Politico Reports: ONC Releases Meaningful Use Stage 2 Attestation Rates

Attestation rates for Stage 2 of meaningful use remained low at the end of September, according to data released ahead of today's Health IT Policy Committee meeting. The figures, contained as footnotes in an ONC data analytics update, show that 4,656 doctors and other eligible providers and 258 hospitals had attested to Stage 2. This is an increase over the end of August but still only a rounding error out of 480,000-plus eligible providers and hospitals. The low figures reflect problems that electronic health records vendors and providers have had achieving Stage 2. 

CMS relaxed the rules on reporting Stage 2 attestation earlier in the year, and provider groups have been pressing to reduce the one-year reporting period to 90 days in 2015. We have a feeling that a GOP-controlled Congress may try to do something about this.

ONC's analysis of the Sept. 30 attestation data showed disappointing levels of accomplishment in meeting some of the most important categories of Stage 2. For example, 87 percent of eligible providers who attested to Stage 2 received exclusions from showing they could electronically send summaries of care. Of those who did not receive exclusions, only 18 percent were able to send electronic summaries 80 percent of the time or more. A total of 55 percent were able to file summaries electronically 30 percent or less of the time. Scores for the "view, download or transmit" category, a measure of physicians' capacity to share data with patients, were even worse. Although 65 percent of the attesters' patients had online access to records, only 10 percent of these providers were able to get patients to download their records more than half the time.

A similarly small percentage sent patient reminders on a regular basis. In its analysis of hospitals, ONC found that only 10 percent got out electronic care summaries to patients more than half the time, and less than 15 percent were able to get more than 20 percent of their patients to view, download or transmit their records. However, as ONC pointed out, the figures represented a somewhat improved picture from analyses it did over the summer.

Many individuals are concerned about the privacy of their medical records, but that doesn't keep most of them from giving information to health care providers, according to survey results to be released at the meeting. In a survey of more than 2,000 people conducted in 2012-13 for ONC, 75 percent were "very or somewhat concerned" about the privacy of information in EHRs. But only eight percent said those concerns would cause them to withhold information from health care providers.

Politico Report: http://www.politico.com/morningehealth/1114/morningehealth15954.html

Can't Miss Event May 13th at NAHAM 40th Annual Conference: NAHAM University Session

NAHAM University

 Hot Topics Discussion & Networking Opportunity

The National Association of Health Access Management 40th Annual Educational Conference & Exposition will be held May 13-16th in Hollywood, Florida. The conference theme this year is "From Admitting to Patient Access: 40 Years of Leadership." Conference attendees will enjoy outstanding educational sessions and invaluable networking opportunities. 

One of the most interactive and informative sessions is held before the conference officially begins on Tuesday, May 13th at noon. Peter Kraus, Business Analyst at Emory Healthcare, will moderate a NAHAM University session that is a popular venue for attendees to meet and discuss hot topics in the industry. 

The event is open to patient access manager participants from both academic and non-academic healthcare facilities. The topics for the 2-hour interactive session are determined by conference registrants. Kraus expects this year's discussion to cover the ICD-10 transition, Meaningful Use implementation, electronic health records, and issues that arise in the admission process. Participants found past discussions very helpful as colleagues offered road-tested solutions to the issues facing participants' individual hospitals.

What Hot Topics are you interested in? What issues is your hospital facing in 2014? 

Let NAHAM hear your topic suggestions for the the NAHAM University 

session in the comments section!

EVENT DETAILS

NAHAM University

Tuesday, May 13
12:00 p.m. – 2:30 p.m.

REGISTER HERE: http://www.naham.org/?page=Conference_Reg

Separate registration fee applies. Lunch is included and will be provided starting at 11:30 a.m. 

Proposed Medicare Rule Leaves Hospitals Concerned About Financial Impact

The Centers for Medicare & Medicaid proposed a rule on Wednesday that makes changes to several aspects of the  Medicare payment program. The proposals were part of a wide-ranging, 1,600-plus-page proposed rule issued by the CMS outlining Medicare payment and policy changes for hospitals in 2015. A final rule is scheduled to be published August 1. The policies would be effective October 1.

Under the proposed rule the payments for inpatient treatment at acute-care hospitals will decrease by $241 million in fiscal year 2015. The proposed rule would affect over 3,000 hospitals nationwide.  In addition, the CMS proposes increasing Medicare payments to long-term-care hospitals by 0.8% in 2015, a bump of $44 million. The change in payment methodology would affect 435 facilities. Under the proposed payment rule, hospitals that successfully participate in Medicare’s quality reporting system and meet the criteria for the meaningful use of health information technology will see a payment bump of 1.3%. However, because of the penalties meted out to the hospitals that don’t, the CMS is projecting an overall reduction in payments.

Bill to Delay ICD-10 and Sustainable Growth Rate Patch Passes House

Advocates on behalf of hospitals and practitioners were optimistic about the likelihood of a permanent 'fix' to the Sustainable Growth Rate for Medicare's physician reimbursement system. Members in both the House and the Senate introduced bills this session that would repeal the Sustainable Growth Rate in Medicare's physician payment formula. 

In a surprise development today the House passed the Protecting Access to Medicare Act of 2014, H.R. 4302, by voice vote. This bill does not provide a permanent fix, only a one year patch to the Sustainable Growth Rate. The legislation, sponsored by Rep. Pitts of Pennsylvania, did not extend a fix for the SGR to physician-owned hospitals. Insiders agree that the cost of longer term bipartisan bills with permanent fixes to SGR were tabled because the parties were not able to agree on how to pay for the costs--about $140 billion over a 10 year period.  

Many on the hill expect the Senate to move this bill to a vote tonight. Speaker Harry Reid is said to be working on a deal to bring the bill to the floor. However, Senator Wyden is said to be pushing back on passing a bill with only a short term fix. Stakeholders following SGR legislation believe that if a temporary fix is passed the Congress will feel less pressure, and efforts to pass a permanent fix this year will fade into the background. 

The Protecting Access to Medicare Act of 2014 also contains a provision to delay the ICD-10 meaningful use requirements until October 2015. CMS Administrator Marilyn Tavenner has repeatedly stated that the agency was not going to extend the ICD-10 meaningful use requirements. Many eligible practitioners and hospitals are concerned about being able to meet the deadline and have publicly appealed to the agency and Congress to extend the compliance deadline. 

CMS Issues Guidance on Stage 2 Meaningful Use Hardship Exceptions

The Centers for Medicare and Medicaid Services (CMS) issued guidance on qualifying for the hardship exception from Stage 2 meaningful use requirements under the federal electronic health record incentive payment program. CMS has been under pressure by stakeholders and lawmakers alike to provide clarification about how to apply and what conditions qualified hospitals and eligible professionals for a hardship exemption

The guidance explains that CMS may grant hospitals and eligible professionals the hardship exception and grant an extension for meeting the Stage 2 meaningful use requirements if their electronic health record (EHR) vendor is at fault for their failure to meet the deadline. This expands on previous statements by CMS Administrator Marilyn Tavenner that the applications for exceptions would be evaluated on a case-by-case basis. 

The guidance specifically states that providers may apply for hardship exceptions if the "EHR vendor was unable to obtain 2014 certification" or the hospital or eligible professional "was unable to implement meaningful use due to 2014 EHR certification delays." If approved, the hardship exception is valid for a single payment year. In the event the application for exception is denied hospitals and eligible professionals may not appeal the decision and any denial is considered final.

The hardship exception application for hospitals is available here.

The hardship exception application for eligible professionals is available here. 

Patient Identification and Matching Report Released by ONC

The Office of the National Coordinator for Health Information Technology (ONC) released the final version of the Patient Identification and Matching Report. The report evaluated best practices and current trends in using electronic health record systems to accurately identify patients and exchange information between providers, patients, and caregivers. Mistakes in properly identifying patient health records put patient safety at risk and has resulted in too many patient deaths. 

The drafting process for the report included an industry environmental scan with input from stakeholders at meetings, on calls, and requests for submitted comments and recommendations. NAHAM was an active participant throughout the drafting process and provided recommendations focused on improving patient safety that are featured in the report. NAHAM's recommendations can be found on page 76 of the report. 

The report resulted in 10 findings that ONC will use as they move forward with the process of improving electronic health record systems and patient matching to improve patient safety.The findings are below.

Findings

1. Standardized patient identifying attributes should be required in the relevant exchange transactions. 

2. Any changes to patient data attributes in exchange transactions should be coordinated with organizations working on parallel efforts to standardize healthcare transactions. 

3. Certification criteria should be introduced that require certified EHR technology (CEHRT) to capture the data attributes that would be required in the standardized patient identifying attributes.

4. The ability of additional, non-traditional data attributes to improve patient matching should be studied. 

5. Certification criteria should not be created for patient matching algorithms or require organizations to utilize a specific type of algorithm. 

6. Certification criteria that requires CEHRT that performs patient matching to demonstrate the ability to generate and provide to end users reports that detail potential duplicate patient records should be considered. 

7. Build on the initial best practices that emerged during the environmental scan by convening industry stakeholders to consider a more formal structure for establishing best practices for the matching process and data governance. 

8. Work with the industry to develop best practices and policies to encourage consumers to keep their information current and accurate. 

9. Work with healthcare professional associations and the Safety Assurance Factors for EHR Resilience (SAFER) Guide initiative to develop and disseminate education and training materials detail best practices for accurately capturing and consistently verifying patient data attributes. 

10. Continue collaborating with federal agencies and the industry on improving patient identification and matching processes. 

No Extension for ICD-10 Implementation

Marilyn Tavenner, Administrator for the Centers of Medicare & Medicaid Services, announced today that there will be no extension of the October 1, compliance deadline for the nationwide conversion to the ICD-10 diagnostic and procedural codes. Speaking at the Healthcare Information and Management Systems Society convention in Orlando, Florida, Tavenner also explained that CMS was not changing compliance requirements for Stage 2 despite extensive pressure on the agency. 

Stage 2 of the electronic health record incentive payment program requires providers to electronically exchange healthcare records with each other to improve the interoperability of CMS' value-based payment programs. Eligible hospitals must commence 90 consecutive days of meeting the meaningful-use criteria on schedule. The starting date for most hospitals was October 1, 2013. However eligible professionals and physicians which operate on a fiscal year must begin compliance on April 1 or July 1, 2014. 

CMS will consider extensions on a case-by-case basis for providers and health IT vendors to obtain a "hardship exemption" that will extend the deadline for that facility. Tavenner does not expect the exemptions to delay full Stage 2 implementation by 2015. 

CMS Extends Medicare EHR Meaningful Use Attestation Deadline to March 31, 2014

The Centers for Medicare and Medicaid Services announced an extension for some participants in the Medicare Electronic Health Records meaningful use attestation deadline. The extension did not retroactively change any requirement for the date the criteria must have been met, it merely extended the deadlines for data submission for some physicians, eligible professionals and hospitals. The deadline extensions do not apply to the Medicaid portion of the Electronic Health Records incentive payment program. The Medicaid incentive payment program does not incorporate penalties.

Both the Medicare and Medicaid Electronic Health Records incentive payment programs were created in the American Recovery and Reinvestment Act of 2009. The programs have a significant impact with payments thus far in the amount of over $19 billion to more than 320,000 physicians and other professionals and 4,400 hospitals.  


Physician and Eligible Professional Extension

The Centers for Medicare and Medicaid Services (CMS) extended the deadline for eligible professionals to attest to Electronic Health Records (EHR) meaningful use in 2013. Physicians and eligible professionals will now have until 11:59p.m. on March 31, 2014 to submit their performance data. The new deadline, extended from February 28, 2014, does not change the requirement that the criteria for meaningful use must have been met by the end of the reporting period for the incentive payments, December 31, 2013. 

A CMS press release explained that this extension would allow more time for providers to submit their meaningful-use data, receive an incentive payment for the 2013 year and avoid the 1% penalty 2015 payment adjustment. 

EPs attesting for the Medicaid program or Physicians Quality Reporting Systems incentive pilot program did not receive an extension and must complete the attestation requirements by the original deadline. 


Hospital Extension

CMS is also offering what the agency is calling a "one-time" extension to hospitals "that may have experienced difficulty attesting" by the November 31, 2013 Medicare meaningful use attestation deadline. To be eligible to participate in the deadline extension hospitals must contact CMS by 11:59p.m March 15, 2014 for assistance. 

This extension will allow eligible hospitals to receive incentive payments under the program and avoid the price adjustments effective in 2015. 

Like the extension for physicians, the extension for hospitals does not change the deadline for the date the meaningful use criteria must have been met. The implementation deadline for the hospitals program, which operates on the fiscal year, was September 30, 2013. 


Resources
A Modern Healthcare article discussing the extension is available here.

A Medscape article discussing the extension and incentive payments is available here. 

A FierceHealthIT article discussing industry representative opinions on the extension is available here. 

A user guide for eligible professionals on meaningful use attestation is available here. 

A user guide for eligible hospitals on meaningful use attestation is available here.

The EHR Information Center is Open Monday-Friday from 8:30a.m.-5:30p.m. EST. The toll-free number to reach the center for assistance with meaningful use attestation is 1-888-734-6433. 

Congressional Gridlock Stalls Hopes for National Patient Identifier and Meaningful Use Stage 2 Delay

Many in the health IT field believe that implementing a national patient identifier and a deadline extension for stage 2 meaningful use requirements would ensure a more cohesive operation of patient access and identification systems and increase patient safety.  Both of these problems require congressional action to solve, but with a Congress that fails to pass even the most basic pieces of legislation and appropriations it is unlikely there will be any legislation addressing these issues in the year to come.

National Patient Identifier

A national patient identifier would go far to improve patient safety by improving the accuracy with which patients are matched with their medical records.  Ideally, a national patient identifier would be a unique number for each patient with a two-digit checksum at the end of the number. In practice this would allow a patient’s data to move completely through multiple data systems without comingling with other patients’ records that may contain similar names, addresses and other identifying factors.

However, the likelihood of legislation requiring a national patient identifier is very slim after Congress voted to overturn a HIPAA provision that would have required a patient identifier in 1998. Congressional opposition focused on privacy concerns and the capability providers have to identify patients with several different identifying factors. Former national health IT coordinator Farzad Mostashari, M.D., explained that he believed the odds were very low for a national patient identifier and that it would require the industry proving they are unable to keep patients straight by cross-checking a patient’s identity with other identifying factors available to the provider.

Meaningful Use Incentive Program

The electronic health records meaningful use incentive program was created to advance the adoption of health information technology nationwide. Beginning in 2014 eligible hospitals and professionals will have to comply with stage 2 of the regulatory standards in order to receive corresponding incentive payments. 

Senator Alexander and Senator Thune, along with 15 other Senators, wrote a letter to HHS Secretary Kathleen Sebelius requesting more time for implementation of stage 2 standards. Their letter stated, “If the goal is to improve care by achieving broad and meaningful utilization of EHRs, providing sufficient time to ensure a safe, orderly transition through Stage 2 is critical to having stakeholder buy-in, a necessary component of long-term success.

However, former national health IT coordinator Farzad Mostashari, M.D., does not think that this extension will be granted.  Without speaking to the merit of the request, Mostashari recently told a group gathered at the CHIME Fall Forum that the extension would take up to a year to approve, and the extension requested is a year. The overlap would through U.S. health IT into “total chaos” due to the uncertainty during the rulemaking process to amend the schedule.

 Resources

Don Fluckinger’s article, “Shut down thoughts of a national patient identifier,stage 2 extension,” 

A podcast discussing the benefits of a national patient identifier can be found here. 

Alexander-Thune Letter from 17 Senators to Secretary Kathleen Sebelius requesting a meaningful use stage 2 delay can be found here. 

Hidden Costs of Duplicate Patient Records

A recent article by Patricia Consolver, Minimizing Duplicate Patient Records to Maximize Cash Flow, highlighted the relationship between a reduction in duplicate patient records and increases in revenue cycle efficiency. A 2008 RAND Corporation study found that the average duplicate patient record is 8 percent. In addition to the inherent risks to patient safety, duplicate and incorrect patient identifications have the potential to impair downstream financial activities such as delayed payments, appeals, and denials. 

The costs associated with duplicate records also include instances of repetitious lab and diagnostic tests that were performed, but documented in a duplicate record. Insurance companies often deny claims for repetitive tests. This results in care that the hospital will not be reimbursed for and cannot collect. 

Texas Health Resources, a 13-hospital system that serves over 1 million patients per year, implemented a four-step process during the transition to EHRs that resulted in a duplicate patient record rate of 0.36 percent. 

The Four-Step Process

1. Scrubbing the existing MPI
2. Identifying and selecting the correct patient records
3. Educating key stakeholders on avoiding duplicate creation
4. Monitoring performance

Education was necessary to ensure the EHR did not devolve to the state of MPI's duplicate records. Texas Health Resources education efforts were focused on both registration and medical record department employees. These courses emphasized the importance of using a full, legal name and the ways that duplicate records affect downstream activities in several areas of the hospital's operations. Data integrity teams were created to monitor the records and focus new education efforts on common mistakes that needed to be corrected. 

The implementation of similar systems is being evaluated at hospitals across the country as Meaningful Use requirements become effective.