Quality measure reporting is one of the 3 basic tenets of the EHR Incentive Program—the other 2 being ePrescribing and data sharing (interoperability)—as identified in ARRA, the program’s defining legislation. It is a key component to improving the quality of patient care. In a recent EMR Straight Talk post—“A Waste of Physicians’ Money and Vendors’ Time”—I proposed a more cost-effective method of analyzing clinical quality measure (CQM) data that would deliver more useful information for quality improvement than the approach currently in place for meaningful use. I suggested that rather than requiring each of the 472 vendors of certified EHRs to program the same CQMs (no longer 125 as initially proposed, but still a burdensome 64), EHRs should simply collect and report the data, and CMS or its designate should provide the analytics. Such a centralized approach would not only be more efficient, but it would produce more consistent and reliable data. Most importantly, it would allow for the immediate implementation of any changes to measure specifications as necessitated by the availability of new medical information.
Recently, I confronted a perfect example of the ineffectiveness of the current system and the opportunities that a centralized approach would afford. A physician informed me that a new CVX (immunization) code was created for the influenza vaccine—CVX code 144. While I told this client that we could easily add this code to the EHR for his use in documenting vaccinations (which we did), these vaccinations would unfortunately still not be reflected in the numerator for NQF 0041 (Preventive Care and Screening: Influenza Immunization for Patients over Age 50)—a fact validated by CMS. New electronic specifications for CQMs will not be implemented until 2014, and the current specifications remain in force for 2012 and 2013.
As an EHR vendor, I certainly appreciate the fact that we are not subject to the expectation that we will reprogram measures off-cycle. That would wreak havoc with our development roadmap and resource planning. Furthermore, changing the calculations to accommodate the new codes would compromise data comparability. So now we have comparable—but incorrect—data that does not reflect actual vaccination status. Under this system, how will we ever stay current as medicine constantly evolves?
Just imagine if everyone could begin using the new CVX codes immediately because the electronic specifications were updated in one centralized location with one effort. This is just one example from a potential 64 CQMs. How much more value would we derive from all the work that we demand of physicians in capturing the CQM data? How can we accelerate healthcare improvement if we are always 2–3 years behind?
CMS asked for comments on its Proposed Rule for Stage 2 Meaningful Use, and it got them—1,131 of them, to be exact. While the comments that have drawn media attention are those from major stakeholder organizations, the vast majority of comments were submitted by individuals—and CMS is obligated to read and consider each and every one of them as they formulate the Final Rule.
I thought it would be interesting to see whether the comments from those in the trenches—those whose everyday lives are impacted by the meaningful use regulations—are in line with the sentiments expressed by groups like the AMA, AHA, MGMA, EHRA, etc. In a review of the first 25% of the comments by individuals, (over 250 comments), a consensus clearly evolved around a few major points, and the results remained fairly consistent as we read. The graph above illustrates the prevailing sentiments.
By far, the predominant concern is that the proposed requirements are far too demanding, i.e., the bar is being set too high. An overwhelming 82 of the comments identified the sheer number of measures and components, challenging thresholds, the cost of compliance, and overly aggressive timetables—even in light of the delay to 2014—as being unrealistic.
On a similar note, another 14 addressed the complexity of the requirements, describing them as difficult to understand, ambiguous, and overly complicated. When combined with the above, approximately 40% of the 250 comments reviewed maintained that the Stage 2 requirements are simply too demanding.
As anticipated, there was a resounding concern (56 comments) about holding physicians responsible for actions by any third parties over whom they have no real control. Most comments referred to the requirement that patients view or download their charts and communicate to the physician by secure e-mail, but some asked that providers be insulated from any failure by vendors to meet the requirements or the client upgrade schedules.
The limited relevance for specialists remains an issue in Stage 2, as the program is still viewed as primary-care focused. There were 23 comments that addressed the paucity of meaningful use measures and clinical quality measures that are relevant to specialists, and some went so far as to claim that trying to meet requirements that are geared towards primary care could actually distract specialists from their own priorities and be detrimental to the quality of care they would be able to deliver.
Some comments addressed the penalties and suggested that the rules provide for a broader range of exemptions and more leeway. The suggestion that the first year of Stage 2 only require 90 days of reporting—which was suggested for other reasons as well—was supported by providers concerned with the penalties.
In response to a plea from CMS that people report what they like in the proposal, in addition to what they don’t, some commenters expressed general support for the Stage 2 recommendations, and a small number argued that the bar wasn’t raised high enough. Some—likely specialists—applauded the change in exclusions for reporting of vital signs; several approved of ensuring patient access to their clinical information; and there was support for the proposed harmonization of clinical quality measure reporting under the various government programs (meaningful use and PQRS).
Perhaps what is most interesting about the comments is the emotion and passion behind many of them—whether expressing favorable or unfavorable opinions. If you would like to browse through the public comments yourself, go to www.regulations.gov and enter “CMS-2012-0022” in the search bar.
I am a firm believer in the tremendous value that the right EHR can deliver to physicians, so the historic dissatisfaction with the EHR industry—as reported in studies and anecdotal conversations—has long disturbed me. The alarming intensity of this dissatisfaction was brought home by visitors to my company’s booth during the recent AAO (American Academy of Ophthalmology) meeting.
I was truly appalled by the abject frustration and anger expressed by numerous physicians about their EHRs. One visitor described his experience by saying, “It has taken the joy out of practicing medicine.” Another said that he felt like he should put a picture of his face on the back of his head so that his patients could see him—because he was forced to focus on the computer and enter data while the patient provided information. Physicians universally complained about the “productivity-killing” impact.
Why is this so? I know there are good EHR products in the market that physicians enjoy using and that enhance, rather than reduce, their productivity. Why are physicians not more successful in finding these?
The answer is that EHRs are being oversold. There are many EHRs that are marvels of software, capable of doing incredible things, but the selection process that physicians typically employ is flawed, and the sales process capitalizes on this shortcoming. The salesperson dazzles them with a demo, or they take prospective purchasers to see a physician—typically just one or two—who adeptly uses the software. This creates a false sense of ease-of-use, and the physician prospect leaves the site visit expecting that he or she will be able to use the EHR just as successfully. But not all physicians are alike—they may all be very intelligent and have tremendous medical expertise, but they are not all equal in technological inclination or skills. Their success—or lack thereof—with a particular EHR will vary significantly.
This brings us back to the importance of doing due diligence—something I have talked about before. Call and/or visit a variety of physicians who represent a wide spectrum of proficiency. Go to the reference practice’s website and select physicians on your own—don’t rely on the vendor’s selection. Ask the kind of questions listed in the last EMR Straight Talk. This is the only way to increase the odds of a successful EHR experience, and to avoid making a painful and costly mistake.
This week, KLAS released its first EMR Performance Report that organizes results according to the specialty of the rating provider. Although the publication of “Ambulatory EMR by Specialty” came on the heels of my posts last week—titled “One Size Does Not Fit All” in EMR Straight Talk and HIStalk—the timing was purely coincidental.
I want to commend Mark Wagner and Kent Gale for taking on this new approach to analyzing and reporting the data they collect. I have had numerous conversations with KLAS on this subject over the years, urging them to report by specialty for all the reasons identified in my posts, and they clearly recognize the value of this type of information. This effort by KLAS was a major undertaking, and the result represents a significant breakthrough in the way the EMR industry provides access to information.
For any specialists looking to adopt an EMR, the KLAS report “Ambulatory EMR by Specialty” is a must-read. It contains information that is vitally important to informed EMR decision-making.
The data raises some interesting questions and implications. In next week’s EMR Straight Talk, I will share some initial observations.
In my recent post on the industry-leading EMR blog HIStalk, I discussed the impossibility of one type of EMR ever meeting the needs of all the disparate types of providers. Among the arguments I presented was that it is impossible for the same EMR product to satisfy both hospitals and private-practice physicians. Enterprise EMRs simply do not work in high-volume ambulatory settings, and it is unrealistic to expect that they would.
Apparently, this hit a nerve, given the passion and intensity of the comments, most of which addressed Epic. (You can read the comments by clicking here.) In response to Peppermint Patty’s claim that “tens of thousands of happy specialists use Epic,” Epic Mythology replied, “The idea that all specialists, or users in general, are happy with Epic is a flat-out lie. My own academic specialty clinic rebelled against Epic’s ambulatory interface as long as we could, and we switched only by force. It destroyed my clinic workflow, and I now see fewer patients while spending longer documenting. . . . I have yet to meet any doctor who really likes Epic.”
There you have it—the basic problem in our industry identified very simply by the argument between Peppermint Patty and Epic Mythology. How do we know who is right? These and several of the other comments beg the question of how a specialist—or any physician—can ferret out the truth about the potential of Epic (or any other enterprise EMR) to satisfy his or her practice’s needs? This is becoming an increasingly critical issue, given the growing pressure hospitals are putting on physicians to adopt the enterprise system by subsidizing the cost. Are physicians who succumb to this pressure getting what is right for their practices?
The following is the comment I added to HIStalk following the initial set of responses to my “Reader’s Write” post:
Judging by the comments to my post, the implementation of enterprise EMRs in ambulatory practices is a major issue confronting physicians. Most of the comments focus on Epic, the dominant player in that market. Peppermint Patty and Epic Mythology sum up the two positions—the former claims that there are many happy users of Epic, while the latter argues the exact opposite. Who is right? And how do we find out for sure? My experience speaking with thousands of physicians over the years supports Epic Mythology’s position—like him, I have not met many specialists satisfied with using enterprise EMR systems in their private practices.
Given the revived interest in EMR purchases, it’s critical for the physician community to know the truth.
Please continue the conversation by commenting on EMR Straight Talk (below) or by joining the dialogue on HIStalk.
A frequent concern I hear in my conversations with physicians is that they are challenged by increasingly harsh economic pressures. Healthcare reform, lower—or at best stagnant—reimbursement rates from government and private payers, and the higher proportion of lower-paying Medicare patients are reducing or capping practice revenue. At the same time, overhead costs are escalating unrelentingly, since employees still expect raises and other operating costs continue to rise. While the common perception is that physicians are not businessmen/women, they are in fact running small businesses; and now, more than ever, they need to focus on ways to maintain business viability in light of lower margins.
The above graph illustrates the economic challenges. Click on it to enter your own practice data and assumptions concerning anticipated growth or decline in reimbursement and expenses, and observe the effect on physician income—the green line. Given that physicians have no control over reimbursement rates, the only way to positively impact that green line is by effecting fundamental changes to practice operations—and the right EMR is critical to this end.
First, it is imperative to significantly reduce overhead—the orange line. Government programs that may, or may not, deliver short-term financial incentives do not address cost structure. What is needed is an EMR that delivers sustainable and significant reductions in the staff-to-physician ratio and more efficient management of all resources—depressing the orange line. Increasing revenue—the blue line—requires increases in physician productivity and patient volume. The challenge here is to wade through EMR marketing hype to identify the EMR that will actually shift the orange line down and the blue and green lines up.
The Economic Stimulus legislation has presented an incredible opportunity for EMR vendors. Unfortunately, it seems that some of them are taking advantage of it by giving out misleading information and applying scare tactics so that practices will purchase their EMRs. Below is a sampling of such statements, which have been forwarded to me by physicians asking whether they are “fact or fiction.”
Have you had similar experiences? Please share them by submitting a comment at the bottom of this post.
What some EMR reps are saying:
“The government is requiring you to buy an EMR.” This one is a scare tactic since participation is voluntary.Section 3006 of the American Recovery and Reinvestment Act specifically states “…nothing in such Act or in the amendments made by such Act shall be construed to require a private entity to adopt or comply with a standard or implementation specification adopted under section 3004.”
“Your EMR must be CCHIT-certified to qualify for the incentive payments.” I hate to use the word “lying” but this statement comes close since the legislation neither identifies standards nor mentions any particular credentialing body, including CCHIT. The HIT Standards Committees, which just had its first meeting on May 15, is charged with recommending an initial set of certification standards by December 31, 2009. Recently, there has been a surge of rhetoric in the media expressing dissatisfaction with CCHIT, so it is by no means a foregone conclusion that CCHIT certification will be required.
“Simply buy a CCHIT-certified product, and you will qualify for the Stimulus money.” This remark is similar to “I have a great stock to sell you”—because EHR incentive payments are not guaranteed. Simply purchasing a “certified” EHR is not sufficient; the incentives require you to demonstrate “meaningful use” of the EHR every year, and to do so in the manner specified by and to the satisfaction of the government. “Meaningful use” has not yet been fully defined, and the legislation states that the requirements are to become more stringent over the period covered by the law.
“You must act now—buy an EHR now because in order to get the money from the government, you must be using the EMR by 2011.” As with used-car salesmen, “buy now” is always popular, but you actually have until 2013 to implement and potentially qualify for the lion’s share of the incentives. Even if you do not implement until 2014 (5 years from now), you would still be eligible for almost 80% of the money.
Have you heard any of these statements of “fact”? My advice: Do your due-diligence. Make sure you understand the real facts about the legislation and find an EMR that meets the needs of your practice. Have you heard other statements of “fiction?”—Please share them by submitting a comment at the bottom of this post.