CMS rule to help providers make use of Certified EHR Technology

Rule also proposes to extend Stage 2 of the EHR Incentive Programs through 2016

Today, HHS published a new proposed rule that would provide eligible professionals, eligible hospitals, and critical access hospitals more flexibility in how they use certified electronic health record (EHR) technology (CEHRT) to meet meaningful use. The proposed rule, from the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC), would let providers use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for the EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs.

Beginning in 2015, all eligible hospitals and professionals would still be required to report using 2014 Edition CEHRT. Since the Medicare and Medicaid EHR Incentive Programs began in 2011, more than 370,000 hospitals and professionals nationwide have received an incentive payment.

“We have seen tremendous participation in the EHR Incentive Programs since they began,” said CMS Administrator Marilyn Tavenner. “By extending Stage 2, we are being receptive to stakeholder feedback to ensure providers can continue to meet meaningful use and keep momentum moving forward.”

The proposed rule also includes a provision that would formalize CMS and ONC’s previously stated intention to extend Stage 2 through 2016 and begin Stage 3 in 2017. These proposed changes would address concerns raised by stakeholders and will encourage the continued adoption of Certified EHR Technology.

“Increasing the adoption of EHRs is key to improving the nation’s health care system and the steps we are taking today will give new options to those who, through no fault of their own, have been unable to get the new 2014 Edition technology, including those at high risk, such as smaller providers and rural hospitals,” said Karen DeSalvo, M.D., M.P.H, M.Sc., national coordinator for health information technology.

Proposed changes to meaningful use timeline

First Payment Year	Stage of Meaningful Use
	2011	2012	2013	2014	2015	2016	2017	2018	2019	2020	2021
2011	1	1	1	2	2	3 -> 2	3	TBD	TBD	TBD	TBD
2012		1	1	2	2	3 -> 2	3	TBD	TBD	TBD	TBD
2013			1	1	2	2	3	3	TBD	TBD	TBD
2014				1	1	2	2	3	3	TBD	TBD
2015					1	1	2	2	3	3	TBD
2016						1	1	2	2	3	3
2017							1	1	2	2	3
						Current Stage 2 Start Date
							Proposed Stage 3 Start Date

	You would be able to attest for MU:
If you were scheduled to demonstrate:	Using 2011 Edition CEHRT to do:	Using 2011 & 2014 Edition CEHRT to do:	Using 2014 Edition CEHRT to do:
Stage 1 in 2014	2013 Stage 1 objectives and measures	2013 Stage 1 objectives and measures -or- 2014 Stage 1 objectives and measures	2014 Stage 1 objectives and measures
Stage 2 in 2014	2013 Stage 1 objectives and measures	2013 Stage 1 objectives and measures -OR- 2014 Stage 1 objectives and measures -OR- Stage 2 objectives and measures	2014 Stage 1 objectives and measures -OR- Stage 2 objectives and measures

Changes at Health IT Policy Committee and FDASIA Update

There were some changes announced in the membership of the Health IT Policy Committee (HITPC) at the May 5, 2014 meeting. Three departing members who have been with the HITPC from the beginning are:

• Neil Calman, M.D., CEO of the Institute for Family Health, one of the largest networks of community health centers in New York State;
• Judy Faulkner, CEO of Epic Systems;
• Art Davidson, M.D., director of Public Health Informatics for Denver Public Health

The three new members replacing them are:

• Christoph U. Lehmann, M.D., the founding medical director of the American Academy of Pediatrics Child Health Informatics Center and a professor in Pediatrics and Biomedical Informatics at the Monroe Carell Jr. Children’s Hospital at Vanderbilt University in Tennessee, as an expert on vulnerable populations;
• Neal Patterson, co-founder, chairman and CEO of Cerner Corp. as a vendor representative;
• Kim J. Schofield, health educator and advocacy chair for the Lupus Foundation of America’s Georgia Chapter, representing consumers and patients.

Notable is the departure of the Epic CEO, Judy Faulkner, being replaced by the Cerner CEO, Neal Patterson as a vendor representative. They also received an update from the FDASIA workgroup.

HIT Policy Committee FDASIA Update

Next weeks very important Proposed Risk-Based Regulatory Framework and Strategy for Health IT Workshop convened by the FDA should provide even greater clarity into the development of the Health IT Safety Center and important development of potential regulations for software which falls into the Health Management Functionality category.

Karen DeSalvo also announced during the meeting that new workgroups are being formed. The ONC is Congressionally mandated to update its Health IT strategic plan, and will be adjusting its organizational structure and creating new workgroups to align with overall goals and available resources. The categories for new workgroups are being formed along:

• Health IT Strategic Planning
• Advanced Health Models and Meaningful Use
• Interoperability & Health Information Exchange (HIE)
• Health IT Implementation, Usability and Safety
• Privacy and Security
• Consumer

The HIT Strategic Planning and Interoperability & HIE Workgroups will begin forming first, followed by the Advanced Health Models and Meaningful Use and Health IT Implementation, Usability and Safety Workgroups later this year. For now the activities of the Privacy/Security and Consumer groups will continue as planned.

The Health Data Analytics Hype Cycle

At the recent Healthcare Think Tank,  At the Crossroads: Technology and Transformation in Healthcare, sponsored by Dell, we had some very interesting discussions on a wide variety of topics. I will be highlighting some of the topics we covered in a few posts over the next couple months. At the first Think Tank three years ago at the HIMSS conference in Las Vegas I said that "Big data is the next big thing in healthcare." One of the hot topics discussed at this years Think Tank springing out of the HIMSS conference was health data analytics. I have also said that data analytics is the third wave of health IT that we're undergoing, after data capture and data sharing. It is this component - having robust analytics capabilities - that will provide the return on investment for the massive amount of government and private sector spending on health IT in the past few years.

During the session where we discussed data analytics Dan Munro, a contributor at Forbes, brought up the distinction between predictive analytics, proscriptive analytics, and persuasive analytics. Moving quickly past predictive analytics, which everyone seems to be working on, and into proscriptive analytics where actionable information is obtained and used. Then he introduces the notion of persuasive analytics. But sometimes the jargon we use can stand in the way when terms like "big data" and "analytics" become buzz words and lose some of their effectiveness. Dilbert also addressed this issue in the January, 9 2013 comic strip

Dan discussed the ability that retail giant Target has in consumer analytics, and went on to highlight the Gartner hype cycle and quickly walked through the Gartner Hype Cycle methodology which gives a good view of how a technology or application will evolve over time. According to Gartner each of the Hype Cycles drills down into the five key phases of a technology’s life cycle:

• Technology Trigger: A potential technology breakthrough kicks things off. Early proof-of-concept stories and media interest trigger significant publicity. Often no usable products exist and commercial viability is unproven.
• Peak of Inflated Expectations: Early publicity produces a number of success stories—often accompanied by scores of failures. Some companies take action; many do not.
• Trough of Disillusionment: Interest wanes as experiments and implementations fail to deliver. Producers of the technology shake out or fail. Investments continue only if the surviving providers improve their products to the satisfaction of early adopters.
• Slope of Enlightenment: More instances of how the technology can benefit the enterprise start to crystallize and become more widely understood. Second- and third-generation products appear from technology providers. More enterprises fund pilots; conservative companies remain cautious.
• Plateau of Productivity: Mainstream adoption starts to take off. Criteria for assessing provider viability are more clearly defined. The technology’s broad market applicability and relevance are clearly paying off.

In it's recent report "Top Actions for Healthcare Delivery Organization CIOs, 2014: Avoid 25 Years of Mistakes in Enterprise Data Warehousing" Gartner makes the point that healthcare has a compelling need to use more information, and use it better. Enterprise data warehousing (EDW) is an important analytics component addressing various needs: The integrated clinical and business EDW; EHR; claims/revenue cycle; ERP; cost accounting; and patient satisfaction data.

Now that we have widespread adoption of EHRs, providers should leverage EHR data by advancing retrospective and real-time analytics because the superior use of analytics will be a dominant factor for success over the next 4-5 years. As a gushing of new data streams are on the way, CIOs cannot afford the cost, time or agony of repeating classic blunders (avoiding the "nine fatal flaws" in business operations improvement), just to get to an integrated warehouse with clinical data. They point out the Integrating business/financial and clinical data into an effective EDW is the top new healthcare IT initiative and will be necessary to succeed.

Over half of the early stage initiatives Gartner is tracking are either pure analytics (green) or contain an analytics component (yellow).

Hype Cycle for Healthcare Provider Applications, Analytics and Systems, 2013

Source: Gartner (February 2014)

In it's report Gartner stresses the need for strong information governance and the importance of data quality. They also warn not to overestimate the value of a commercial vendor's data model, to avoid underscoping the total effort and personnel needs, and never treat an EDW as just another module from the EHR vendor. They acknowledge the deep need for analytics solutions and show that the shift in payment models fueling this need includes both incentive-based and risk-reward payment models.

In the September 2012 Electronic Healthcare, a new eight-stage Analytics Adoption Model similar to the seven-stage EMR Adoption Model (EMRAM) from HIMSS Analytics was proposed. This model is being widely used to help analytics companies to inform their strategy and product roadmap. An excellent whitepaper that explains the model in greater detail is available HERE. Now HIMSS Analytics has partnered with the International Institute for Analytics (IIA) to create a benchmarking survey designed to measure and score clinical business intelligence and analytics maturity in healthcare organizations. They will use the DELTA model (data, enterprise-focus, leadership, targets and analysts) to assess analytic capabilities. The survey measures 33 competencies based within the DELTA model framework to assess the importance of each competency to the organization and the organization’s effectiveness in performing each competency.

As the Gartner report cautions over-reliance on vendor data models, one thing that I am interested in seeing is: Who will win the day in the exploding health data analytics market, EHR vendors or specialty analytics vendors? I do not think that specific EHR vendors, while they hold a great deal of data and are a critical piece of the puzzle, have the ability to aggregate all of these disparate data sources that will enable them to provide a comprehensive solution. So it will likely take partnerships between EHR vendors, HIE vendors, and analytics vendors to provide the true value that health systems will need to thrive in a transformed healthcare marketplace.

Ukrainian Situation is Evolving

Off topic for this blog, but a very disturbing story has emerged in the Ukraine that I think deserves a lot of attention. It is being reported that leaflets with instructions to "register" were handed to Jews as they left synagogue following holiday prayers. On the first day of Passover this week, three armed men in the eastern Ukrainian province of Donetsk distributed flyers warning Jews to “register” themselves and their assets with the new pro-Russian government. The leaflets bore the name of Denis Pushilin, who identified himself as chairman of "Donetsk's temporary government," and were distributed near the Donetsk synagogue and other areas. In interviews with local media Mr. Pushilin rejected the content of the flyers, and also denied that his organization was behind their printing. "Some idiots yesterday were giving out these flyers in targeted areas," he said, claiming that he had never himself used the "people’s governor" title.

According to Ynet's English report, the leaflet, written in Russian, reads:

"Dear Ukraine citizens of Jewish nationality. Due to the fact that the leaders of the Jewish community of Ukraine supported Bendery Junta," a reference to Stepan Bandera, the leader of the Ukrainian nationalist movement which fought for Ukrainian independence at the end of World War II, "and oppose the pro-Slavic People's Republic of Donetsk, (the interim government) has decided that all citizens of Jewish descent, over 16 years of age and residing within the republic's territory are required to report to the Commissioner for Nationalities in the Donetsk Regional Administration building and register."

Steps are being taken to de-escalate the crisis. The United States, Russia, Ukraine and the European Union reached an agreement at a meeting in Geneva, Switzerland that calls for armed pro-Russian bands to give up the government buildings they have seized in eastern Ukraine and outlines other steps. But the agreement, described in a joint statement, does not specifically require Russia to remove the approximately 40,000 troops it has on Ukraine’s border as President Obama has demanded.

According to a report in The New Republic the Donetsk Jewish community dismissed this as "a provocation," which it clearly is. "It's an obvious provocation designed to get this exact response, going all the way up to Kerry," says Fyodr Lukyanov, editor of Russia in Global Affairs. "I have no doubt that there is a sizeable community of anti-Semites on both sides of the barricades, but for one of them to do something this stupid—this is done to compromise the pro-Russian groups in the east."

The situation with the leaflets was also discussed at the meeting in Geneva. Secretary of State John Kerry stated Jews in one Ukrainian city were were sent notes "indicating that they have to identify themselves as Jews."

"In the year 2014, after all of the miles traveled and all of the journey of history, this is not just intolerable, it's grotesque. It is beyond unacceptable. And any of the people who engage in these kinds of activities — from whatever party or whatever ideology or whatever place they crawl out of — there is no place for that."

All parties at international talks on the Ukraine crisis Thursday unanimously condemned anti-Semitism and other forms of religious intolerance, Kerry said.

Also, members of the Russian Orthodox church in Ukraine were recently threatened that they would be attacked in the coming days by members of the Ukrainian Orthodox Church, Kerry said.