Beyond Meaningful Use Lies a Game Changer for Specialists

 Beyond Meaningful Use Lies a Game Changer for SpecialistsI have frequently said that meaningful use is a primary-care program, and I still maintain that it was designed with primary-care physicians and their patients in mind. But I believe that specialists will be the greatest beneficiaries of Stage 2’s shift in focus to interoperability. If EHR vendors expand upon the groundwork laid by meaningful use, they will provide physicians with not only a reliable way to get information about their patients’ clinical history, but also an efficient way to reconcile that information and incorporate it into their charts.

As increasing amounts of discrete clinical data is shared between physicians—Stage 2 adds new elements to the Stage 1 required data set—many physicians will find themselves subject to significant workflow disruptions as they struggle to incorporate all of this data into their patient charts. The workflow impact is clearly greatest when the physician sees a new patient, so specialists—for whom new patients typically constitute 25–35% of their office visits—will feel the impact more intensely than primary-care physicians, who may see only a few new patients a week.

How does the physician get this data into the patients’ chart, and where should the data come from? While patients are a good source of demographic data, the primary-care physician is the best source of an authoritative and vetted record of the patient’s health history. Stage 2 of meaningful use creates standards that facilitate the transport of this clinical data from the primary-care physician to the specialist via the “Direct” messaging protocol—a secure e-mail-like exchange process. The data is sent in a standard format called the CCDA (Consolidated Clinical Document Architecture). But this is where meaningful use ends, leaving it up to the recipient of the data to incorporate it into the patient’s digital chart, and this can be time-consuming and disruptive to workflow if the process is not automated.

For physicians, having the tools to accomplish these tasks in an efficient, productivity-focused manner will be a veritable game changer. It will not be sufficient for an EHR to merely display the data from the primary-care physician. Rather, it will be critical for vendors to provide physicians with an efficient means of reconciling this data and automating the process of entering the approved discrete clinical data elements into the patients’ charts. The key for EHR vendors will be to go above and beyond the requirements specified by meaningful use.

My Thoughts on the New York Times Article

My Thoughts on the New York Times ArticleI woke up Tuesday morning excited to see a lead story about EHRs in the New York Times. I had expected to read about the impact that meaningful use is having on the EHR industry and the practice of medicine, because that was the subject of the 45-minute interview I had with the author 3 weeks ago. Instead, I was rather surprised to see the article’s title: “A Digital Shift on Health Data Swells Profits in an Industry.

The article focused on the politics behind the funding of the EHR Incentives Program— aka “meaningful use”—which is a very important story but one that was already covered in 2009 in a Washington Post expose titled “The Machinery Behind Health-Care Reform: How an Industry Lobby Scored a Swift, Unexpected Victory by Channeling Billions to Electronic Records.” (For more information, see my EMR Straight Talk post on that article.)

The New York Times article went on to castigate EHRs with the following statement, backed up by a quote from a physician:

. . .these systems also have many critics, who contend that they can be difficult to use, cannot share patient information with other systems and are sometimes adding hours to the time physicians spend documenting patient care.

“On a really good day, you might be able to call the system mediocre, but most of the time, it’s lousy.”

The online version of the article had 495 highly charged negative comments, which are worth perusing to understand the current sentiment among physicians.

I have not been shy about expressing my concerns about the effect of the typical point-and-click EHR on physician productivity, and about the sapping of innovation brought about by the complexities of the meaningful use regulations. However, I do see a silver lining in the meaningful use cloud, and that is the establishment of standards that are already having profound and positive effects on interoperability. In my interview with the author, we talked at length about the problems of EHR-siloed information and the benefits that certification will bring to the sharing of clinical data among providers, HIEs, and patients. Painful and costly as the certification process has been for EHR vendors, this standardization is advancing the industry and addressing many of the concerns expressed in the comments.

I hope that the New York Times will consider future stories about the progress being made towards EHR interoperability and about the differences among EHRs that distinguish the physicians who are reaping the benefits of their EHRs from those who are suffering from the negative impact of theirs.

EHR Vendors on Meaningful Use: Enough is Enough!

EHR Vendors on Meaningful Use: Enough is Enough!Physicians, professional societies, and EHR vendors are now aligned against the complexity and pace of the meaningful use program. In my last two EMR Straight Talk posts, I shared my concerns about the future of the meaningful use program. My letter to Farzad Mostashari relayed the rampant dissatisfaction expressed by physicians about the program’s complexity, the government’s unrealistic expectations, and the impact on physician productivity. In my last post, Physicians Are Crying “Uncle!”, I discussed how physicians and the professional societies that represent them are demanding that the runaway meaningful use train be slowed. Of paramount concern to physicians is the fact that the EHR usability they crave is being sacrificed in the pursuit of certification.

EHR vendors collectively expressed their concerns in a comment letter from the HIMSS EHRA (Electronic Health Record Association) to the HIT Policy Committee about the initial proposal for Stage 3, and their message was in synch with that of the physicians and their societies. The vendors focused on the government’s interference with their ability to innovate, and they expressed their frustration over being unable to creatively address the needs and demands of physicians for new capabilities:

The needs of such experienced and often sophisticated [physician] users will best be met by market innovation, while extensive and detailed standardized requirements dictated by the federal government are not only unnecessary but may actually interfere with the pace and direction of needed innovations.

Vendors advocate, as I do, for the government to limit its focus to overarching issues like ensuring interoperability, and they argue against the government simply piling on more new measures. The opportunity to innovate is being thwarted by government programs that force vendors to devote all available resources to an ongoing chase after continually changing certification requirements.

Rarely do we see such close alignment between physicians and vendors on any matter. If CMS and ONC continue plowing ahead, ignoring the pleas of these major stakeholders, history will deem them to have been woefully negligent stewards of a program that started out with such laudable goals.

Physicians Cry “Uncle” Over Meaningful Use

Physicians Cry 'Uncle' over Meaningful UseThe increasingly unrealistic demands of meaningful use are leading to a groundswell of resistance. While 96,000 physicians have demonstrated meaningful use and earned EHR incentives, the majority did so while complaining about the negative impact that the Stage 1 “minimal” set of requirements had on their practice workflows. (See the results of a physician survey and read physicians’ comments in my last EMR Straight Talk post.) As Stage 2 approaches, those who have previewed the increasingly complex and demanding requirements are consumed by trepidation. Many are already considering abandoning meaningful use after they collect their $30,000 for Stage 1. Despite the fact that no one has yet had experience with the Stage 2 requirements, the Stage 3 proposal from the HIT Policy Committee is already out for public comment. Physicians and the professional organizations that represent them—already close to the breaking point—are crying “Uncle!”

The following is only a partial list of organizations that have commented: the American Medical Association, American Academy of Family Practice, College of Healthcare Information Management Executives, American College of Physicians, and the American Hospital Association. You can read their comments by googling the organization name and “Stage 3 comments” or “Letter to Mostashari.”

Although they phrase it in slightly different ways, all of these organizations are pleading with the powers that be to slow down what is perceived as a runaway train. Their comments center around several problems: lack of EHR usability, unrealistic and excessively complex requirements, the undue speed with which they are being imposed, and a lack of evidence of the program’s success. Physicians see the program as a massive data collection and reporting project with no proven quality improvement outcomes attached to it. Unless the government pays heed to the concerns and recommendations being voiced, the EHR incentive program is doomed to failure. Physicians will simply toss in the towel.

The following is a description of the most common sentiments expressed in the letters and formal comments:

  • Stage 3 should not even be considered until the experience of Stages 1 and 2 can be evaluated to see what was actually accomplished and what the cost is to physicians. Many are calling for an independent assessment of the program. It is not sufficient to merely gloat about how successful the successful meaningful users were—an analysis must be conducted to investigate why other physicians were either not successful or chose not to even attempt to achieve meaningful use.
  • In addition, Stage 3 should not occur until at least 3 years after Stage 2, giving physicians and vendors sufficient time to move forward.
  • EHR usability is identified as a major issue in every set of comments. EHR de-installs are increasing in number as physicians abandon legacy systems. The impact of a lack of usability is compounded when physicians attempt to use an already challenging system to meet an overwhelmingly challenging set of requirements. When workflow is negatively affected, the costs to physicians can quickly exceed the benefits.
  • The AMA suggests that the government conduct user-satisfaction surveys—by practice type, size, and specialty—and incorporate the results into the certification requirements going forward.
  • Meaningful use remains a primary-care program that, despite the addition of a few specialist-focused measures, does not adequately recognize specialists’ unique workflows. They resent being asked to report on measures that have minimal, if any, value to their practices.
  • As the requirements become increasingly complex, it may be time to modify the “all or nothing” approach, and reward physicians for reasonable levels of success. Penalties should be eliminated, or at a minimum, significantly delayed.

Don’t sit back and wait for the Stage 3 rules to be finalized. Express your opinions either by writing to your professional organization or directly to Dr. Farzad Mostashari. It is critical to keep up the pressure on the decision makers.

Meaningful Use Stage 2: Did CMS Hear the Physicians? (Part 2)

Meaningful Use Stage 2: Did CMS Hear the Physicians? (Part 2)’ TimeIn my last post, I commended CMS for responding positively to many of the comments that were submitted regarding the Proposed Rule for Stage 2 of meaningful use. However, there were also troublesome areas that were acknowledged in the Final Rule, but addressed in a way that remains problematic for physicians. This post will review some of those issues.

Most notable are the two measures that make physicians’ incentives dependent on actions by patients—actions over which the physician does not have control. The Final Rule requires that:

  • More than 5% of all patients seen by the physician during the reporting period actually view, download, or transmit their available health information, and
  • More than 5% of patients seen send a secure message to the physician (containing health information, not just a request for an appointment).

The proposed rule had set the threshold at 10% for each of these measures. The response from the provider community was almost universal, arguing that no matter how much education, encouragement, and cajoling the practice provides to encourage this form of patient engagement, the physicians could not guarantee patient compliance. Alternatives were offered—my company suggested having the physician be the source of the messages, or holding him/her responsible for responding to a minimum percent of the messages received from patients. However, CMS held firm in its belief that it is incumbent upon the physician to encourage patients by offering an attractive, patient-friendly portal. By way of compromise, the Final Rule reduced the threshold from 10% to 5%, but this solution does not address the principle involved—i.e., the inequity of making the physician’s incentive dependent on the actions of patients. Just imagine if after successfully meeting all of the Stage 2 requirements for the 1,000 patients a physician saw during the reporting period, only 49 of the patients (instead of 50) actually viewed their information on the portal that the physician installed—his entire year’s incentive payment would be lost.

The menu set of measures is intended to afford physicians some flexibility—there are 6 measures from which they must select 3. Part of the rationale for this structure is to make meaningful use more meaningful for specialists. Yet in Stage 2, the menu measures that a physician is eligible to exclude will no longer count as being met, so many specialists will be left with no real choices at all—the menu measures become de facto core measures. Many specialists will find 3, or even 4, of the menu measures to be in that category—CMS acknowledges that syndromic surveillance is still premature, cancer registry reporting is likely irrelevant to most physicians, diagnostic images are only relevant to a few specialties, and many others will find no viable specialty registry to which to report so CMS “does not expect every EP to select this measure.” An ophthalmologist, for example, will have to report on the family history measure and the electronic progress note—not a measure they would choose if the menu were truly a menu.

Patient reminders is another measure that may be problematic for specialists who provide episodic care. Stage 2 requires the physician to send an appropriate reminder for follow-up or preventive care to 10% of the patients seen during the prior 24 months. No exclusion is available for physicians who see patients two or three times to treat a particular problem, but have no reason to ever recall the patient.

The above are examples of where CMS may have listened to the physicians, but didn’t really hear them. I hope that some further guidance related to these issues will be forthcoming to ensure that physicians are able to successfully demonstrate meaningful use in Stage 2.

Meaningful Use Stage 2: Did CMS Hear the Physicians?

Meaningful Use Stage 2: Did CMS Hear the Physicians?’ TimeKudos to CMS for responding positively and reasonably to many of the comments submitted by physicians and/or their professional organizations regarding the Proposed Rule for Stage 2 meaningful use. Of course, there were also a number of issues that could have been addressed more favorably from the providers’ perspective—and I will address those in my next EMR Straight Talk post—but I was pleasantly surprised to see the changes and the compromises that CMS did make that will benefit physicians.

The most significant concession was related to timing: in 2014, physicians will only report for a 90-day calendar quarter—rather than a full year, as originally intended. This should result in higher-quality, more-usable EHRs as vendors will have more time to develop, test, and certify their new versions. It also eliminates the fiasco that surely would have ensued for providers were they all to require upgrading by their vendors within a very small window of time. This new schedule also ensures that physicians will have the time they need to implement, and sufficiently train on, the new versions of their software, enhancing the likelihood that they will be able to successfully demonstrate meaningful use. The 90-day reporting period also provides some flexibility for those unfortunate physicians who hastily purchased an EHR in a rush to meet meaningful use and now find themselves dissatisfied with their decision—they will have down time that will make the replacement process easier.

I was also pleased to see several changes that address the reporting burden for physicians. Stage 2 offers a batch-reporting option—however, providers must still individually meet all of the meaningful use requirements—and it attempts to harmonize clinical quality measure reporting across the various government programs. These were two proposed concepts that physicians strongly endorsed in their comments.

Specialists particularly appreciate the Final Rule’s successful resolution to the challenges posed by the vital-signs measure currently in force—the new requirement unlinks the reporting of height and weight from the reporting of blood pressure. Beginning in 2013 (i.e., a year before Stage 2 even takes effect), physicians who find height and weight relevant to their practices (but not blood pressure) will be able to report the former while attesting to an exclusion for the latter. This will remove an irrelevant step in the workflow for many specialists.

While CMS did hear the physicians on these important issues, there are other areas that the Final Rule did not sufficiently address. I will discuss these in my next post.

The Future of Meaningful Use

The Future of Meaningful Use
This week, I came upon two blog posts that I thought were interesting in light of my last EMR Straight Talk post, which suggested that EHR adoption was being driven to the tipping point by the meaningful use incentives. Increasing numbers of physicians—many of whom were initially motivated by the government’s incentives—are beginning to question the real value of complying with the program’s ever-more-demanding requirements. Whether or not meaningful use thrives as the program progresses will ultimately be determined by the physician market, but sentiment is clearly mounting that too much is being demanded.

In a recent post on the venerable HIStalk blog, Dr. Jayne reminds physicians of why they went into medicine, and she challenges the government to justify new requirements by “providing concrete evidence that jumping through the hoops you’re holding in front of us will actually help patients in a truly meaningful way.” Analyzing the trade-off between the incentives and productivity, she worries about not only the impact on physician income, but also the impact on the number of patients who can receive care. I particularly appreciated her conclusion that what we should be seeking is “evidence-based Meaningful Use.”

An editorial published on the AMA’s American Medical News website, titled “Meaningful Use’s Stage 2: A Recipe for Failure,” highlights the AMA’s concerns about the Proposed Rule, concluding that the requirements are simply “too demanding” and will turn physicians into cynics, rather than participants in the EHR program.