Archive for the 'Meaningful Use' Category

Can HL7 solve your Meaningful Use needs?

By now most healthcare organizations are knee-deep in Meaningful Use (MU) – but a new year means a new stage of MU, which means new requirements, new opportunities for solutions, and new pressures to find the right solution for your organization. That’s where we come in.

Next week Wednesday, February 18, Galen will be presenting a webcast on HL7 interfaces and how they fit into the Meaningful Use puzzle. The focus will be on Meaning Use Stage 2, as only 1% of hospitals and Eligible Professionals completed attestation for that stage in 2014; the bulk of qualified organizations will attest for Stage 2 in 2015 and 2016. The webcast will cover this year’s requirements, thresholds for attestation, new menu objectives, and Clinical Quality Measures.

HL7 timeline

We will also give a brief overview of HL7 messaging and its role in interoperability. The HL7 standard is used by 95% of U.S. healthcare organizations and boasts backwards capability – meaning HL7 is able to be integrated into nearly any existing information system. We will select seven MU2 objectives (shown below) and take an in-depth look at which HL7 interfaces would be appropriate as solutions.


Next week’s webcast is intended for an audience that have already been exposed to the basics of both Meaningful Use and HL7. However, we have previously presented separate webcasts for beginners on both topics, which can be found on Galen’s Wiki (notably, here are the links for the HL7 Fundamentals webcast and the MU2 Requirements webcast).

You can register for the “Your HL7 Interface and What It Means for Meaningful Use” here.  We hope you can join us!

Looking Forward to MU Stage 3


Every year Galen carves out a few days to regroup internally, looking towards the future of the healthcare IT industry, as well as recapping where we’ve come from.  As we do this, I’d like to do the same with Meaningful Use (MU) – reflecting on lessons learned from the past four years, as well as looking forward to MU Stage 3.

The goals for the three MU stages can be summarized as:

Stage 1: Data capture and sharing

Stage 2: Advanced clinical processes and decision support

Stage 3: Improved outcomes

The three stages were originally geared to support the healthcare industry’s move towards controlling costs, increasing quality, and improving patient health outcomes. Since the start of the meaningful use initiative in 2011, the healthcare industry has experienced significant changes with a particular shift toward Accountable Care Organizations (ACOs), where providers specialize in managing outcome risks for patient populations through patient care coordination.

Last month, the Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare & Medicaid Services (CMS) announced a delay to the start of MU Stage 3 to 2017, listing the following benefits for the changes to the MU Stage 3 timeline:

  • More analysis of feedback from stakeholders on Stage 2 progress and outcomes;
  • More available data on Stage 2 adoption and measure calculations – especially on new patient engagement measures and health information exchange objectives;
  • More consideration of potential Stage 3 requirements;
  • Additional time for preparation for enhanced Stage 3 requirements;
  • Ample time for developers to create and distribute certified EHR technology before Stage 3 begins, and incorporate lessons learned about usability and customization.

The delay impacts participants who began MU Stage 1 in 2011 or 2012, as they will now demonstrate MU Stage 2 for a third program year in 2016 before proceeding to MU Stage 3 in 2017.  For those who did not begin in 2011 or 2012, the last year to start participation and receive a payment was 2014.  Beginning January 1, 2015, eligible providers (EP) who do not successfully demonstrate meaningful use are subject to a negative payment adjustment. EPs who attest for the first time in 2015 will not receive an incentive payment, but can still avoid the penalty.

ONC and CMS have also proposed a new approach to the Certified EHR Technology (CEHRT) certification process, though the “2014 Edition” will still remain the baseline.  Vendors who have certified applications to the 2014 Edition will not need to recertify their products, and providers participating in incentive programs will not be required to upgrade beyond a 2014 Edition CEHRT application.  Per CMS, the goal of the new approach is to “to provide public input on policy proposals, enable our certification processes to more quickly adapt to include newer industry standards that can lead to greater interoperability, and add more predictability for EHR technology developers”, all the while allowing vendors more time to react.

As of January 12, 2015, CMS has not released a notice of proposed rulemaking (NPRM) for Stage 3, or the corresponding ONC NPRM for the 2017 Edition, or proposed interim 2015 Edition of the ONC Standards and Certification Criteria.  They document current recommendations for Stage 3 on their website.

CMS and ONC will continue to review all stakeholder comments before the final rules are published. The following is a sampling of feedback that has already been presented.

Stage 1 Lessons Learned

In the beginning, providers and healthcare organizations were challenged to understand what was needed. It took the organizations time to assemble teams with the right skills, build the infrastructures, and learn new processes to support Stage 1 requirements.  And while the incentive money has been a valuable motivational tool for providers and organizations, it took time to gain their attentions and to learn new requirements.

Stage 2 Lessons Learned

Transitions of care require community infrastructure and cooperation, with a reliance on patient actions and costly technology. To meet the new criteria, organizations have had to define new strategies, processes, and workflows for referrals and transitions of care.  It was, and still is, challenging to implement additional technical and organizational infrastructure in time for attestation.

Resource needs are greater in Stage 2 to develop the understanding of the requirements of the multiple activities and the coordination between the multiple vendors (MU, ICD10, PQRS, eRx, Direct Message IDs, etc.).

Key Takeaways and Recommendations for Stage 3

One of the biggest lessons learned is to allow enough time, especially when the objective is to improve outcomes and reduce costs, all the while emphasizing interoperability, care coordination, and quality of care.

Stage 1 and 2 are two-year reporting cycles, but the implementation required more, sometimes up to five years. The Stage 3 implementation could take even longer considering the stricter vendor requirements, higher user adoption, the fact that obsolete systems must be replaced, and that new systems must be integrated to support these measures.  CMS and ONC need to allow sufficient time for those changes in organizational infrastructure and workflows, meaning all required materials, such as CQM specifications, need to be available at least eighteen months before the start of Stage 3.

In addition to important time considerations, recommendations from providers and healthcare organizations include:

  1. Providing additional incentives for interoperability.
  2. Improving financial incentives for ACOs to assume risk and reward providers that do share risks.
  3. Streamlining high-value quality measures.
  4. Considerations for the impact on usability, development and implementation costs.
  5. Reconsideration of the “all or nothing” approach to attestation and full year reporting.
  6. Allowances for group reporting as is done with PQRS.
  7. Avoiding measures that require third party action (patients and other care settings). Engage patients, but do not force their engagement.

Healthcare organizations and EPs have gone through many challenges since the beginning of MU.  CMS and ONC responded to the providers’ feedback by delaying the start of Stage 3, and their intent is to deliver a final rule with smaller, more incremental changes that will be smoother for organizations to adopt. In addition to incorporating the lessons learned from Stages 1 and 2, organizations recommended that Stage 3 align with other pertinent healthcare initiatives such as ACOs.  We look forward to receiving the Stage 3 final rule sometime in Q1 or Q2, with new requirements that will hopefully result in the adoption of positive, manageable changes for healthcare organizations.


Syndromic Surveillance


Syndromic surveillance is a method of collecting and using clinical data for the early detection of potential disease outbreaks. For Meaningful Use Stage 2, there are several scenarios in which Eligible Providers (EP) can meet the Syndromic Surveillance Menu Set measure.  Each of those scenarios can be grouped into one of two categories:

Syndromic Surveillance is Available in your State

The first scenario occurs when an EP has been submitting information using an ONC certified EHR prior to the EP’s MU Stage 2 attestation, and continues to submit during the reporting period.  At this point in time, very few EPs fall into this category, but for those who do, no changes are necessary.

The next scenario happens when an EP registers intent with the state within 60 days of the reporting period and achieves ongoing submission of data for the reporting period.

Syndromic Surveillance is not Currently Available in your State

For many states Syndromic Surveillance is not yet up and running, so ongoing submissions are not an option for meeting the measure.  In this scenario CMS requires you to register intent with your state within 60 days of the start of your reporting period. Once you’ve registered, intent your organization will need to engage in the required validation and testing, or wait for your state to approach you about validation and testing process.

The key to this measure is to register intent within 60 days of your EP’s reporting period.  For 2015 that would be March 1st, so make sure to mark that date on your calendar.





Patient Reminders


Sending patient reminders based upon clinically relevant data is now a core measure for Meaningful Use Stage 2.  The required threshold is 10% of unique patients that have been seen by an eligible provider at least twice in the past 24 months.

Initially, the best approach is to generate several general patient lists based upon specific conditions to gauge where your providers stand in terms of meeting that 10% threshold.  From there, you could slowly make the queries more specific to narrow the population down near 10%.

Since this is based upon the patients’ preferred communication methods, we recommend not defining too broad of a patient population.  Your organization will be responsible for calling your patients and for printing and mailing these reminder letters, both which can be costly and time consuming.  This serves as all the more motivation to encourage patients to enroll and use your patient portal.

A qualifier for this measure requires that the reminder be for follow up or preventive care that the patient is not already scheduled to receive.  For example, it would not be acceptable to send patients reminders about an annual visit that had been previously scheduled, though sending a reminder to schedule an annual mammogram or get a yearly flu shot does count towards the numerator.  If your organization needs any help generating queries or defining patient populations to help you meet this measure, the staff at Galen can gladly assist you.

Failure to Address Advancements Electronic Healthcare May Affect Patient Safety

Safety Image

With advancements in technology and improvements in functionality comes an increased risk in patient safety.  Systems are continuously being upgraded and configured to address the latest improvements.  With each change there is potential for unexpected glitches, causing the system to possibly behave incorrectly or differently than previously utilized by its users.  New workflows may be required within the organization and existing ones may need to be re-visited.  This can lead to data being entered incorrectly or not captured at all.  One recent case involved an Ebola patient being released when quarantine was required, potentially exposing other patients and individuals upon release.  Upgrades to software versions may display risks in a different manner and become confusing to the individual entering data.  Unfortunately, this can jeopardize patient safety.

Electronic healthcare has been a growing business and vendors are continuously offering new applications and add-ons.  They are created and offered for different EHR systems and may or may not work as intended with each new upgrade. There are many vendors and products in the industry which causes an unfortunate problem where many disparate systems are unable to communicate with one another.

It becomes more important to ensure each organization is prepared for roll-outs with careful planning.  Strategies need to be in place to prepare for these changes.  Training should be created, detailed, and documented to ensure end-users are trained on newer versions, as well as being trained on each new application and feature that will be used.  This applies to current employees and new-hires.

Researchers evaluated 100 closed safety investigations reported between August 2009 and May 2013 to the Informatics Patient Safety Office of the Veterans Health Administration. Among the findings, 74 events resulted from unsafe technology, such as system failures, computer glitches, false alarms or “hidden dependencies,” a term for what happens when a change in one part of a system inadvertently leads to key changes in another part. Another 25 events involved unsafe use of technology such as an input error or a misinterpretation of a display.

Universally, organizations have devised aggressive timelines to implement new systems and features in order to meet federal requirements for meaningful-use goals.  Unfortunately, this may lead to improper planning, testing and training.  Patient safety becomes compromised in these situations and puts healthcare networks at risk for penalties.  SAFER Guides is a recommended list of various implementation and monitoring resources.

See Modern Healthcare “Complicated, confusing EHRs pose serious patient safety threats”

See HealthIT.Gov for additional information and resources.

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