Taking the long view ... again.

HITECHAnswers has published another worthwhile read for those of us who like to think big picture. It's First Glimpse at Stage 3 Meaningful Use Measures by Mary Mosquera, Senior Editor, Government Health IT. 


I'm intentionally keeping my comments short today in the hope you'll click the link and read what Ms. Mosquera has to say. If you've been following the long-term trends, you already knew that clinical decision support would be the crown jewel of Stage 3 certification. No surprise, the Health IT Policy Committee confirmed that direction at its August 1 meeting.


To date however, most talk of CDS centers around drugs: drug-drug interactions; drug allergy alerts, and so on. And, in this area, an authoritative resource is sought, versus every vendor coming up with its own rules. Great concept! That might leave vendors a place still to set themselves apart - for example, helping with the everyday decisions made by providers that are not medication related yet lead to better patient outcomes.


In the meantime, read Mary Mosquera and maybe a related post or two. Enjoy!


Alistair Jackson, M.Ed.

Key Changes to the ONC HIT Certification Program

You probably already know that the current EHR certification program is a temporary certification program. The anticipated sunset of the temporary certification program is expected to occur upon the effective date of a final rule for the stage 2 proposed rule. At that time, the permanent certification program would become effective and known as the “ONC HIT Certification Program”. 

Proposed changes for stage 2 aim to increase regulatory transparency and add flexibility for the HIT community. ONC is proposing changes to the certification processes for EHR Modules that remove certain certification requirements and provide clear direction for certifying to proposed new certification criteria. The revised process would provide flexibility to quickly utilize newer versions of “minimum standard” code sets. Also proposed is an increase in certification transparency and clarity by making publicly available the test results used to certify EHR technology and clearly representing EHR technology that has been certified. Public comment is also invited on full cost transparency for certified Complete EHR and EHR Module.

Here's another interesting request for public input, a statement that corroborates our recent post on EMR switching. ONC writes in its Stage 2 Fact Sheet, "Data portability (including the migration from one EHR to the next) is a key factor in the EHR technology market where agility and innovation is necessary. We request public input on ways to improve data portability, including comment on a proposal to improve data portability for providers."

A final note: our discussion of Stage 2 is based on the proposed rule making. The 2014 Edition EHR certification criteria are opening for public comment through May 7. Only after this date will a final rule be published.

Alistair Jackson, M.Ed. 

Acronyms of Change, Part 8 (CEHRT)

Here's another acronym I couldn't resist sharing: CEHRT: Certified EHR Technology. The Office of the National Coordinator is looking to revise the definition of CEHRT, based on feedback from stakeholders and the recommendations from the HIT Standards Committee. The new definition would take effect beginning with the EHR reporting periods in 2014, and would provide more flexibility for eligible health care providers. 

The proposed revised definition of CEHRT would require eligible health care providers to have a "Base EHR" that includes fundamental capabilities all providers would need to have, as well as the additional EHR technology necessary to meet the meaningful use objectives and measures for the stage of meaningful use that they seek to meet and to capture, calculate, and report clinical quality measures, but not more than necessary to meet those objectives. A Base EHR would include such fundamental capabilities as:

1. the ability to provide clinical decision support; 
2. the ability to support physician order entry; 
3. the capacity to exchange health information with other sources; 
4. and the capacity to protect the confidentiality, integrity and availability of health information stored and exchanged. 

The revised definition of CEHRT would also enable eligible providers to upgrade and adopt EHR technology certified to the 2014 Edition EHR certification criteria as early as 2012 if they so choose.

That's the information piece. Now, what are the takeaways? 

1. There's nothing more constant than change. Expect continuous change as we move through the transformation of healthcare. That's not a bad thing. In fact, it's a good thing. Change means someone is listening and adapting.
2. Note well the repetition of clinical decision support. It's an incidental mention here but make no mistake, it's a key underpinning showing what is expected of CEHRT.
3. Note also the frequency of exchange language. The transformation of healthcare is all about taking us outside the four walls of our practice to the wider community. Exchange means the portability of health information, locally, at the state level and, in due course, nationally.
4. Just as healthcare at large is continuing to evolve, stay after your own change process. If you've implemented EHRs already, don't stop there! Keep moving on. And the next step is your state Health Information Exchange. Find out more from your state association and check back here; we'll soon be talking about an eye care demonstration project for a state HIE.

Alistair Jackson, M.Ed.

EMR switching? The second wave.

I want to reference today a great discussion by John @ EMR and HIPAA, EMR Switching Encouraged by Meaningful Use. My colleagues and I have long believed we'll see a second wave of software purchasing (switching) driven by usefulness, or what one commenter called "functional disappointment".


First-wave buyers are often driven by easy-to-assess factors, such as screen appearance or price. Coming from paper, we may be satisfied to see during a demo that the software covers the expected items, i.e. the checklist you have on your paper exam form. After that, if the software is certified, it's easy to conclude that "it must be good". Throw in a big name and a low price and you're ready to make your leap of faith.


Second-wave buyers are ready to look deeper. You may already have experienced this with your cell phone, car or house. My wife and I bought our second home not because the first home didn't have everything on our checklist but because of missed criteria we did not have on our checklist the first time around.


What are those missed criteria for EHR buyers? Without attempting an exhaustive list, here are some things to consider:
1. Meaningful Use is for the government; usefulness is for you. Buy for both.
2. We're moving from recording results to "improved patient outcomes". That means software has to be smart.
3. "Smart" starts under the hood. If the software doesn't show evidence of a robust rules-based engine, look elsewhere.
4. All software programming uses rules to a greater or lesser degree, so engage some qualified IT people to advise you on what's under the hood. 
5. Remember that cloud computing is a delivery method not a software guarantee. While there are good things about browser-based solutions, they can still be seriously underpowered in their decision-driving capabilities.
6. As we move to stage 2 of meaningful use, communications will be the litmus test. I believe that in stage 3, clinical decision support will be the final test. This is where "smart" will emerge from under the hood to the surface and where the inferior solutions will fall by the wayside.
7. The stages of meaningful use govern phases of certification. These phases do not limit vendors from releasing useful functionality today. Therefore, look for signs of advanced communications and clinical decision support today.


Alistair Jackson, M.Ed.

Predictions anyone? Where next?

We're suddenly into a very exciting 2012. Why? At our company at least, the news of successful attestations began trickling in before the old year was done. 90 days from October 3 brought us right to the door of the new year. It'll be very interesting to see the numbers, the announcements and press releases that emerge as the 2011 Meaningful Use statistics get tabulated.


Predictions anyone? I predict a new wave of hope and belief in Health Care Reform. The naysayers have had their day and the facts are now all but undeniable: reform is here, it's here to stay and it has come to eye care as well.


There's another reason to get excited about 2012. Every vendor that's going to be a certified EHR player has now been through the first wave. With the early adopter phase behind us, we're all more prepared for the second wave. We've smoothed out the wrinkles, we've created our supporting documents and resources and we've achieved the desired result: money in the pockets of customers who believed in us and took those first steps.


2012 will not be without its new frontiers however. We're over the Stage 1 EHRs hump but here comes the HIE hump. We've proven the case for EHRs but now need to get communicating at a whole new level, the statewide level. 2012 will be the year when Health Information Exchanges appear at center field and certified users will start demanding to play ball in the big leagues.


Alistair Jackson, M.Ed.

Stage 2 Certification – the Great Delay

By now, most of us know that Stage 2 Certification for EHRs is being delayed. Originally set to take effect January 1, 2013, it has been pushed back to 2014. This is a good thing for several reasons:

• Someone’s listening. We all want to be heard and there’s no shortage of input on this massive transformation in healthcare. The great delay is to give everyone the additional time they’re asking for. It’s a win-win response.
• Time is our friend. Health care reform is complex enough on a pure technology level. But it’s more than that. It involves all of us and our individual learning curves. In even the best case scenarios we need time to adapt and embrace.
• Incentive payments are unaffected. For those who started into their MU Attestation already – and even for those who will start in 2012 – the stimulus incentive grants are not affected. In fact, given that the Stage 2 and 3 requirements will only get more stringent, this means the early adopters get an easier ride. For a whole extra year, they get to keep doing what they’re already doing.*
• An early-adopter bonus. The incentive program rolls out over five years, right? Do the math. Those who got started in 2011 will finish collecting their grants by the end of 2015. That means the early adopters will finish collecting before Stage 3 hits. To be clear, I don’t mean Stage 3 standards will not apply to those who finish by 2015, only that they won’t have grant money at stake as they move into the Stage 3.

* This point is worth clarifying. I still get asked frequently if, once the 90-day Meaningful Use Attestation period is over, do I just wait until the next period comes around? The answer is no. The whole point of the incentive program is to get you engaged in permanent change. Your initial attestation period, be it in 2011, 2012 or later, will be 90 consecutive days. Once that period is over, you must continue demonstrating Meaningful Use 365 days a year, and from year to year. 

Alistair Jackson, M.Ed. 

What are you doing about health care reform? (Part 1)

I recently asked that question of an optometrist I considered a prominent figure in the eye care profession. Response? “You know, I just don’t believe the feds are going to pull it off.” Unfortunately, that answer belies what I’ve heard all too often. Ostrich syndrome.
Meanwhile, our friends at HITECHAnswers (I strongly recommend following ) are announcing,“Critical Mass in the Advance of Health Information Technology” including:

• Over 115,000 eligible professionals have signed on with the Regional Extension Centers.
• Close to one billion dollars have been paid out in incentives to date. [aj: HHS has since announced, as of Oct.31, it was over $1.2 Billion.]
• Over 650 complete EHRs have received Stage 1 Certification.    
• 2012 will see the transition from the Temporary to the Permanent Certification Program. 

Optometry has a problem. Though far from all, too many leaders are playing wait ‘n see. Ophthalmology is not playing that game. Instead, the MDs are running away with the evidence-based medicine that will be critical to the Quality Measures upon which all eye care pay-for-performance will be established.
In our 2007 white paper, A White Paper for Optometry: Medicare Pay-for-Performance & Value-Driven Health Care, we asked the question, “Is it in the best interests of either the patient or the health care system itself to emphasize surgical and advanced-treatment methods over early intervention and preventive methods?” Then we gave our answer. “Clearly not! Yet this is the natural course of the current pay-for-performance implementation. Optometry must position itself to gain input into the outcomes selection process.”


Alistair Jackson, M.Ed.