Everything HITECH

Where are your Peers on Meaningful Use Payments?

2011 was the first year for receiving ARRA’s EHR Incentive Payments.  Just how much Meaningful Use money has CMS distributed, and how many providers got paid?    

Action item: Make it a priority to get Meaningful Use Funds in 2012  When Congress approved the appropriations for the EHR Incentive program, they provided for about $32 billion in gross payments, with $2 billion for program administration, leaving $30 billion in cash outflow to providers.  As of the end of November, CMS has paid out a little over $1.8 billion to providers under Medicare and Medicaid.  $1.8 billion down, $28.2 billion to go.  Is this a program success?   The incentive phase of this program is budgeted to pay out stimulus funds through 2016 for Medicare; the Medicaid incentives run a little longer, going through 2021 for Medicaid EP’s, and 2019 for Medicaid Hospitals.  Of course, payments are very front-end-loaded.  The first year is the biggest year for any provider, under any aspect of this program, and payments tend to dwindle down in later years.   It is also important to note that qualifying for payment is not a one-time deal.  Every year, providers must re-apply and re-qualify.  Of course we all get to qualify under the easiest set of Meaningful Use criteria (Stage 1) for at least the first two years, but even that is not a slam-dunk.  Second year qualification is harder if for no other reason that providers must maintain threshold values in each criterion for the entire year, rather than just any 90 day period.  So one of the first questions of interest in the payouts is “how many organizations have qualified as Meaningful Users of EHR Technology”.  The answer is surprisingly, “a small percentage”.   Here’s how the $1.8 billion has been paid out:

But these numbers do not in themselves tell us how many providers have actually been paid under Meaningful Use, as opposed to the Adopting, Implementing or Upgrading (AIU) provision of Medicaid, under which it is not necessary to achieve Meaningful Use.  CMS does not separate out those hospitals receiving AIU payments vs Meaningful Use Payments.  However, there is one interesting statistic that may help us impute this split.  Medicare made payments to 411 hospitals through November of 2011, and Medicaid made payments to 802 hospitals in that same period. 

A little analysis on these numbers leads us to the conclusion that a large percentage of hospitals paid under Medicaid are likely to be AIU alone.  Here’s the logic stream:

1. Of the 802 hospitals receiving Medicaid payments, most would qualify to receive Medicare stimulus payments (if they achieve Meaningful Use);
2. Medicare has no AIU provision, so all 411 hospitals receiving Medicare funds attested to Meaningful Use;
3. Therefore something close to 391 hospitals, or 48% of stimulus recipients (802 – 411 = 391), probably did so under AIU. 

 

So, by digging deeper into the numbers, we see that fewer that fewer than 14 percent of the country’s hospitals have received stimulus funds, and only about half of those have attested to Meaningful Use … after one full year’s program eligibility. 

 I don’t know about you, but I’m not sure I would call that a rousing success in “stimulating” the healthcare industry.  Not yet, anyway. 

 To keep track of CMS progress on EHR Stimulus Payments, click and bookmark: http://www.cms.gov/EHRIncentivePrograms/56_DataAndReports.asp

CMS Increases Cost of EHR Technology?

Well, here's an interesting observation.  Not particularly decision-quality, but intriguing nonetheless.  I was researching a the Final Rule /Federal Register on a question for one of our subscribers, when I came across the following quote (Federal Register / Vol 75, No 144, July 28, 2010, page 4492, column 1):

"Specifically, since the ONC is establishing new certification criteria for EHR technology, we believe the average cost of certified EHR technology incorporating the new criteria will be higher than the current costs of EHR technology. It is our assumption that making improvements to incorporate the new certification standards into current EHR technology will be costly."

So the cost of the government program alone increases the cost of technology we will be using in our hospitals and physician offices.  If you didn't have sufficient incentive to apply for incentives before ...

I wonder if anyone has actually observed this.

Jay Fisher | @JayRFisher

ARRA Meaningful Use Guidelines as an Implementation Planning Aid

ARRA HITECH represents important financial and regulatory compliance content for most hospitals and medical groups for the next several years.  But we believe that Meaningful Use, Quality Measure Management, and EHR Interoperability guidelines established by CMS also represent a body of work in defining reasonable goals for most EHR Implementations – quite apart from the regulatory implications. 

For hospitals embarking on new EHR journeys, or re-evaluating their EHR priorities, one of the most difficult and time-consuming tasks is to define operational and clinical EHR goals that are easily communicated to medical staff, and where progress can be easily measured.  In some cases, your vision becomes a competitive physician recruitment and retention weapon, showing that you are a state-of-the-art Medical Facility.  We have observed cases where developing this vision takes months.  Getting the message to all relevant stakeholders, and getting obtaining commitment is time consuming and critical to successful implementations.  Clinician buy-in may be the single most important factor in determining the timing, and cost of getting your EHR up and running. 

Adopting the CMS HITECH requirements, as the starting point for a clear, relevant set of goals makes a lot of sense.  Your institution may choose to go farther than these requirements suggest, or you may choose to phase them in over multiple future periods.  HITECH cuts through the amount of time it takes to get organized, develop a clear and convincing vision, communicate expectations and progress, and keeps your entire organization clearly focused on your EHR goals … and does so over the life of your programs. 

I've always been a Project Manager and Program Manager.  My principal tracking and communication tools have been workplans in Microsoft Project, or Open Workbench, or something similar.  And, while I loved the order and predictability these  plans give, we were always missing something.  That missing element was an ability for the business (or clincial) stakeholders to clearly evaluate and communicate their progress. 

The ARRA Meaningful Use (well, 23 Meaningful Use requirements and another 40 or so Quality Measures) define one possible vision that has value beyond merely getting money from CMS.  If we can figure out good ways to communicate those standards across all our clinicians, and communicate our progress against them, the government may have done us all a favor!   Take a look at a tool we have developed for our clients' use.  It organizes and interprets the requirements in a way to drastically improve communication.  It gives clinical departments a simple, ongoing way to show their progress.  From a project management point of view, you should really consider using the HITECH requirements to measure accomplishments in a  way that makes sense to your business and clinicians ... not just to your project managers. 

Jay Fisher | @JayRFisher

Do Multi-EHR Hospitals fulfil Meaningful Use Compliance more Easily?

As we review requirements, we find that for hospitals with multiple EHR systems in place, compliance changes, just a little. Click on the image to the left, here for a thoughtful, simplified illustration.  And have a little fun.

Seriously, though ... it seems that for Quality Reporting (if not many Meaningful Use Requirements) that multiple departmental EHR's might be involved in gathering the data for an individual requirement.    HITECH requires this data be drawn from your Certified EHR's.  Consider, for example the need to calculate an all-hospital 30 day re-admission rate.  Or (a possible scenario) you have an EHR in your OR that is not Certified, but have a general acute care EHR product which is Certified.  You might need to move data to qualify.  And to satisfy the need to do drug-drug or drug-allergy checks, you'll probably need to do it in each place in your clinical environment ... regardless of what vendor's product is being used. 

Bottom line - we think you've got to inventory all your EHR assets, and plan accordingly.

Jay Fisher | @JayRFisher

Meaningful Use Requires Meaningful Leadership

We ran across this post today by Edward Marx, CIO of Texas Health Resources. His opinion on the standards represented by the interim final rule and Stage 1 requirements is insightful. Very valuable information for hospital leadership.

Do Word and Excel and Power Point not let you type "EHR"? Grrrrrr!

This is for a CIO friend of mine (and anyone else who grinds their teeth and always types EMR because Word and Power Point always autocorrect to HER).  I've updated my custom dictionary, to no avail. 

Justin Wilcox of NimbusHealth sent me this URL on how to prevent Microsoft tools from auto correcting!  It is SO easy I'm embarassed.  (Thanks, Justin ... you made my day. And my CIO friend's too)

at screencast.com