Centers for Medicare and Medicaid Services – RISC Management and Consulting

Challenges of Meaningful Use

Meaningful Use (MU) is the adoption of a certified Electronic Health Record (EHR) technology with a focus on improving quality, safety, efficiency, and reducing health disparities in the clinical/hospital setting. The idea is to increase patient engagement to improve care coordination while maintaining the privacy and security of the patient’s Protected Health Information (PHI).

According to Milan (July 27, 2015) “After a day spent hearing from health IT experts about information blocking practices, Republican Sen. Lamar Alexander, chair of the Senate Health, Education, Labor & Pensions Committee, said Thursday afternoon that he’s asked HHS to consider a delay of Stage 3 meaningful use”. The Department of Health and Human Services (HHS) is the U.S. government’s main agency for enhancing and protecting the health and well-being of all Americans.

Here are some quotes from Senator Lamar Alexander:

“Let’s not impose on physicians and hospitals a system that doesn’t work…”

“We want something physicians buy into, rather than something they dread…”

It is important to update and improve our current way of keeping health records as well as a more appropriate way to share health information with other providers. The quality of the EHR tool becomes the most desirable trait it seems. Remembering HIPAA where the importance of assessing all of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of all Protected Health Information (PHI) is required. However, each medical provider is unique in their operational environment with their own set of variables and must be factored in to the equation.

Another important piece of information according to McCarthy (July 22, 2015):

“Stage 3 of meaningful use for EHR implementation requires providers to send electronic summaries for 50 percent of patients they refer to others, receive summaries for 40 percent of patients that are referred to them and reconcile past patient data with current reports for 80 percent of such patients. If other providers do not send electronic summaries, however, the provider who was supposed to receive them will fail to meet the second and third requirements.”

Probst (2014) mentioned from an interview that Intermountain Healthcare is Stage 2 Certified in 2014 but will not be attesting at this time.

The Agency for Healthcare Research and Quality (AHRQ, March 26, 2015) provided some research data on barriers to meeting the stage 3 criteria for Meaningful Use:

Lack of provider and practice staff time – 69%
Complexity of required workflow changes – 68%
Difficulty with electronic exchange of information – 65%
Direct Financial Costs – 54%
EHR design and functions do not easily support care coordination – 51%

Readiness to meet criteria results:

Only 11% of those who participated in the research are able to meet all of the criteria

AHRQ’s mission is to “bring about evidence to improve health care quality and safety, increase accessibility, equitability and affordability within the HHS and other partners. Their objective is to ensure that the evidence is understood and employed.

For more information on Stages of Meaningful Use Click the link above

These are only some views on the subject of Meaningful Use, but there are many standards, policies, ideas that are available from other organizations that might be helpful.

Our work here at RISC Management has enabled us to view firsthand the privacy and security challenges of Meaningful Use, and of course HIPAA and HITECH. These are significant challenges that the Providers must meet, but they are reasonable and attainable.

For more information on Risk Analysis Click the link above

References

Agency for Healthcare Research and Quality. (March 26, 2015). Informing stage 3 meaningful use requirements through evidence: Webinar. Retrieved from https://www.youtube.com/watch?v=nQrMKcq0VAM

McCarthy, Jack. (July 22, 2015). Stage 3 meaningful use ignores market realities. Retrieved from http://www.healthcareitnews.com/news/brookings-meaningful-use-stage-3-ignores-market-realities

Meaningful Use. (2015) Definition. Retrieved from http://www.healthit.gov/providers-professionals/meaningful-use-definition-objectives

Miliard, Mike. (July 23, 2015). Senate suggests stage 3 MU delay. Retrieved from http://www.healthcareitnews.com/news/senate-call-stage-3-mu-delay?mkt_tok=3RkMMJWWfF9wsRohuKTPZKXonjHpfsX57e8uUKOylMI%2F0ER3fOvrPUfGjI4GRMVkI%2BSLDwEYGJlv6SgFQ7LHMbpszbgPUhM%3D

Probst (2014). CIO on MU stage 2: Certified but not attesting. Retrieved from http://bcove.me/kt82385m

According to the Institute for Operations Research and the Management Sciences (INFORMS), analytics is the scientific process of transforming data into insight for making informed decisions. The HIMSS Analytics Report released September 18, 2013 mentioned approximately 68% of hospitals who bought an EHR software through June of this year purchased from a certified vendor who “fit” the 2014 Edition certification criteria. The report was made possible by the not for profit organization of the Healthcare Information and Management Systems Society (HIMSS).

Highlights of the report:

At least 60% of hospitals in the sample have met the requirements for at least nine of the core metrics that define Stage 2 Meaningful Use
70 % of respondents across all metrics are actively moving toward , meeting Stage 2 ,Meaningful Use requirements
Suggests industry is moving towards Stage 2 Meaningful Use and hospitals will be ready to begin attesting in 2014
Research was based on 418 hospitals that provided the data from January- June of 2013

Meaningful Use and Risk Analysis

In order to qualify for Meaningful Use incentives CMS identified a core set of 14 Meaningful Use objectives in which eligible hospitals (EH) and 15 core Meaningful Use objectives in which eligible professionals (EP) need to focus to qualify for incentive funds provided through the new CMS Medicare and Medicaid incentive program. Additionally, EHs and EPs must also focus on five of 10 menu set objectives to quality for incentive funds.

An Eligible Hospital (EP) must attest to all 14 Core Measures of the Meaningful Use Stage 1 requirements in order to qualify for stimulus money. Core Measure #14 requires that organizations complete a series of activities, both initial and follow-on. It is important to note that there is no exclusion from Core Measure #14, that is, it is not an optional or excludable component of the attestation. Eligible professionals (EPs) must attest Yes to having conducted or reviewed a risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1) and implemented security updates as necessary and corrected identified security deficiencies prior to or during the EHR reporting period to meet this measure. It is worth noting that Stage 2’s requirements continue to reinforce the importance of Privacy and Security by requiring encryption. All providers must achieve meaningful use under the Stage 1 criteria before moving to Stage 2.

The area of risk analysis is one that organizations must ensure that they are taking into consideration. Without undergoing this process and then using the outcomes to change use of controls and modifications within policies and procedures, organizations will not qualify for the Meaningful Use incentives.

Contact RISC Management and Consulting to learn more about our Meaningful Use services and Attestation: http://www.riscsecurity.com/

For more details, visit the HIMSS Analytics page and download the entire report: http://www.himss.org/News/NewsDetail.aspx?ItemNumber=22376

Click here for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs Stage 2 Toolkit: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_Toolkit_EHR_0313.pdf