’t trust them to care for patients.

Reader Zafirex receives similarly ridiculous notes addressed to “Dear Dr: No Referring Doctor.” The paradox here is that the referring physician receives the referral note. Therefore, the practice at least knows how to address the envelope correctly.

I also loved Jedi Knight’s comment that, “We’ve sped up the process of sharing data without considering that the data is no longer worth sharing.” I do hope that the OpenNotes movement and the resulting opportunities for patients to read their notes will spur some providers to clean up their acts. Over the weekend, my dad asked about some information that was in his recent encounter note that didn’t make sense. I hope he calls his doctor on the carpet about it.

The idea that gives me the most hope, though, is Richie’s mention of a “Data Kidney” that can review text for “cleanliness.” In the newspaper world, that would have been the editors and proofreaders. All kinds of imagery comes to mind, including the proverbial red pencil. We’ve got grammar check in our word processing software, so why not for EHR output text?

What gives you hope that documentation will get better? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 6/30/14

I spent most of this weekend doing a special project. Our coding and compliance officers approached me about how some of our providers’ notes look in EHR. They had seen some notes that were “really awful” and naturally assumed that something was going on with the EHR to cause them to be that way.

Our ambulatory vendor offers checkbox-style documentation templates, so I figured the complaints were about how their documentation was being output now that we’re dealing with SNOMED and other factors.

I asked my team to pull a sampling of notes from each of our specialties so that I could look at them myself. We’ve seen issues where the behind-the-scenes verbiage engine generates some subject/verb disagreements. Additionally, when a large number of positive and negative symptoms are documented, sometimes that can get a little strange.

Since our analysts are not clinical, I know that I can’t exclusively use their review to identify good vs. bad notes. Sometimes the documentation might be technically accurate, but would actually be something a receiving physician would laugh at.

We have a lot of subspecialists who do a lot of procedures, so I had the team pull a variety of those notes as well. They’ve been problematic in the past, especially when multiple procedures are documented. Most of those issues have been easy fixes. Still, considering the variety of specialties and all the different kinds of documentation, I had well over 100 visit notes to review.

By the time I was done, I could barely contain my aggravation. The largest subset of “awful” notes came from our providers who are heavy users of voice recognition. Some of the notes were downright incoherent. The problem however wasn’t with the technology – it was with subspecialists dictating sheer nonsense that normal humans (even those with medical degrees) would have difficulty comprehending.

The next subset of bad notes came from providers who have created their own documentation macros. The idea of providers having their own saved text blocks is generally a good one. We all know that there are some parts of the note that are the same over and over again: “regular rate and rhythm, no murmurs, rubs, or gallops, lungs clear to auscultation bilaterally, abdomen soft non-tender and non-distended with normal active bowel sounds.” From years of dictation it just rolls off the tongue, so it would make sense to save it as a block for EHR.

The problem comes when providers save text that either doesn’t make sense or has gender-specific findings that winds up being reused on the opposite gender. The point of saved text is to be able to quickly add documentation with little work. Some of our providers take the idea of efficiency too far, with so many acronyms and abbreviations it’s impossible to figure out what is going on with the patient.

Even with the subject/verb disagreement and some of the typical template issues, the group that most heavily uses check-box powered documentation did the best. They were easy to sort out due to the way the history blocks format and I was surprised at how much clearer their notes were compared to those done via other methods. Those that used the templates, however, had a much higher propensity to document Review of Systems items that I’m sure they didn’t actually perform.

For your amusement, I’ll share some of the highlights:

• General surgeon sees a patient to remove a skin cyst. She documents a gynecological review of systems with seven negative elements. I confirmed that it wasn’t from a paper form the patient completed and staff keyed in. She also documented the procedure as “EXC TR-EXT B9+MARG 2.1-3cm.” What does that even mean? I could extrapolate “benign” and “margins” from that, but it makes no sense for the type of cyst excised.
• The same surgeon documented a 21(!) point male urinary review of systems for a similar visit. The procedure document was the same except it was 0.6-1cm. At least she’s consistent. And apparently thorough, since she documented that she examined all 12 cranial nerves and the cyst was on the shin.
• Orthopedic surgeon documents a physical exam that includes a normal fundoscopic exam. I’d pretty much bank that the last time an orthopedic surgeon touched the instrument needed to look at the back of the eye, it was in medical school.
• Chief complaint of “bx results” which was saved to a provider custom list. Could we not have spared the extra characters to have it read “biopsy results” so that when the patient receives the note on our patient portal it makes sense?
• Not capitalizing the names of other physicians on the team. Nothing says “thanks for the referral” like addressing the letter to “dear dr jayne.”
• A “follow up back pain” visit with a (no kidding) 91-point review of systems including “changes in shape/size of moles” and “breast lumps.” I can’t wait until that one gets pulled for a CMS audit.
• Detailed discussions of radiologic studies pulled into the note from other practices. I guess in addition to being “one patient, one chart” the EHR also lets us time travel because the same CD with the MRI results that the patient hand-carried from shoulder surgeon was simultaneously imported to the orthopedic consultant’s May visit note and also to the nephrologist’s note with a date stamp two months prior to the visit.

I could go on, but it would just make me frustrated and likely make you angry. More than anything, it just makes me sad, especially since the providers electronically signed all of them and indicated that they were read and reviewed.

You might ask who had the best documentation. Hands-down the most coherent, thorough, and clearly non-padded were the notes done by one cardiology group using a mix of voice recognition for the history and plan and template documentation for the physical exam and review of systems. I didn’t identify any gratuitous documentation and the notes were high quality. It probably takes them longer to document since they’re speaking most of the note vs. clicking. However, their documentation was so pretty I wish I could clone them. But CMS says cloning is bad, right?

Got documentation problems? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 6/23/14

The pile of medical journals on my desk has been growing steadily over the last several months. It’s hard to keep up with all the reading required for my informatics role (Federal Register, anyone?) let alone make time for clinical reading.

Summer hit full force this weekend and the prospect of going out in 90 percent humidity didn’t sound too enticing, so I decided to play catch up. One of my journals has a dedicated public policy section and of course the IT-related items always grab my attention.

CMS apparently released a mobile app to help physicians track payments and gifts received from drug and device manufacturers. My journal stack must have been older than I thought since the requirement for manufacturers and group purchasing organizations to collect the data kicked in last August. Separate apps were created for physician and industry use. Maybe being behind on one’s journals is a good thing, however, since it would allow me to do a post-live assessment of the app.

Looking at the FAQ for the app (only CMS would release an eight-page document for a smart phone app) it didn’t look that promising, although I liked the feature that would allow physicians to send profile information from the physician app to the industry app. That would have been helpful last year when I had to provide my NPI number after a colleague bought me a drink. He realized as he was signing the bill that as an employee of a medical device manufacturer, he was obligated to report it.

Knowing that I have no idea what my NPI is, I’d rather have bought him a drink as opposed to having to email myself a reminder to dig it up and send it to him. In case you’re interested, the threshold for reporting is $10. The martini in question was $12.50, having been purchased in a hotel bar at HIMSS. Had we both had the app in play, I could have stored my NPI in my profile and simply beamed it over.

Other than that, the apps don’t communicate with anyone. They are designed to make tracking easier, which probably benefits the manufacturers more than it does individual physicians, except for those who habitually mooch off of every vendor rep they encounter. In the interests of full disclosure, I didn’t accept drug samples in my primary care practice and generally don’t attend industry-sponsored events. I would probably have less than a dozen items to track over the course of a year and they would probably all be related to drinks at HIMSS, MGMA, or another trade show.

The physician app (which is also for other professionals subject to the reporting requirements) also features the ability to create or import QR codes to share information with others involved, although separate codes are needed for profile and payment data. A summary of transactions can be downloaded and the app is password protected. The information is stored locally and will auto-erase after multiple failed access attempts.

If you get a new phone, you might be out of luck since there’s not an easy way to transfer the information. Just looking at the FAQs, it seemed like more trouble than it was worth, but I headed off to download it nevertheless. It requires an eight-character password although it didn’t require me to use anything other than lower case. The cheesy stock images of physicians and industry staff were a turn-off however. Data entry was completely manual, so my initial reaction was right. I’d rather email myself the information and auto-route it to a folder in Outlook.

I agree it’s important for physicians to keep track of their data since it will be made public this fall. I decided to visit the CMS website to see what information was available and whether that martini from HIMSS was now visible to the public. Apparently it’s more complicated than I thought. There are two phases of registration. Physicians can register in the CMS Portal, but then they’ll have to come back in July to register in the Open Payments system itself.

The CMS website links to a “Step-by-Step” registration presentation.  Seriously? CMS expects us to demonstrate Meaningful Use in a variety of ways but has to provide a presentation on how to complete a registration to an online repository? No kidding, it was 42 slides long.

I did learn that the registration just started June 1, which seemed somehow validating that maybe procrastinating on my journals wasn’t a bad thing. Had I read about this last August when it was released, I probably would have forgotten by now.

I also learned that I’d have to go through an identity-proofing process that was even more stringent than what I had to go through to be an e-prescriber of controlled substances. I’ll be asked questions about my employment history, mortgage lender, and other “private data” and information from my credit report. The identity-proofing process is being run by Experian, but CMS wants to assure me the information isn’t going to be stored anywhere. The registration process will result in a soft credit inquiry.

By Slide 11, I was ready for a martini even if I had to make it myself. CMS requires the password to be changed every 60 days, so I’m sure I’ll become familiar with the reset process. I’m not familiar with this CMS portal, so I was intrigued by its promise to “present each user with only relevant content and applications” yet “provide ‘one-stop shopping’ capabilities to improve customer experience and satisfaction.”

My satisfaction wasn’t much improved by the popup that appeared when I tried to read the FAQs to see what else I could do on the Portal while I wait for Open Payments registration to open next month. I did find quite a few new acronyms I hadn’t seen before, but left before discovering anything I thought might be of use. I finally figured out that I had to request access to Open Payments specifically. Maybe I should have paid more attention to Slide 28.

At that point, I went through the actual identity proofing, only to be told I need to set up another profile to register to see my data. I got blocked at that point, since the “Physician” option is still inactive. I’ll have to try my luck in July, when I can not only see my data but experience a yet-to-be-determined dispute process should the need arise. At least that will give me plenty of time to find a new martini recipe. Have a good one for summer? Email me.

Email Dr. Jayne.

Curbside Consult with Dr. Jayne 6/16/14

I’m sure those of you that follow me on Twitter were wondering what could possibly have happened last week to make it one of the strangest days of my career. In retrospect, it wasn’t just one of the craziest days of my IT career, but of my physician career as well.

My hospital is part of a larger health system. When have to have a representative on some kind of IT-related committee, I am usually tapped to attend.

We’re a decent-sized organization with plenty of employed physicians. One of my CMIO friends in a similar situation has employer-paid medical co-payments to encourage staff to see the physicians in their group. Another offers their “associates” early access to office appointments that aren’t available to other patients. Theoretically, when you’re caring for your own people, it should be like a miniature accountable care organization and might give you insight into the best way to maximize health and lower costs for a defined patient population.

I have to admit I am way behind on my email and didn’t read the agenda for our Emerging Technologies meeting prior to heading uptown for the session. I’m barely keeping my head above water and didn’t think it was a big deal because usually the topics are things I can handle on the fly. This time, however, I was seriously wrong.

The meeting happens over lunch and I was trying to grab a quick bite while scanning the agenda as people arrived. One of my IT colleagues thought he was going to have to perform the Heimlich maneuver after I started choking on my salad.

Apparently our brilliant “ET” group decided to bring in a third-party solution for “advanced access” to physicians. Unfortunately, it’s a telemedicine solution staffed not by our own physicians, but by others in the market. As the meeting started, a glossy marketing slick was passed around. I thought it might be some kind of Friday the 13th prank until I realized they were serious.

Our human resources department wants to roll this out as part of our benefits package in the fall. They wanted to vet it with our group as far as our thoughts on HIPAA and other regulatory issues. The health system would pay a fee to the vendor, which offers “doctor visits anytime, anywhere!”

I’m not opposed to the concept of virtual visits, but I’m truly surprised that we wouldn’t give our own physicians the opportunity to not only serve the employee community, but to maybe make a little extra cash as “advanced access” physician resources. Given the recent draft policy from the Federation of State Medical Boards regarding telemedicine, we would be ideal. We’re licensed in the states where most employees live (and are usually located), so that’s easy. We already have unified medical liability coverage, so that’s easy, too. We also have a vested interest in keeping our collective employees healthy as a means to strengthen the community.

I also like the idea of employees being able to receive care without disrupting work schedules, although the service promises access to physicians “at home, at work, or anywhere you need care.” We have enough issues with staff using cell phones to take care of personal business in patient care areas and don’t want to encourage them to talk about their medical issues in the workplace. There aren’t a lot of private places in most of our ambulatory practices (the physicians don’t even have private offices any more) so I’m not sure that’s a benefit.

What really got me was the assertion that the third-party physicians would become “your doctor.” Are they really advocating conducting a longstanding patient-physician relationship established via smart phone? Are they going to be accessible 24/7 to handle all the health issues that typical patients should be addressing with their personal physicians? What is their plan for continuity of care?

I was trying to see the other side of the equation. Maybe they were worried about patient privacy. Employees might not want to see network physicians because their records would become part of our central database. That’s certainly valid. Maybe they were worried about accessibility and that’s a factor, although more and more of our employed practices are extending their hours and providing walk-in accessibility. Maybe they think offering this will differentiate us as an “employer of choice,” as the HR people like to describe it.

One of the other physicians at the table who wasn’t distracted by lunch managed to access the telemedicine website and find out more about it. Apparently they’re willing to partner with healthcare organizations to involve their own physicians, but our HR department didn’t think that was important. They figured they’d just offer it to our employees with the existing provider network because that would be faster.

I wonder if they seriously considered the public relations and morale repercussions of offering our staff having virtual visits with providers from a competitor health system. I’m sure the various medical executive committees at our hospitals will have a field day with this if it moves forward. That’s likely to happen since HR didn’t seem to understand our objections or find them valid. One of the physicians actually got up and walked out. The rest of us stuck it out, if for nothing else than to gather information to help inform our next steps.

Since we’re a technology committee and we couldn’t find any significant technology objections (I have to admit their setup looks pretty slick), it’s likely to move forward. I’m interested to see what the hospital administrators will think since it will likely have an impact on their bottom line.

I’d be interested to hear from organizations who have done something like this, including whether your providers participated or whether you used an existing or external network. We’re having a discussion with the vendor in a couple of weeks, assuming roadblocks aren’t thrown up in the interim. I’m putting together my list of questions and “what if” scenarios for the meeting.

Got ideas? Or alternatively a potential job with a seaside location? Email me.

Email Dr. Jayne.