Tuesday, September 21, 2010

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 




10Report 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 agenciesActual 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! 


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