2014 Is a Big Year for EHRs
Practice Management Feature — December 2013
Tex Med. 2013;109(12):45-49.
By Crystal Zuzek
If you're participating in Stage 1 or Stage 2 of the Medicare electronic health record (EHR) incentive program, circle Oct. 1, 2014, on your calendar. That's the cutoff date for ensuring you've upgraded your EHRs to meet Stage 2 product certification requirements. If it's your first time to attest to meaningful use, you must begin the 90-day EHR reporting period by July 1, 2014, to meet the Oct. 1 deadline and avoid a future penalty.
The software upgrade mandated by the U.S. Department of Health and Human Services (HHS) Office of the National Coordinator for Health Information Technology (ONC) requires you to collaborate with your EHR vendors. You'll also need time to test the system and train your staff on how to use it. Physicians who've gone through it already say you should plan for a temporary dip in productivity during the upgrade process.
Allen Schultz, MD, an Abilene family physician, will attest to Stage 2 meaningful use next year. The second stage of measures in the Medicare EHR incentive program requires physicians, hospitals, and labs to use their EHRs to deliver collaborative patient care. That means EHRs must be able to communicate with each other to share patient data. The common language EHRs must speak in Stage 2 is known as Systematized Nomenclature of Medicine Clinical Terms (SNOMED-CT).
Dr. Schultz, a member of the Texas Medical Association's Ad Hoc Committee on Health Information Technology (HIT), implemented SNOMED-CT in his EHR system in September. He spent 12 hours in one weekend converting to SNOMED-CT, and he still had 180 patient charts to review to ensure accurate SNOMED-CT diagnoses.
"I anticipate that the Stage 2 measures will decrease my efficiency. Now I describe my diagnosis in terms that match a SNOMED-CT set. This is teaching an old dog yet another set of tricks," Dr. Schultz said.
He encourages physicians to ask their EHR vendors now how they'll incorporate SNOMED-CT into the patients' family, social, and past medical histories. He says the SNOMED-CT implementation is among the "largest stumbling blocks" to achieving Stage 2 meaningful use.
Plainview family physician Sidney Ontai, MD, another member of TMA's ad hoc committee, says EHR upgrades inevitably cause system crashes and glitches in features physicians commonly use.
"Our last upgrade really affected the software's performance on prescription writing, so everyone's productivity took about a 5-percent hit for several months," he said.
Despite the short-term loss of productivity, achieving meaningful use does have the potential to improve care, Dr. Ontai says.
"Better quality of care is possible with careful selection of indicators and close work with staff and providers so that the indicators are indeed meaningful and do not negatively impact workflow," he said.
EHR Vendors Prepare
Some EHR vendors already have released Stage 2-certified versions of their products. Check the online certified health product list (CHPL) to see if your vendor is one of them. Certification ensures the product has all the necessary capabilities and security components required to successfully attest to meaningful use.
During attestation, the Centers for Medicare & Medicaid Services (CMS) requires you to list the EHR Certification ID for the EHR technology you use to demonstrate meaningful use. To obtain the certification ID for a product, consult instructions for using the CHPL website. A Stage 2-certified product is required for all physicians attesting in 2014, regardless of the participation year. Physicians attesting to Stage 1 meaningful use need the Stage 2-certified EHR in 2014.
For assistance with the EHR incentive program, you can turn to one of four Texas regional extension centers (RECs). The RECs can help you navigate the complexities of the program. Check out TMA's REC Resource Center for REC service area information.
A Modern Healthcare review of the CHPL indicates that at press time just 79 companies and other organizations had developed, tested, and certified software that meets Stage 2 meaningful use functionality standards. Compare that number with the 988 developers of HIT systems tested and certified for Stage 1, and experts worry some physician practices could get left in the dust and could face payment penalties down the road.
According to Modern Healthcare, EHR vendors are struggling to develop systems that can calculate measures physicians must report to CMS under Stage 2.
Lawmakers are trying to buy physicians and vendors more time to comply with Stage 2. In September, 17 U.S. Senate Republicans, led by Sen. John Thune (R-S.D.) and Sen. Lamar Alexander (R-Tenn.), asked HHS Secretary Kathleen Sebelius for a one-year delay. Their letter says aggressive deadlines in Stage 2 may widen the digital divide for small and rural practices and could have other unintended consequences, such as stifling innovation and increasing medical errors.
The American Medical Association, the American Hospital Association, the National Rural Health Association, the College of Healthcare Information Management Executives, the Medical Group Management Association, the American College of Physicians, and the Tennessee Medical Association support the request. At press time, the federal government hadn't granted a delay.
If you haven't become a meaningful user by 2015, you'll be subject to a 1-percent cut in Medicare payments beginning that year. The penalties increase to 2 percent by 2016 and 3 percent by 2017. HHS may continue to decrease Medicare payments 1 percent per year up to 5 percent if 75 percent of office-based physicians do not achieve meaningful use by 2018.
Pamela Chapman, e-MDs director of clinical product and regulatory affairs, says the biggest challenge in preparing for Stage 2 from an EHR vendor's perspective is ensuring that meaningful use data collection doesn't affect physician workflow.
"For instance, we've made changes to the way physicians document patient immunization information. We've tied that documentation into clinical decision support so all of the information is incorporated into the workflow for physician users," she said.
At press time, e-MDs planned to have its EHR product certified and listed on the CHPL by the end of October. e-MDs is helping physician-users prepare to meet meaningful use Stage 2 requirements by offering webinars and online training modules. Physician clients of e-MDs will start receiving their software upgrade in mid-December, according to Ms. Chapman.
Contact your EHR vendor to find out when you'll receive the upgraded software and to ensure you'll have enough time to test the system.
TMA Weighs In
CMS adopted Stage 2 EHR meaningful use rules last summer and increased the measures physicians must achieve to earn incentives in Stage 2. For example, Stage 1 requires physicians to give patients their clinical summaries in three days. In Stage 2, physicians have only one day. (See "Medicare and Medicaid Incentives.")
To qualify for the Stage 2 incentives, physicians must meet 17 core objectives and three menu objectives. To read the Stage 2 meaningful use final rule, a table comparing Stage 1 and Stage 2 objectives, a complete list of the Stage 2 core and menu measures for physicians, and a Stage 2 timeline, visit the CMS website.
Before CMS adopted the final rules, TMA sent a 14-page comment letter with suggestions to improve the proposed Stage 2 rules. The association recommended CMS allow physicians to meet only 90 days of meaningful use during the 2014 transition, and the agency heeded TMA's advice. The final rule allows physicians to meet the reduced reporting period because of the time it will take EHR vendors to meet the new certification requirements.
The EHR certification rules complement the CMS meaningful use Stage 2 rules. The ONC fact sheet on standards, implementation specifications, and certification criteria for EHR technology is available online.
TMA submitted an 11-page comment letter to ONC on its proposed EHR technology standards and certification rules last May. The letter, signed by Joseph Schneider, MD, chair of the TMA ad hoc HIT committee, expressed TMA's frustration over the federal government's inadequate response to the association's call to establish a robust mechanism for collecting and sharing problems with EHRs.
The CentrEast Regional Extension Center developed such a resource with its EHR Support Center. The online adverse event reporting tool gives physicians a place to submit EHR problems and to share techniques that improve EHR use. TMA encourages physicians to use the tool to report EHR problems.
To review TMA's advocacy efforts and read TMA's letter to federal officials, log on to www.texmed.org/EHRincentive/ and scroll down to Advocacy.
Crystal Zuzek can be reached by telephone at (800) 880-1300, ext. 1385, or (512) 370-1385; by fax at (512) 370-1629; or by email.
Medicare and Medicaid Incentives
Health care professionals in the Medicare incentive program can earn up to $44,000 over five years for meeting meaningful use criteria by 2016. Eligible Medicare physicians in a health professional shortage area can receive a 10-percent increase in incentives.
Eligible non-hospital-based physicians with at least 30-percent Medicaid patient volume can receive up to $63,750 over six years in incentive payments from 2011 to 2021. Eligible non-hospital-based pediatricians with at least 20-percent Medicaid patient volume could receive up to $42,500 during the same period.
For more information, visit the CMS electronic health record (EHR) incentive programs website and the TMA EHR Incentive Program Resource Center.
Additionally, the TMA EHR Implementation Guide, EHR Product Comparison Tool (TMA members only), Medicare and Medicaid EHR Incentive Comparison, EHR Incentive Eligibility Tool, and Medicare and Medicaid incentive program instructions are on the TMA HIT webpage.
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