Round 1’s Definition of “Meaningful Use” for EHRs

As we discussed the governmental push {Stimulus} towards EHR, the definition of “meaningful use” came to surface; rather the lack of definition arose. EHR companies and healthcare facilities alike have been waiting to hear from the HIT Policy Committee on “What exactly defines ‘meaningful use’ of an EHR?”. On June 16, the committee released its initial recommendations for the definition.

Health Data Management reported this “First Look at ‘Meaningful Use’” article, which lists 15 of the 22 objectives for EHRs in 2011. Here’s the list:

* Use CPOE for all order types including medications
* Implement drug-drug, drug-allergy and drug-formulary checks
* Maintain an up-to-date problem list
* Generate and transmit permissible prescriptions electronically
* Maintain an active medication allergy list
* Send reminders to patients per their preference for preventive and follow-up care
* Document a progress note for each encounter
* Provide patients with an electronic copy or electronic access to clinical information such as lab results, problem list, medication lists and allergies
* Provide clinical summaries for patients for each encounter
* Exchange key clinical information among providers of care
* Perform medication reconciliation at relevant encounters
* Submit electronic data to immunization registries where required and accepted
* Provide electronic submissions of reportable lab results to public health agencies
* Provide electronic surveillance data to public health agencies according to applicable law and practice
* Comply with federal and state privacy/security laws and the fair data sharing practices in HHS’ Nationwide Privacy and Security Framework, released in December 2008.

Once this first round of definition and standards were released, we read in Modern Healthcare where

“the group invited feedback on whether the balance it sought to strike was ‘overly aggressive based on the current state of technology and the demands on new provider workflows, or not challenging enough to result in significant transformation.’”

Some believe the group did a nice job of establishing a decent framework for the standards. Some believe the objectives have set the bar a little too high, which could slow the adoption of EHR. The jury is still out.

“For better or worse, it is now the starting point for what surely will be months of debate on ‘meaningful use’ before the federal rulemaking is completed. That is expected to happen sometime early next year. Even then, the meaning of ‘meaningful use’ will remain fluid throughout the life of the EHR subsidy program, which is now slated to run through 2015.”

Here’s a helpful matrix that the group developed that outlines the Goals, Objectives and Measures of “Meaningful Use”.

There is one thing you need to be sure of: Make certain that your EHR not only meets the governmental standards and objectives, but also shows measurable results in your facility with positive feedback from active users. Make sure that your facility sees improved patient care, increased safety, reduced medical errors, and a healthier bottom line. To do this, you must be sure that your EHR covers all your bases.

In my time, I’ve seen a gap in the ability of EHRs to capture surgical documentation at the point of service. This is exactly where ComplyMD comes into play and fits seamlessly with most any EHR on the market. You’ve got to engage physicians. You’ve got to capture their attention at the point of service, when their knowledge of the patient encounter is most fresh. You’ve got to ensure they give accurate, comprehensive documentation. You’ve got to have ComplyMD’s Surgeon Notes™ solution.

Money, Money, Money: The Stimulus

Since President Barack Obama signed the $787 billion American Recovery and Reinvestment Act of 2009, the words “stimulus” and “EHR” go together like bread and butter in the world of Healthcare IT. This article from our friends at Modern Healthcare Magazine’s February 23, 2009 edition titled “IT’s the Money” gave us a great overview on what some experts had to say about the Stimulus money’s impact on EHR adoption among hospitals and office-based physicians.

“Industry officials said the federal money and standards setting provisions in the new law will be the twin charges that burst the financial dam that has kept electronic health-record system adoption at relatively low levels.”

“The Medicare and Medicaid incentive programs will more directly subsidize adoption of EHRs by providers. Hospitals will receive IT payments over a maximum period of four years…..For those hospitals using “meaningful” EHRs during fiscals years 2011 through 2013, the amounts will be a 100% payment the first year, and 75%, 50% and 25% the subsequent years.”

Here’s a graph depicting the bonus structure for early EHR adopters:

Health I.T. Carrots

With these Health IT Carrots, comes Health IT Sticks. “The stimulus law calls for Medicare reimbursement penalties for physicians how delay adoption of health information technology until after 2014.” If you start in 2015, your Medicare penalty is -1%; 2016 penalty is -2%; 2017 penalty is -3%; 2018 penalty depends on overall adoption rate.

So what does all of this have to do with ComplyMD, a non-EHR healthcare solutions company? It has everything to do with ComplyMD. One of the gray areas of this whole carrot is “What is the definition for ‘meaningful use”? (We’ll get more into that next week.) But for now, I want us to focus on the plain fact that Electronic Healthcare is coming. Like it or not, every facility, every physician, every nurse, every hospital employee, every patient, everyone needs to accept the fact that technology is changing patient care. The government is pushing for adoption of EHRs; facilities are putting it off. The government is giving incentives for early adoption; some facilities are still putting it off. As we’ve discussed before, successful adoption hinges on a facility’s readiness for such a massive undertaking as EHR adoption.

How Far Does Your Facility Go for Documentation Assurance?

In Hospital Case Management’s recent article “Does Your Documentation Assurance Program Stop Short?” (March 1,2009), the following quote caught our eye:

“If your documentation assurance program focuses on reimbursement alone, you’re not going far enough. With pay-for-performance initiatives on the rise and increasing mandates for public reporting of hospital data, it’s critical that the medical record accurately reflect the severity of illness and the services provided to your patients.”

If we really think about it, the quote above is totally true. Many facilities have implemented Documentation Assurance Programs, such as Clinical Documentation Improvement initiatives. And these programs oftentimes measure ‘success’ in terms of dollars and cents, rather than by quality documentation of severity of illness, continuity of care, level of acuity and risk of mortality.

“Many times, documentation specialists do a great job of picking up the complications/comorbidities (CCs) and major complications/cormorbidities (MCCs) but stop right there and miss the opportunity to add additional documentation, which will affect the drivers of acuity level and risk of mortality.”

Documentation Specialists are trained professionals who are taught to look for those CCs and MCCs. In an attempt to build the best DRG, they must capture these important conditions. But, they shouldn’t just stop when they’ve gotten to a certain DRG level. A good Documentation Specialist will not be focused on getting the patient into the highest paying DRG, but will be focused on painting the most comprehensive picture of the health of each patient.

This is exactly where ComplyMD comes in. In attempt to paint the most vivid picture of (1) the health of the patient and (2) the procedure(s) performed on the patient, we aid physicians and staff in capturing the most documentation about each patient encounter.

Pay-for-Performance: Will you be a loser?

“Pay-for-performance reimbursement plans and consumer-directed health plans both depend on assessing and distributing information on clinical performance. Physicians who don’t have the means to track their own clinical results will be losers, literally, of patient volume and revenues.”

“Medicare Quality Codes & Their Impact on Physicians” ICLOPS, LLC. December 2005

With these new plans and governmental mandates, physicians need to be equipped with the tools to properly, easily and efficiently track their own clinical results. Capturing appropriate documentation of diagnoses and procedures will result in capturing appropriate revenue for the facility and the physician. ComplyMD is a web-based application located inside or immediately outside the OR to help physicians capture appropriate documentation, at the point of service. The more time physicians wait to document (dictate) their procedures, the more room they leave for error in their documentation.

ComplyMD gives physicians multiple choice lists of proper, code-ready documentation of diagnoses and procedures. It creates a comprehensive operative note for the patient encounter that’s ready to be sent to the coder’s office, immediately after the procedure. ComplyMD gives physicians the tools to track their own results so they will not be losers of patient volume and revenues, and their facilities will not be found as losers either.