Final “2014 MU Flexibility Rule”—What It Does and Does Not Offer

As predicted, the rule modifying meaningful use in 2014—now referred to as “The blog-103014Flexibility Rule”—was finalized basically as proposed. Pleas for future flexibility, however, were rejected. (For a review of the details, read EMR Straight Talk’s Kudos to CMS for MU 2014 Proposed Rule).The good news is that for 2014, many providers can report Stage 1 again instead of Stage 2, and some providers can report using 2011-certified EHR technology instead of 2014 CEHRT.

Providers who exercise any of the flexible options will have to attest to the following statement: “EP was unable to fully implement 2014 Edition CEHRT for a full EHR reporting period in 2014 due to delays in 2014 CEHRT availability,” and they should be prepared to support their decision if they are audited pre- or post-attestation. Potential justifications include—for example—certification delays or implementation backlogs, software problems once the EHR was implemented or upgraded, delayed installation of required integrations/interfaces, insufficient time to make necessary workflow revisions, etc. Provider inaction or delay, financial constraints, inadequate staffing, and the contention that Stage 2 is just too darn hard—while certainly understandable—are not considered legitimate justifications under the rule.

Many of the comments submitted on the Proposed Rule had asked (“pleaded” would be a more accurate word) for flexibility beyond that which was offered. The biggest “ask” in this regard was for quarterly reporting again in 2015, as it is in 2014, rather than full calendar year reporting. CMS rejected that request outright. Undeterred by that response, numerous healthcare professional organizations subsequently submitted their recommendations on the future of meaningful use directly to the Secretary of HHS and the head of ONC—the two organizations responsible for the program. In addition, “The Flex-IT Act” (recently introduced by representatives Renee Ellmers and James Matheson) attempts to mandate a return to 3-month reporting.

While it may be tempting to dream that the bill will become law or that CMS will relent, the only safe assumption at this time is that the 2015 meaningful use reporting period will begin on January 1. Therefore, any physicians who want to pursue meaningful use incentives in 2015 will need to have a 2014-certified EHR in place by January 1 (if they are not already using one), and physicians who will be at Stage 2 next year should devote the next 2 months to preparing to support the increased requirements—installing required interfaces and integrations, implementing Direct, and developing new workflows as needed.

Client Satisfaction Isn’t a Noun

People talk about client satisfaction as if it were a static thing—something that never blog-101314progresses or evolves. I believe the “action” in satisfaction means we must continually measure it and make adjustments as necessary. Our world is constantly changing; what made a customer happy three months ago may have nothing to do with his or her needs today. We must check in on a regular basis through a variety of channels in order to create a multi-dimensional living model of what our clients really want. Only then can we understand whether we are truly satisfying our customers. In order for any company to innovate, they must know what is important to clients today—as well as have a sense of what will be important tomorrow. Insights are discovered in many ways, and I believe we should use a variety of tools to determine the most accurate picture. Here are a few:

  • Industry Events – Be present to check the pulse of your industry, hear about issues and trends, and speak to others as an authority and a colleague. Events are already in place for these purposes, so get out there and learn.
  • Focus Groups – Drill down to specific insights that allow you to ask new questions and test ideas that may not yet be ready for a larger forum. Modern focus groups can provide nearly instantaneous feedback and insights at a very reasonable cost, so consider upping the frequency.
  • Social Media – Sometimes it’s the informal comment or question that can trigger a breakthrough innovation. Social media can be the next best thing to actually talking with clients—and sometimes even better, since it gives people a place to share their thoughts in real time.

If you’re really committed to knowing (instead of assuming) what your customers are thinking, why not create a whole experience dedicated to discovering just that? Right now I’m at our annual User Summit, where my team and I will be spending three days with our clients, listening to what only they can tell us. This is the ultimate forum for the pursuit of knowledge, and we look forward to learning how to continue to evolve our company to best serve our customers. Each customer interaction reveals different insights; enabling and acting upon that ongoing dialog is what we consider to be the action in customer satisfaction. It’s what allows us to innovate with purpose. The most significant question our clients ask right now is, “How can I successfully meet government requirements and achieve my practice’s goals without having to sacrifice one to serve the other?” I’ll be sharing more about our answer to that in my next blog post, so stay tuned . . .

The Key to Growing Your Practice

blog-key-093014If there is one thing both physicians and vendors readily agree on, it is the ever-
changing healthcare landscape—driven by legislation, government programs, and technology. This changing environment poses a challenge for medical practices and businesses alike to retain and attract new patients/clients in order to prosper and thrive.

How can a medical practice operate like a successful business? It all starts with creating a marketing plan that includes clear goals, an identified target market, powerful tactics to reach your target market, and metrics to measure your success. The marketing plan acts as a roadmap by clearly stating goals, laying out a tactical plan of action to achieve them, and identifying the right measurements to ensure a successful outcome. Clearly defined goals might include a targeted number of new patient visits/follow-up visits/procedures per month. Not only is the goal clearly defined, it is timely, and measurable.

The tactical portion of your marketing plan will identify the ways in which you plan to reach your target audience. Today, patients search for information online. This makes your website the focal point of your practice’s online presence. It should be up to date, accurate, and user-friendly. Both your website and social media can help position your practice as an educational resource by providing videos concerning disease-state awareness, detailing procedures, and exposing patients to educational information about practice resources and expertise.

Having the right technology can also help you reach your goals. For example, you can leverage your EHR to run reports identifying a subset of patients (target audience) inclusive of demographics, frequency of visits, diagnoses, and procedures. These reports can be used to assist in communicating with these patients to drive follow-up visits.

In addition, push notifications such as e-mails can be sent through the patient portal to request appointments or to communicate with patients. The use of a portal cuts down on phone calls and paper, representing a significant financial savings and creating an efficient flow of patients through the waiting room. Print materials placed strategically at check-in and check-out points can also help educate patients, and drive portal usage.

Developing and implementing a marketing plan for your practice will place you ahead of the competition, in front of patients and referral sources, and increase your revenue base.

When Is an EHR Like a Tesla?

091214-blogMany of us simultaneously adore and fear the high-tech gadgetry that has entered our day-to-day lives. We adore the benefits today’s technology can bring—convenience, speed, connectivity—yet we fear the ramifications of the unknown. From mobile phones to golf clubs, there are so many choices out there, and we all want to make the right choice. But how do we determine what is right for us? Ironically, our high-tech decisions are usually made in a very low-tech way—through discussion with people we trust. In my circle, I’ve always been the one that friends and family have come to for insights on all things technological.

I’ll admit I’m a technophile, but with a caveat: I’m only for technology that actually helps our lives in meaningful ways. Just because a new gizmo exists doesn’t mean it is right for my life—even though many times, it’s just that it’s not quite right, quite yet. I’ll give you an example: lately, I’ve been getting barraged with questions about cars with alternative-fuel sources. Most often I’m asked, “When are you getting a Tesla?” My response, “Not now,” seems to surprise those who know me.

Don’t get me wrong. I wholeheartedly support the inroads Tesla is making in bringing electric-powered cars into the mainstream. These are gorgeous automobiles that are winning awards from all the right sources for everything from performance to safety. Those who have them brag about being on the leading edge, and with every right. But if you dig a little deeper, you’ll find that some of these proud owners are plagued with a fear... a fear that, at some point, they will literally run out of energy because there aren’t enough charging stations. The infrastructure simply is not in place yet. So if I run out of electricity—a very real possibility—I don’t care how amazing these cars are; I’m still stuck, and may as well be driving an AMC Gremlin.

What does this have to do with what I do? Meaningful use makes many high-tech demands of the physicians we serve in the HCIT industry, and it seems that some of those demands don’t consider the implications to the physician in a practical application. Why are doctors—whose time is best spent interacting with patients in a very human way—being relegated to capturing every bit of data imaginable when chances are they will only leverage a very small portion of the information? This is especially true when that data (a) may not be relevant to every patient and/or practice, and (b) may not ever be shared because the information superhighways for this exchange are still under construction.

The right data is critical, of course, and that’s something that medical professionals have long been experts in diagnosing. So what happens when a shiny new EHR technology suddenly makes unreasonable demands on doctors’ time, but with limited tangible benefits? We start to interfere with meaningful patient interactions, and practice-wide productivity, in the name of compliance. Again, the right technology will help in the right way—and in our industry, I believe that means IT solutions that help doctors do more of what they do best: spend meaningful time with patients, and do it more efficiently and with better outcomes.

So if you want to know when I’ll consider getting a Tesla, the answer is when the proper infrastructure is in place to handle it. Until then, I’ll find the vehicle that best serves my needs today and in the foreseeable future. And if you’re looking for my advice regarding mobile phones, golf clubs, or EHR solutions, it’s exactly the same.


Tomorrow’s Technology

As a product manager in the healthcare information technology industry, I speak with customers, potential clients, partners, and competitors on a regular basis to identify emerging trends. For the most part, the feedback is actionable and concrete—there is a market need that is both urgent and pervasive, and, if solved correctly, will bring value to our customers. However, recently the topics on everyone’s minds are more abstract. They are monolithic concepts like “interoperability,” “big data,” “analytics,” “outcomes,” and my favorite: “population health management.”

Every year the research and advisory company Gartner releases a “Hype Cycle” for various industries. It plots the most-talked-about emerging technology trends on a continuum, and, based on historical track records, estimates how long before that technology becomes productive. Below is the continuum and what the stages actually mean. This year’s release includes three technology items that reflect the concepts mentioned above. According to Gartner, “Content Analytics,” “Big Data,” and “Mobile Health” are 5–10 years from becoming productive technologies that are widely embraced and, more importantly, bring value to customers.

Gartner-chartSource: Gartner, Inc.

At this point, some of you may be thinking, “I can’t wait for 5 years, I need these things today.” The good news is that many companies are racing to build, improve, or buy the technology to address all of these trends. Some already exist in the marketplace, and other new products or services will be launched in the near future. The bad news, as I see it, is that no one will get it just right on the first try. As with any other industry offering, we will see many iterations over the next few years. Each one will improve by using lessons learned from the last iteration. Ultimately, the market will decide which options add value to the practice and patient.

Although I am personally excited to see what the next few years bring, I do have a few words of caution for healthcare providers and practices who are looking to leverage these technologies. First, because these technologies are in their infancy, it is important that you provide frequent feedback to your partners. Let them know what works and what doesn’t. This will help them to develop the functionality that you value. Second, since all of these trends revolve around data, you must be willing to invest time in capturing it. If you don’t have it, you can’t analyze, exchange, or act on it.

I look forward to reading your comments and learning about your views.

How Do You Measure Success?

blog-tape-measureWhen we were kids, we had clearly defined measurements—from literally marking our physical growth each year by standing with our back to the wall, to earning grades, scoring goals, and more. While we couldn’t will ourselves to grow taller (no matter how hard some of us may have tried), we learned that we could work on the other metrics, and we learned the sense of satisfaction that comes with achieving measurable goals. That’s because we had leaders in life who taught us these things: principals, coaches, parents…

So what happened when we ventured out into the workplace? Unfortunately, many of us ended up working in companies where measurement was not built in to the management system. Perhaps it’s because, as adults, we no longer feel that sort of “supervision” is necessary. The fact is, however, that without defining what is most important to an organization—and then continually measuring the effectiveness of the ways we work together to achieve that objective—we simply cannot engage the minds and hearts of every individual on the team.

This is particularly true—and particularly crucial—in the world of healthcare, where the customers are people who are turning to physicians and medical staff for care that ranges from preventive through life saving. Leadership is critical to making sure that each patient gets the best your team has to offer, and every measurement should focus on that—including the measurement of vendors. The right vendors have put metrics in place to measure how well they help you achieve your goals.

That’s my leadership philosophy at work and in life. After all, it seems like if things don’t get measured, they don’t get done the right way, and you certainly can’t fix something if you don’t know that it’s broken. We’re all so busy that it’s easy to get distracted by “squirrels”—things that dart into our paths, taking our attention off of what’s most important. But taking the time to evaluate what your company can do for maximum customer satisfaction, putting metrics in place to ensure that everyone on the team knows how they can help achieve those goals, and regularly reviewing results to see how you’re doing—that’s probably the biggest value a leader can impart to an organization.

Perhaps it’s time to put some new metrics in place in your business to ensure that you’re providing the best service possible—and you can draw from industry analysis, staff, clients and vendors—to determine what those metrics should be. Because it’s human nature: we all want to know how we’re measuring up!


Kudos to CMS for MU 2014 Proposed Rule

Doctors clappingYou can hear the sigh of relief—albeit mixed with a bit of uncertainty-driven anxiety—as physicians await publication of the final rule that will modify meaningful use in 2014. By relaxing the timeline, the government has finally acknowledged what so many stakeholders have been arguing for a while: Stage 2 and upgrading to a 2014 Certified EHR simply required too much of providers, too quickly. The paltry number of Stage 2 attestations to date is evidence enough—by May, only 50 physicians had attested to Stage 2; by June, just 447 had succeeded; and by July (mid-way into the year), the number had reached only 972. To put these numbers in context, over 378,000 providers have earned EHR incentives for Stage 1.

The major challenges that prompted the government’s reconsideration of the meaningful use timeline are reflected in the 1,184 comments submitted to CMS—some of which express frustration with the demands of the program in general, but almost all of which wholeheartedly support the proposed changes. (My comments, submitted on behalf of SRS physicians, are available here.) The following are the most common challenges cited:

  • Availability of 2014 Certified EHR Technology (CEHRT) – But it’s not just about the products that are not yet certified or about vendors with insufficient resources to keep up with the demand for implementations. Many of the products that have been certified were rushed out under overly aggressive and unrealistic timeframes, which has left physicians faced with not-ready-for-primetime software.
  • Overestimation of market readiness for interoperability – Sufficient infrastructure is not in place yet, so even physicians who have implemented the DIRECT messaging capability cannot find enough “trading partners” with whom they can connect to share information.
  • Dependence on non-participating parties – It takes an extraordinary amount of effort to successfully coordinate with labs, radiology providers, long-term care facilities, and registries, who are not required to conform to standards promulgated under meaningful use.
  • Reluctance of patients to embrace portal utilization – The two portal measures (patients accessing clinical information and sending messages to physicians) are cited by many commenters as the major obstacle to MU success. Changing patient behavior in this regard is turning out to be even harder to accomplish than previously anticipated.
  • Excessive workflow challenges – Meaningful use necessitates operational changes to practice workflows that are, in the words of one commenter, “daunting, at best.”

The options proposed in the rule are summarized in a handy CMS Decision Tool and include reporting Stage 1 again, instead of Stage 2, and attesting using either a 2011 or 2014 CEHRT.

So what can physicians expect and what would be a good strategy to pursue as they wait for the final rule? CMS is promising—or at least hoping—to publish the final rule in early September. The 60-day comment period ended on July 21, and CMS is obligated to read and consider all of the comments before issuing the final rule. However, I think it is reasonable for physicians to assume that the final rule will be at least as flexible as the proposed rule—maybe even more so. CMS has been asked by many commenters to definitively spell out the conditions under which physicians could avail themselves of the various reporting options, which would address the uncertainty created by the lack of clarity in the proposed rule.

In the meantime, physicians should plan to attest for any quarter during which they have met all of the requirements under one of the options provided for in the proposed rule. It can even be a quarter that precedes the publication of the final rule. They should then aggressively turn their attention to upgrading to 2014 CEHRT—if they have not done so already—and to preparing for Stage 2. Remember: as flexible as the rule may be, it only offers a 3-month reprieve. Physicians who were to be at Stage 2 in 2014 must now be ready to start a full year of reporting on Stage 2, using a 2014 CEHRT, on January 1, 2015.