Archive for the 'Meaningful Use' Category

Final Meaningful Use (MU) ruling has arrived! What stays and what goes?


Last Tuesday, CMS and ONC released rulings for 2015-2017 Modified Stage 2 objectives as well as some details for Stage 3 MU.  News spread quickly that the changes outlined in the Modified Stage 2 objectives opened up the field for eligible providers to meet MU Stage 1 and Stage 2 for this reporting year, whereas the previous criteria were quite challenging for most.  CMS has provided the summary of changes for the new objectives for 2015-2017. What happens now that the final ruling has passed?  First, each healthcare organization will need to understand what actually has changed in the new Modified Stage 2 and how it impacts end users.  Likewise, Electronic Health Record (EHR) vendors and organizations with alternative reporting warehouses will need to accommodate the changes to the new metrics for MU reporting.  I have highlighted some key areas to consider with the final ruling below.

What’s new?

  • 90-day reporting period for MU 2015, both Core and Clinical Quality Measures
  • Patient Access – now only one patient is required to view, download, or transmit his/her information during the reporting period. Previously, it was 5% of patients.
  • Secure Messaging – The original threshold of 5% of patients being required to send or receive messages has been eased. To receive credit, clinicians now only need to demonstrate the ability to generate secure messaging.
  • Single set of ten (10) objectives for all EPs regardless of Stage (1 or 2)
  • No Menu objectives to select from in the Modified Stage 2 objectives
  • Clinical Quality Measures are the same for MU

What goes?  Does that mean we stop doing it?  The original intent of MU was to focus on the use of the EHR to improve patient care, and the later stages focus on patient quality outcomes.  Some of the criteria were certainly viewed as “busy work” by staff.  However, many of the core measures below that have been removed are still required to some degree as part of the Clinical Quality Measures.  For example, obtaining blood pressure and smoking status for NQF 0018 and NQF 0028, respectively, remain quality metrics for Physician Quality Reporting System (PQRS) and MU Clinical Quality Measures reporting.

  • Record demographics
  • Capture vitals
  • Smoking status
  • Provide clinical summaries
  • Lab Results
  • Generate patient list
  • Patient reminders

What stays?  Ten Objectives are required in Modified Stage 2.  All providers, whether they attest to Stage 1 or 2, will report on the exact same measures.  There are some caveats.  If EPs are reporting on Stage 1 in the Modified Stage 2 objectives, they will see lower thresholds for many of the objectives, which is listed in the ten objectives outlined by CMS.

  1. Protect Patient Health
  2. Clinical Decision Support
  3. Computerized Provider Order Entry
  4. Electronic Prescribing
  5. Health Information Exchange
  6. Patient Education
  7. Medication Reconciliation
  8. Patient Electronic Access
  9. Secure Messaging
  10. Public Health Reporting

What’s next? What do healthcare organizations need to consider?

  • Organizations should begin internal communications on the changes contained in this latest ruling. Be clear on what work is no longer required to be performed.  Detailed discussions on what items remain will need to take place.  For many organizations, there may be discussion around maintaining workflows for measures such as providing a clinical summary or sending patient reminders and the value added along with detailed directions to end users.  Organizations will need to consider any configuration changes based on these decisions (for example, if an EHR has alerts for certain items such as vitals or demographics, should they remain enabled?).
  • Once modifications are completed, organizations with their own data warehouse (EDW) will need to ensure reports are updated and validated to capture the correct metrics for the 90-day reporting period.
  • 2016 and 2017 will be a full calendar reporting period for all EP’S unless newly attesting for the first time for MU. Organizations will need to have close monitoring throughout next year to ensure providers stay on track with the new measures and quickly identify any poor performers for early remediation.

As a reminder, PQRS is still a full calendar year reporting period for 2015.  Organizations will need the capability to pull those metrics for the full calendar year for 2015 to avoid penalties in payment year 2017.  If you have questions on MU, PQRS, or other incentive programs such as Medicare Chronic Care Management and how it may impact your organization, please feel free to contact us at, we’d be happy to answer your questions.



You converted to a new EHR mid-year….now what?


 A few weeks ago, I had the pleasure of attending the Healthcare Analytics Summit hosted by Health Catalyst. As a data nerd, I attended out of interest for what is going on in the industry, specifically what initiatives health care systems around the country are currently involved in, and the challenges they are facing.

For the past few years at Galen, I’ve been performing data conversions for clients from one Electronic Health Record (EHR) to another. A recurring issue that I heard a few times during the Summit is that sometimes health systems need to perform mid-year data conversions from one system to a new system, which made year end reporting for quality initiative programs from the legacy system challenging. Some systems with their own Enterprise Data Warehouse (EDW) were able to incorporate the legacy data into their existing EDW, saving them hundreds of man hours of physically going through the records to find patients that meet the criteria.

But some of you don’t have the luxury of a fully functional EDW. And many of you are acquiring practices left and right. Incorporating the data from these legacy systems into your new or existing EHR is an exhaustive process in itself. Testing the data imports, managing timelines, training staff on a new system. It can be daunting.


Last year Galen performed many data conversions from a variety of source systems. The data that we extract as part of the conversion process is reportable and can be used for a number of reporting initiatives. Although they aren’t technically part of your hospital system, your conversion tech and conversion analysts know your data very well by the end of a conversion. We often work with staff in your hospital to understand workflows. We understand that specialty practices have different types of data and different types of needs than primary care practices. We work so closely with your data for months at a time that it sometimes feels as if we are actually employees of your health care organization.

The thought struck me during the Summit – why not utilize the data that was extracted for the conversion in order to assist in your reporting needs for your quality initiatives? Like I stated above, by the end of the conversion, your tech is going to understand your data really well, and most importantly, have access to it. For conversions, some of the most commonly extracted items include problems, medications, allergies, appointments, smoking history, vital signs, lab and imaging results, visit notes, health maintenance history and immunizations. On top of these items, we can also extract any items that you might need for quality initiative reporting at the same time that we are performing the extraction for the data conversion. For example, in the demographic extract, we can extract race, which might not necessarily be part of the conversion efforts, but something simple for us to add into the extract that will go a long way in helping you report for Meaningful Use.

We can help you. If you are one of our current or past conversion clients, contact us to see how we can work with you. Galen also offers archival solutions, de-migration and conversion services as well as a variety of reporting offerings to meet your quality initiative reporting measures as well as your own internal needs.

Top 10 Recent Quotes on Healthcare Interoperability

Much print has been dedicated to interoperability over the past several months. At issue is whether the government (ONC) should attempt to solve healthcare interoperability or continue the course and let the market solve it (or perhaps some in between). We will be discussing this issue with our partners at our annual GPAC event next week in Boston. To prime the discussion – and as part of our interoperability blog series – we present the top 10 recent quotes on the issue:

  1. Interoperability may not have gotten enough attention in the early days of Meaningful Use’s electronic health records (EHR) gold rush, but it’s now taking center stage as healthcare providers, government agencies, vendors, and committees consider how to support the exchange of data easily and securely. It’s very easy to point fingers at folks. People underestimate how challenging this work is,” Sawyer told InformationWeek. “I think the vendors are being cautious before spending lots of research and development money before a standard is more clearly defined.

    -Alison Diana, Information Week, “Healthcare Interoperability: Who’s The Tortoise?”

  1. If Big Data is the new oil in healthcare, clinical business intelligence is the refinery.

    -Brendan Fitzgerald, HIMSS Analytics, “Infographic: The future of clinical & business intelligence in healthcare”

  1. Congress doesn’t think that the marketplace has created the interoperability it thought it was mandating in the HITECH Act. The right question is: How do we ensure that patients, clinicians and caregivers all have read and write access to a patient’s longitudinal health record in real time? More generically, how do we ensure that the right information gets to the right person at the right time?

    -Flow Health Blog, “Beyond Interoperability”

  1. “information blocking” – I believe this concept is like the Loch Ness Monster, often described but rarely seen.   As written, the information blocking language will result in some vendors lobbying in new political forums (Federal Trade Commission and Inspector General) to investigate every instance where they are getting beaten in the market by other vendors.  The criteria are not objective and will be unenforceable except in the most egregious cases, which none of us have ever experienced. We are in a time of great turmoil in healthcare IT policy making.   We have the CMS and ONC Notices of Proposed Rulemaking for Meaningful Use Stage 3, both of which need to be radically pared down.   We have the Burgess Bill which attempts to fix interoperability with the blunt instrument of legislation.  Most importantly we have the 21st Century Cures Act, which few want to publicly criticize.   I’m happy to serve as the lightening rod for this discussion, pointing out the assumptions that are unlikely to be helpful and most likely to be hurtful

    -John Halamka, Life as a Healthcare CIO Blog, “21st Century Cures Act”

  1. The good people in Congress recently asked ONC: When it comes to the nationwide roll-out of a connected health IT system, are we getting our 28 billion dollars’ worth?

    -HealthBlawg “Locked Down or Blocked Up? ONC Report on Health Information Blocking”

  1. The bill abolishes theHealth IT Standards Committee and proposes to have the work of developing interoperability standards contracted out though usual procurement channels, and reviewed and approved by NIST and the Secretary ofHHS in addition to ONC. It also requires attestations by EHR vendors as to their products’ compliance with the interoperability standard, and it calls for the creation of a federal website that will have full transparent pricing for every certified EHR (and its components and interfaces) 

    -David Harlow, JD MPH, Principal, The Harlow Group LLC, “Whither Interoperability”

  1. The U.S. healthcare stakeholders include patients and individual physicians. Unfortunately, these two stakeholder groups are seldom represented in technical standards organizations and, more importantly, have almost no purchasing power when it comes to electronic health records or health information technology. This contributes to the slow rate of progress and has created significant frustration among both patients and physicians. The beauty of patient-driven interoperability is that ancillary infrastructure is helpful but not mandatory. As with auto-pay transactions with your bank, directory services are not required and certificate authorities are already in place. Certification tests would still be needed but the the Internet provides ample examples of open tests and self-asserted certification that would bypass most of the delays associated with legacy methods.

    -Adrian Gropper, MD, The Health Care Blog, “Patient-Driven Interoperability”

  1. I believe that the sufficient conditions for interoperability include the following:
    *A business process must exist for which standardization is needed. As Arien Malec put it recently, ‘SDOs don’t create standards de novo. They standardize working practices.’
    *A proven standard then needs to be developed, via an iterative process that involves repeated real-world testing and validation.
    *A group of healthcare entities must choose to deploy and use the standard, in service of some business purpose. The business purpose may include satisfying regulatory requirements, or meeting market pressures, or both.
    *A ‘network architecture’ must be defined that provides for the identity, trust, and security frameworks necessary for data sharing in the complex world of healthcare.
    *A ‘business architecture’ must exist that manages the contractual and legal arrangements necessary for healthcare data sharing to occur.
    *A governance mechanism with sufficient authority over the participants must ensure that the network and business frameworks are followed.
    *And almost no healthcare standard can be deployed in isolation, so all of the ancillary infrastructure (such as directory services, certificate authorities, and certification tests) must be organized and deployed in support of the standard.

    -John Halamka, Life as a Healthcare CIO Blog, “Standards Alone are not the Answer for Interoperability”

  1. Sometimes things are so ill-advised, in hindsight, that you wonder what people were thinking. That includes HHS’ willingness to give out $30 billion to date in Meaningful Use incentives without demanding that vendors offer some kind of interoperability. When you ponder the wasted opportunity, it’s truly painful. While the Meaningful Use program may have been a good idea, it failed to bring the interoperability hammer down on vendors, and now that ship has sailed. While HHS might have been able to force the issue back in the day, demanding that vendors step up or be ineligible for certification, I doubt vendors could backward-engineer the necessary communications formats into their current systems, even if there was a straightforward standard to implement — at least not at a price anyone’s willing to pay

    Anne Zieger, EMR & EHR, “HHS’ $30B Interoperability Mistake”

  1. This is one of the most public and noteworthy conversations that has taken place on the issue of patient identification. It’s time that Congress recognize the inability to accurately identify patients is fundamentally a patient safety issue.

    Leslie Krigstein, CHIME Interim Vice President of Public Policy,  EMR & EHR News Blog,  “Patient ID Highlighted as Barrier to Interoperability during Senate HELP Hearing”


Free Webcast on Galen’s Note Form Reporting Solution

Noteform reporting 1

Please join us for a free webcast on Wednesday, July 15th at 2pm EST as we discuss an overview of Galen’s Note Form Reporting solution and the new charge automation functionality available within the Note Form Reporting software. We will also cover client success stories of how clients are using this solution for efficient and successful PCMH, Medicare Advantage, and ACO documentation and tracking.

To register, please visit:



For the Users, By the Users: ERUG 2015


The 5th Annual Allscripts Eastern Region Users Group Summer Conference was held last week at the posh, “boutique design” W Hotel in downtown Atlanta, GA. True to its motto, “For the Users, By the Users,” the ERUG conference proved to be a collaborative and informative educational and networking event for clients and vendors alike.

The educational sessions focused on topics such as patient tracking, optimization, ICD-10, and patient engagement. In addition, Allscripts shared their roadmap and updates for the TouchWorksTM product and provided color around services and solutions including EHR upgrades, mobility, Meaningful Use reporting, clinical notes strategy, and architecture advisory. We also had meaningful discussions with clients on topics including EHR downtime, custom interface development and support, CIE migrations, and application portfolio management.

Galen’s Vice President of Clinical Solutions, Rita Owens, presented on Galen’s Note Form Reporting solution, which aides TouchWorksTM V11 Note Form users in efficient and successful PCMH, Medicare Advantage, and ACO documentation and tracking. Rita also shared new Note Form Reporting charge automation functionality and recent client success stories.

Of course, a conference wouldn’t be complete without some fun! Galen sponsored both the networking reception Wednesday evening and the Cirque du Soleil ERUG member appreciation event on Thursday evening at Opera Nightclub.

Special recognition to ERUG President Jeff Ciccanti and the rest of the board for their tireless efforts in organizing a spectacular conference and ensuring it went off without a hitch.


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