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Wednesday, August 22, 2012

2012 Meaningful Use Year One Attestation deadline draws nigh

Table 1
Failing to meet a 2012 90-day year one attestation will cost you $5,000 per EP, 60% of which will come out of your 2013 check.


My iMovie entry.

Short and to the allusive point. No Talking Head or v/o. The music is a royalty-free GarageBand loop from my GarageBand library.

Shot that on my kitchen counter the other day with my iPhone. No need to drag out the heavy artillery (my Sony alpha 500 DSLR).


My submission was rejected out of hand as "ineligible." "Not specific enough regarding PHR benefits."

Well, that was quick. Submission deadline is the 23rd. They have all of 19 submissions to date, as of the night before.


UPDATE UPDATE: total final deadline submissions, 29. Some pretty good ones in there.


One quick non-geek nominal analogy I thought of.

i.e., one clinic "speaks" eCW to an e-MDs clinic, which then relays the translated information on to a specialist whose EMR "speaks" Primesuite... etc, etc, etc. Should every datum in the transmitted PHI be amenable to HL7 I/O unmodified, no problem.

In theory. I would think extensive 360-degree testing is warranted. I'm sure there have to be people out there doing this sort of thing for "authentication / data integrity" compliance.


The definition of "Quixotic," I suppose.

Data "are." OED can kiss off. Almost no one says "you're welcome" anymore, either (instead, it's "Thank YOU").

Pedantic Curmudgeon.

Yeah, I went over to The Dark Side finally. @BobbyGvegas. Not sure about that whole thing yet, but you do get some good breaking HIT news, and a ton of HIT and other health care related companies and individuals using it. "Social Media Marketing" and all that.


Uh, OK...

Compliance Guidelines for Financial Institutions in the Healthcare Sector:

Executive Summary
The recent passage of the Health Information Technology for Economic and Clinical Health Act (HITECH) directly affects financial institutions and their services for the healthcare sector. HITECH modifies and amplifies the existing data privacy and security rules for protected healthcare information under the Health Insurance Portability and Accountability Act (HIPAA). There are new breach reporting requirements and tougher penalties. Financial institutions may find they must be able to meet the HIPAA data privacy and security measures if they deliver services to the healthcare sector...

Another 67 pages of HIMSS light bedtime reading (pdf).

In other news...
HIStalk Advisory Panel: IT in Patient Harm, Patient Outcomes

The HIStalk Advisory Panel is a group of hospital CIOs, hospital CMIOs, practicing physicians, and a few vendor executives who have volunteered to provide their thoughts on topical industry issues. I’ll seek their input every month or so on an important news developments and also ask the non-vendor members about their recent experience with vendors. E-mail me to suggest an issue for their consideration.

If you work for a provider organization (hospital, practice, etc.), you are welcome to join the panel. I am grateful to the HIStalk Advisory Panel members for their help in making HIStalk better.

What are the biggest lessons we’ve learned from cases where IT contributed to patient harm?

Common Themes Expressed

  • System redundancy is sometimes poorly planned.
  • Systems and system changes (especially those involving upgrades and application setup) are not adequately tested.
  • IT systems management needs to be more formalized (change management, communication, quality assurance).
  • System design should be user-centered and should make it easy for clinicians to do the right thing.
  • User application training needs to be not only more comprehensive, but also tied to the workflow and job role changes that are involved.
  • Clinicians are not represented in the IT governance process for changes that are seen by IT as purely infrastructure related.
  • Clinicians need to take ownership of workflow analysis and get involved in IT projects that affect them and their patients.
  • IT is specifically related to patient harm or patient safety – it’s an enabler of management and processes, whether good or bad. Technology is not a panacea.
  • Clinicians can’t let the computer override their critical thinking, yet computer systems encourage them to.

Which hospital uses of IT have driven the biggest improvement in patient outcomes?

Common Themes Expressed

  • Hospitals need to define their quality goals, track their baseline quality, and then go after improvements.
  • Real-time alerts and notifications can affect patient outcomes dramatically.
  • Population health analytics can drive some of the biggest improvements beyond systems that just affect inpatient stays.
  • Well-defined and closed areas have the most impressive IT-driven improvements: ED, pharmacy, and OR.
  • Pharmacy-related IT has driven major patient care improvements: electronic medication administration record, barcode checking of drugs at the bedside, alerts for drug-drug interactions and other patient-specific problems.
  • Telemedicine makes it possible to use hard to find expertise more broadly.
  • PACS has dramatically changed how clinicians use diagnostic images and how radiologists work.
  • Data analysis can pinpoint areas of potential improvement and allow ongoing monitoring.
  • Technologies, even simple ones, that allow clinicians to communicate more effectively can have a significant patient impact.

A lot to think about here.


1,146 pages total (474 and 672 pages respectively). Just started combing through them (yeah, cool and all, but, what I really want to see is the HIPAA Omnibus Final Rule).

Took up a 4" 3-ring binder (2-sided printing).

How to Play by the (Final) Rules:
An Overview of Meaningful Use Stage 2 & the Standards and Certification Criteria Final Rules
Aug 24th, 1:00-2:30pm EDT

After months of speculation, the final rules for Meaningful Use Stage 2 and the Standards and Certification Criteria have been released. Friday, August 24 at 1 pm EDT, NeHC will host experts on both of these rules for a single webinar to walk through the intricacies and answer questions on each rule. First, NeHC will be joined by Rob Anthony from CMS’s Office of E-Health Standards and Services to give an overview of the final rule and answer attendee questions. Rob will also discuss the feedback that was incorporated into the final rule and what this means for those ready to attest for both Stage 1 and Stage 2. Then, NeHC will once again welcome Steve Posnack, Director of the Federal Policy Division at the Office of the National Coordinator for Health IT (ONC) to join us for an in-depth look at the 2014 Edition Standards and Certification Criteria final rule. Steve will discuss the revised definition for Certified EHR Technology, identify changes from the proposed rule, and give his insight into the next steps.

If you cannot attend Friday's program, NeHC will be repeating this program next week. Please watch your email for updates on upcoming dates and times of the repeat webinars.

Rob Anthony - Office of eHealth Standards and Services, CMS
Steve Posnack - Director of the Federal Policy Division, ONC

Registration required*
Fee: No Fee

Should be interesting. We'll be attending.

apropos of Stage 2 and the concomitant EHR re-cert requirements, I screen-scraped some data off a CMS page today and dropped them into Excel and cleaned them up a tad:

Table 2
Addressing just the Medicare EP side for a moment: Had you been sufficiently adroit to have attested in 2011, you will now get to glide through Stage 1 through 2013 (assuming effective ongoing MU dashboard vigilance), at the end of which time you will have been eligible for 86.4% of the total $44k incentive reimbursement potential (the max amount contingent, of course, on your annual allowable Part-B claims). You will then have to upgrade to a Stage 2 certified system and amend your workflows to comply with Stage 2 criteria to collect the remaining relatively net piddly $6k ($4k in 2014 and $2k in 2015). Then, in 2016, you'd be starting Stage 3 -- for no ensuing incentive money (and, you can be sure the vendors will charge you for both upgrades).

If you're attesting in 2012, your upslope path is even more challenging; your 5th year of participation puts you in Stage 3 in 2016. You're gonna pay for two upgrades and do two workflow/training revisions.

If you miss 2012, and have to start attestation in 2013 (a real possibility for some of the more unruly clients on my personal caseload), well, the case for even doing it gets even more difficult (see Table 1 at the top of this post).

Moreover, absent some sort of renewed funding sources, RECs are effectively finished this time next year, So, all Brave REC Supportive Talk aside, you're gonna be on your own, or paying fee-for-service (which, again, begs the ROI question, given a much bandied-about price point of ~$125/hr).

ONC is paying lip service to REC support, but that's about the extent of it, as far as I can determine. But, in fairness, it's not a propitious time to be going to the Hill or to the administration groveling for more REC money. Moreover, should we have a change in the White House this November (a real possibility, IMO), all bets will be off -- "bipartisan support for HIT" kumbaya talk notwithstanding.

No subsequent news. No web content. No blog. No LinkedIn content. No Facebook. No Twitter. Nada, Zip, Zilch. I guess the "Trade Association" strategy here escapes me. I would have had all of that stuff and more tee'd up on Day One. Prior to Day One, actually. It's.Not.That.Difficult.

Don't let any mold accrue on your CVs.

Health Care: An Alternate Economic Universe
(Jeff Goldsmith, props to TCHB)

...Health care in the US is changing, and becoming more disciplined, team-based and protocol driven. However, the culture of the US health system has changed yet very little. The primordial impulse is to add more (and more expensive) workers whenever new problems need to be solved or new technologies appear, heedless of the expense.
Hospital executives continue speaking wistfully and inaccurately of “reimbursement” as the source of their revenues. This retro word conveys the distinct subtext that they have no responsibility for the cost of their product, that money has been spent, and someone owes them “reimbursement” for it. The proper term is “payment”, and the operative societal question is “are we receiving value for money?” in that payment.
 However, most of the new payment models under intense scrutiny — from accountable care, to bundled payment, to “ambulatory intensive care” for dual eligibles, etc. — only pay off if they markedly reduce, particularly, hospital use. Despite a (slowly) aging population and (hopefully) better access through health reform, the trend line for use of our most expensive health resources will likely turn downward as we reduce avoidable use of our system’s most expensive resources.

An Unsustainable Status Quo

But the cost of health care that remains is still far too high to be affordable long term. Those costs will only be reduced by better coordinated care, and by marked improvements in clinical and organizational productivity, a revolution these data suggest has yet to begin. The supply side of the US health care system remains impressively insulated from cost pressure, and focused on the myriad challenges of growth and revenue enhancement.
At some point on the path to deficit reduction, gravitational forces will assert themselves. Policymakers can assist in that process by re-examining the economic logic of the transactional density and documentation burden they are imposing on caregivers. We will know that economic pressure on the health system has reached a decisive juncture when health sector employment stabilizes or reverses course, and health care providers join the rest of the economy in seeking improved productivity and product quality as necessary strategies to survive.

Ya think? That's Toussaint 101, is it not? (See Potent Medicine and On The Mend.)


Click images to enlarge.

More to come...

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