Health IT Standards & Committees

In the last two blogs we talked about Meaningful Use and benefits of EHR adoption in these changing times.  In the coming years we will see lot more debate and discussion as IT becomes more integrated in terms of how medical care is delivered in the US.  That is where the role of Federal government comes in. Let us take a closer look at how Federal government is trying to shape the IT standards and protocols when it comes to practicing medicines at clinics and hospitals at facilities across the country.  The caveat for the reader is that it will be a high level view.  And, hopefully, the take away for the reader will be to a somewhat better understanding in terms of keeping track of federal and government initiatives in the months to come!

Understanding Health IT Policies & Committees

The American Recovery and Reinvestment Act of 2009 (ARRA) provided for the creation of an HIT Policy Committee under the auspices of the Federal Advisory Committee Act (FACA). The HIT Policy Committee is charged with making recommendations to the National Coordinator for Health IT on a policy framework for the development and adoption of a nationwide health information infrastructure, including standards for the exchange of patient medical information.

The HIT Policy Committee has several workgroups to further the work of the FACA Committee.  The HIT Policy Committee’s workgroups are: 

• Meaningful Use Workgroup
• Certification/Adoption Workgroup
• Information Exchange Workgroup
• NHIN Workgroup, Strategic Planning Workgroup
• Privacy & Security Policy Workgroup
• Enrollment Workgroup

 Details: http://healthit.hhs.gov/portal/server.pt/community/healthit_hhs_gov__health_it_policy_committee

Health IT Standards Committee: The American Recovery and Reinvestment Act of 2009 (ARRA) also provided for the creation of an HIT Standards Committee under the auspices of the FACA. The HIT Standards Committee is charged with making recommendations to the National Coordinator on standards, implementation specifications, and certification criteria for the electronic exchange and use of health information. The HIT Standards Committee will focus on the policies developed by the Health IT Policy Committee.  The HIT Standards Committee also includes several workgroups to further the work of the FACA. These workgroups are: Clinical Operations Workgroup, Clinical Quality Workgroup, Privacy & Security Workgroup, and Implementation Workgroup.

Details:http://healthit.hhs.gov/portal/server.pt/community/healthit_hhs_gov__health_it_standards_committee.

The Office of the National Coordinator for Health Information Technology (ONC) also supports the efforts of several related initiatives to facilitate nationwide adoption of health IT.  Such initiatives include:

• State-Level Health Initiatives: Initiatives designed to ensure that states and regional efforts to achieve health information exchange (HIE) are aligned with the national agenda. 
• Nationwide Health Information Network: A collection of standards, protocols, legal agreements, specifications, and services to enable secure HIE.
• Federal Health Architecture: An e-government line of business initiative to increase efficiency and effectiveness in all government operations.
• Adoption: An initiative supporting two national health IT adoption surveys: one of physician offices and one of hospitals.
• Clinical Decision Support & the CDS Collaboratory: An initiative to provide clinicians, staff, patients or other individuals with knowledge and person-specific information, intelligently filtered or presented at appropriate times, to enhance health and health care.

Needless to say, these organizations are meet regularly, organize events, forums, trade shows, etc., where lot of information is shared and disseminated. To track changing healthcare IT environment, it is perhaps critical for a technology vendor to be a part of such discussions and announcements.  

We suggest at least visiting the URL http://healthit.hhs.gov/portal on a regular basis (if attending and participating in related formus and events is not an option) to stay abreast as HITECH unfolds for the physician community!

EHR Debate: Meaningful Use and CCHIT Certification

Is the confusion finally over? 

 “Our recovery plan will invest in electronic health records and new technologies that will reduce errors, bring down costs, ensure privacy and save lives.”  President Obama, Address to Joint Session of Congress, February 2009

Yes, it is true that is when it all started.  After lot of discussions and just about a year and a half later, on July 13^th, U.S. Department of Health and Human Services Secretary Kathleen Sebelius made key announcements regarding Meaningful Use (MU) and Stimulus money. Though I will cover various aspects of MU in many subsequent posts, it is best to visit the URL  http://www.cms.gov for a comprehensive understanding.  (Warning: It is quite a read! So plan on spending few hours for few days to get most out of it!)

We may not completely agree on how the stimulus, E HR adoption and MU will all play out in the long term, but it is true that there is a new excitement (I may add, much needed!) in the EHR marketplace and physician community is busy trying to select an E HR vendor, put together an implementation plan and trying to be ready when time comes to collect Federal Stimulus dollars- all over the country.  Let us look at few facts:

-     As much as $27 billion has been committed in incentive payments over ten years.  Eligible Professionals (EP) may receive as much as $44,000 under Medicare and $63,750 under Medicaid.

-     Hospitals may receive millions of dollars for implementation and meaningful use of certified EHRs underm both Medicare and Medicaid as well.

-     The final rules divides the requirements into a “Core” group of requirements that must be met, plus an additional “Menu” of procedures from which providers may choose. 

-     Eligible professionals and hospitals must successfully demonstrate meaningful use of certified electronic health record technology every year they participate in the program(Medicare). Eligible professionals and hospitals may qualify for incentive payments for the adoption, implementation, upgrade or the demonstration of meaningful use in their first year of participation. They must successfully demonstrate meaningful use for the remaining years they participate in the program(Medicaid).

-     Proposed rules expect eligible professionals to meet 25 requirements in their use of EHRs. 20 of the objectives must be completed to qualify for an incentive payment. 15 are core objectives that are required, and the remaining 5 objectives may be chosen from the list of 10 menu set objectives.

-    For Hospitals, there are a total of 24 meaningful use objectives. 14 are core objectives that are required, and the remaining 5 objectives may be chosen from the list of 10 menu set objectives.

The criteria for meaningful use will be staged in three steps over the course of the next five years. Stage 1 sets the baseline for electronic data capture and information sharing. Stage 2 (est. 2013) and Stage 3 (est. 2015) will continue to expand on this baseline and be developed through future rule making.

There are detailed regulations with regards to penalties for not adopting EHRs.  For instance, Medicare payments may be reduced to 99% in 2015, and reduced further to 97% by 2017 for practices that have not implemented a certified EHR. Also, after 2015, incentive payments will end.

There will be many new bodies certifying E HRs in the months and years to come.  And, it is certain that CCHIT will be one of the certifying bodies. It is important to understand that CCHIT is not the same thing as Meaningful Use (MU).  MU can be understood best as a subset of CCHIT certification. 

Isn’t that a lot of information to digest? Though fair amount of regulations have been announced and finalized in the last few months, this will continue to be a dynamic environment. For one thing, E HR penetration in the clinical segment (especially smaller practices and solo practioners) remains quite low, and a higher adoption will breed new ideas and ways to practice medicine that no one has thought before. More to follow..

More reads. .

http://www.ofr.gov/OFRUpload/OFRData/2010-17207_PI.pdf 

 http://www.ofr.gov/OFRUpload/OFRData/2010-17210_PI.pdf 

EHR Debate: Meaningful Use and CCHIT Certification

Taking a Deeper Dive. . . 

This is the second post in our series of EHR and meaningful use.  First, few notable announcements and then some more powwow!

Two EHR Certifiers

The Office of the National Coordinator for Health Information Technology has named the Certification Commission for Health Information Technology (CCHIT) and the Drummond Group Inc. as the initial Authorized Testing and Certification bodies for the temporary electronic health records certification program.

-     Chicago-based CCHIT has long been associated with certification process. And, Driummond Group (TX) is a new company that has always wanted to be in this space. EHRs currently certified under previous CCHIT programs must now be recertified as supporting electronic health records meaningful use criteria under the temporary certification program that lasts until at least Jan. 1, 2012.  Now, vendors need to apply to CCHIT and Drummond Group to go through the testing and certification. For more information visit cchit.org and drummondgroup.com.

Let us talk about Stage 1 Objectives in this post as these will be critical to understand and implement EHR till 2013. Stage 2 kicks in 2013 and Stage 3 in 2015 - at least this is how the Final Rule stands today!   

What is Stage 1 Criteria?

·    15 Core Objectives – For benefits to kick in, Eligible User (EU) has to satisfy all 15 objectives

·    Menu set of 10 Objectives, i.e., EU to satisfy 5 of 10 from the menu set

15  Core Objectives

1.    CPOE – Computerized Physician Order Entry: At least one medication ordered via CPOE for >30 percent of unique patients seen with at least one medication on current medication list

2.    Drug-drug, Drug-Allergy Checking: CPOE drug-drug and drug-allergy checking features should be enabled

3.    Generate and Transmit Electronic Prescriptions:  >40 percent of all permissible medication orders (excluding controlled substance orders) are electronically prescribed

4.    Maintain up-to-date Problem/Diagnosis List: For >80 percent of unique patients seen (at least one structured entry, ICD-9-CM or SNOMED CT)

5.    Maintain Active Medication List: For >80 percent of unique patients seen (at least one structured entry)

6.    Maintain Active Medication Allergy List: For >80 percent of unique patients seen(at least one structured entry)

7.    Record Vital Signs: For >50 percent of unique patients ≥ 2 years old seen, record and chart changes in vital signs (as structured data): i. Height, weight, blood pressure; ii. Calculate & display BM, Plot and display growth chart, including BMI (patients 2-20 years old)

8.    Record Demographics: For >50 percent of unique patients seen, record demographics (as structured data):

i.   Gender; ii. Ethnicity, race (federal guidelines), preferred language; iii. Date of birth

9.    Record Smoking Status: For >50 percent of unique patients seen ≥ 13 years 

10. Report Quality Measures to CMS and the States: Report ambulatory quality measures — per data captured and calculated by the EHR — to CMS or the states for specified core and specialty measures

–      For 2011: attest to accuracy and completeness of aggregate numerator and denominator

–      For 2012 (and beyond): submit (at least one measure) electronically

11.  Implement Clinical Decision Support: Implement one rule (with high clinical priority for or relevant to the specialty of the EP) and track compliance

12. Provide Patients with Clinical Summary of Office Visits: Satisfy more than 50 percent of requests for a clinical summary of an office visit (via Personal Health Record (PHR), portal, other electronic media, or printed output) within 3 business days

13. Provide Patient with Electronic Copies of Health Information: Provide >50 percent of patients who request copies with electronic copies of their health information (lab test results, problem, medication, allergy lists) within 3 business days

14. Implement Capability to Exchange Key Clinical Information: Perform at least one test of the capability of the certified EHR system used by the EP to electronically exchange key clinical information (for example, problem list, med list, allergies, test results) with another EHR (not shared)

15. Implement Systems to Protect Patient Data: Conduct or update a security risk assessment per 45 CFR

Functional Requirements

1. Incorporate Test Results into EHR: Incorporate clinical laboratory test results into EHR as structured data

for >40 percent of all clinical lab tests ordered with positive/negative or numeric results

2. Medication Reconciliation: Performed at >50 percent of relevant encounters and transitions of care

3. Drug Formulary Checking: Drug-formulary check functionality is enabled (with access to at least one internal or external formulary for entire period)

4. Generate Patient Lists: Generate at least one list of the EP’s patients with a specific condition to use for quality improvement, reduction of disparities, and/or outreach Health Information Exchange (HIE) Requirements

5. HIE: Patients: Provide >10 percent of unique patients seen with electronic access (available on-demand at any time) to their health information (lab test results, problem, medication, allergy lists) within 4 business days of the 

information’s availability to the EP

6. Patient Follow-up/Preventive Care Reminders: Send reminders for preventive/follow-up care (per patient preference) to >20 percent of patients who are ≥65 or <5 years old

7. HIE: External Providers: Provide summary care record (via electronic exchange, secure portal, secure e-mail, CD, USB drive or printed copy) for >50 percent of patient transitions of care and referrals

8. HIE: Immunization Registries: Perform at least one test of the capability to submit electronic data to

immunization registries; Actual submission where required and accepted

9. HIE: Syndromic Surveillance Data; Perform at least one test of the capability to provide electronic surveillance data to public health agencies.  Actual transmission according to applicable law and practice

10. Identify Patient-Specific Educational Resources: Use EHR technology to identify and provide >10 percent of unique patients seen with patient-specific educational resources

And now, the final caveat.   Incentive payments for becoming a “meaningful user of certified EHR technology” are only a small portion of the savings in the overall healthcare costs if changing policy works as expected over the next 5 years. The EHR incentive programs are putting approximately $25 billion (give or take a few billion), into the hands of physicians and hospitals who adopt EHR technology during 2011 and 2016.  During the same time, experts claim  we could see savings of $100 billion to Medicare alone,( depending on whose estimate you believe) by reducing  waste, duplication, and unnecessary procedures. It might be a lot more.   Some studies indicate that about 25%- 30% of our total national health care expenditure of $2.5 trillion (about $800 million), is unnecessary and could be eliminated through healthcare reforms as proposed by President Obama administration.  Now, that is definitely an amount the country can benefit from!