Foundations for Achieving Meaningful Use and Breaking Down EHR Barriers

Transcription

1 Foundations for Achieving Meaningful Use and Breaking Down EHR Barriers Prepared by: Coker Group Physicians Institute 1849 The Exchange Atlanta, GA 30339

2 A BOUT THE PHYSICIANS INSTITUTE The Physicians' Institute (a nonprofit subsidiary of the Medical Association of Georgia) has become a national leader in developing and managing collaborative educational projects that provide managed educational grants and projects to Continuing Medical Education (CME) providers, with a focus on outcomes-based and performance improvement activities. The Physicians' Institute currently has had collaborative relationships with 16 state medical societies and other organizations representing about 1500 CME providers. The overall aim of the Physicians Institute Collaborative Model is to improve the quality and impact of local CME. These collaborations give the Physicians Institute tremendous reach into locallyprovided CME based on locally identified professional practice gaps in community hospitals, health systems, and state chapters of specialty societies. If it is true that all CME is local, then this collaborative model is ideal for CME. The Physicians Institute focuses on a unique model of pooled funding, the Collaborative Grants Model. This model features secondary grants to CME providers, integrated evaluation services, educational design consultation, project management, and aggregate outcome reports. Depending upon the project, standardized curriculum, monographs, video-based content including simulated patients, and audio-visual services may be provided. The Collaborative Grants Model has been: Vetted and approved by the Accreditation Council for CME; Awarded the Member Sections Great Idea Award (2009) by the Alliance for CME; and Awarded the Best Collaboration Award (2009) by the Alliance for CME. To date, the Physicians Institute has developed and managed more than fifteen distinct Collaborative Grants initiatives which have included sixteen Collaborative organizations, representing 253 CME projects located in 21 states in the following clinical areas: Depression and Anxiety; Cardiovascular Risk Factors, Diabetes, Tobacco Cessation, COPD, Alzheimer s and other Dementias, Chronic Pain, Pneumonia, Rheumatoid Arthritis, Low Back Pain, Stroke, Blood Management, and Sepsis. Aggregate reports and outcomes information are available for completed projects. Recognizing the need for quality, in-depth training and education for health care providers and CME professionals, the Physicians Institute is also focusing on Process Improvement Training (PIT). The Physicians Institute s PIT training modules include CME Outcomes, Performance Improvement, and Motivational Interviewing. The Physicians Institute offers a website that includes an online grants management system, educational videos, and related resources at 2 P a g e

3 INTRODUCTION If you walk into any forward thinking healthcare practice, you will quickly discover that the topic of change is on everyone s mind. From the front office to the back office, the nurses pod to the physician s desk, the waiting room to the examination room (yes, even the patient), everyone is changing the way they view healthcare information. The change is in the adoption of clinical information technology and the ability for providers to use an Electronic Health Record (EHR) in a meaningful way to improve quality of care for their patients. Improvement in the quality of patient outcomes and coordination of care are driving forces of the Health Information Technology for Economic and Clinical Health (HITECH) Act. Incentivized by the American Recovery and Reinvestment Act (ARRA) of 2009, under the Medicare or Medicaid provisions, healthcare organizations are feverishly making strides to stay compliant and competitive in the marketplace by adopting healthcare information technology. The energy that fuels the initiative is often exciting and electrifying, but the vigor can also languish when barriers appear. This paper summarizes key components of the HITECH Act, respective of the three stages required to achieve meaningful use; it also offers strategies and tips for successful procurement and implementation of an EHR. The Physicians' Institute for The energy that fuels the initiative is often exciting and electrifying, but the vigor can also languish when barriers appear. Excellence focuses on activities to support physicians, including educational programs and tools, in addition to sponsoring applied projects to improve the effectiveness of practices and processes in the physician office. 3 P a g e

4 HITECH ACT REVIEW Through the American Recovery and Reinvestment Act (ARRA) of 2009, the Health Information Technology for Economic and Clinical Health Act (HITECH ACT) allocates approximately $20 billion for health information technology (HIT) projects. These investments will improve technologies and standards that range from rural broadband infrastructure upgrades, standardization for a nationwide health information network, and incentives for physicians and hospitals aspiring to procure Electronic Health Record (EHR) technology. The HITECH Act also implicates changes to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) as well as Meaningful Use (MU) measures in regards to data security. According to CMS, MU is the use of certified electronic health record technology to: (1) Improve quality, Organizations may be required to significantly safety, efficiency, and reduce health disparities, (2) Engage upgrade their patients and family, (3) Improve care coordination, and technology population and public health, and (4) maintain privacy and infrastructure to comply security of patient health information. These objectives will be with recent changes discussed later in this document, however the most significant during the procurement HIPAA changes relate to the administrative, physical, and of EHR technology. technical safeguard requirements and security regulations to business associates contracted by covered entities. To ensure protection of patient data, written privacy and security policies must be enforced with reference to personal health information (PHI). Organizations may be required to significantly upgrade their technology infrastructure to comply with the recent changes during the procurement of EHR technology. Failure to comply with these policies may result in civil and criminal penalties outlined in Figure 1. Many organizations overlook the need to secure PHI and primarily focus on the clinical reporting requirements to receive their stage one reimbursement incentives. However, receiving a penalty for knowingly or unknowingly violating these policies may negate the incentive received to adopt HIT. 4 P a g e

5 Figure 1 i : HIPAA Violations and Penalties HIPAA Violation Minimum Penalty Maximum Penalty Individual did not know (and by exercising reasonable diligence would not have known) that he/she violated HIPAA HIPAA violation due to reasonable cause and not due to willful neglect HIPAA violation due to willful neglect but violation is corrected within the required time period HIPAA violation is due to willful neglect and is not corrected $100 per violation, maximum of $25,000 for repeat violations (Note: maximum that can be imposed by State Attorneys General regardless of the type of violation) $1,000 per violation, maximum of $100,000 for repeat violations $10,000 per violation, maximum of $250,000 for repeat violations $50,000 per violation, maximum of $1.5 million $50,000 per violation, maximum of $1.5 million $50,000 per violation, maximum of $1.5 million $50,000 per violation, maximum of $1.5 million $50,000 per violation, maximum of $1.5 million FUNDING AND HIT INCENTIVES HIT and EHRs are considered essential tools for improving patient health outcomes and achieving quality and efficiency within the health care system in the United States. Within the HITECH incentive program, certified EHR technology must be used in a meaningful way. This is one element of a large scale HIT network aimed to reform the healthcare system and improve quality, efficiency, and patient safety within the U.S. health care system. 5 P a g e

6 In July 2010, the Centers for Medicare and Medicaid (CMS) released the final rule for MU. However, with competing views and considerations, the MU definitions are expected to mature over time. At the time of this writing, the stages are targeted to achieve the following goals within the three stages outlined in Figure 2. Figure 2 ii : Three Stages of Meaningful Use Stage 1 Data Capture and Sharing ( ) Stage 2 Advance Clinical Processes (2013) Stage 3 Improved Outcomes (2015) Electronically capture information in a structured format Track key clinical conditions based on the electronically captured data Utilize electronically captured data to conduct coordination of care Use of clinical decision support tools to assist in disease and medication management Engage patients and families via EHRs Report clinical quality measures and public health information Continuous use of HIT for quality improvement at the point of care Exchange of information via computerized provider order entry (CPOE), electronic transmission of diagnostic test results (lab, radiology, imaging, nuclear medicine, and others) As CMS notes in the Rule, Stage 2 Meaningful Use requirements will include rigorous expectations for health information exchange, including more demanding requirements for e-prescribing and incorporating structured laboratory results and the expectation that providers will electronically transmit patient care summaries to support transitions in care across unaffiliated providers, settings, and EHR systems. Promoting improvements in quality, safety, and efficiency leading to improved health outcomes Focusing on decision support for national high priority conditions Patient access to self management tools, and Access to comprehensive patient data through robust, patientcentered information exchange and improving population health 6 P a g e

7 BREAKING THROUGH THE BARRIERS Implementing HIT has been challenging to an industry that has been late to adopt information technology as a tool to improve clinical and operational efficiencies. Cost and disruption to the organization were top responses by providers who have experienced the transition. Considering the barrier of cost, it is important to note that stimulus incentives offered by HITECH are not the only return on investment an organization should realize when deciding to move to an EHR. Increased revenue through the accuracy of coding and physician productivity are two areas in which the EHR will provide significant ROI. To offset the initial upfront cost of procuring the technology, mutually beneficial terms should be tied to any contract between the organization and EHR vendors. Partnering with firms such as The Coker Group to represent providers and negotiate terms is an advantage in lowering the initial upfront cost to adopting HIT. This strategy keeps EHR vendors contractually obligated to the successful implementation of the EHR. It is also a key component of the second barrier, disruption to the organization, because the vendor now becomes a stakeholder and partner during the transition and successful adoption of the EHR. The disruption to the organization is rooted in the fact that human beings are naturally opposed to change. Change is often a result of an external force that compels the reassessment of how processes are performed. The challenge for healthcare organizations is not only the use of the EHR by providers, but also the ability to use the EHR in a meaningful way. The HITECH Meaningful Use objectives through the year 2015 are defined in four key areas for health outcomes policy priorities, which are: Improve Quality, Safety, Efficiency, and Reduce Health Disparities Engage Patients and Families Improve Population and Public Health Ensure Adequate Privacy and Security Protection for Personal Health Information 7 P a g e

8 Each of these stages are broken down into core goals and spread out over a long-term plan for organizations to achieve. (See Appendix A) So, how are these goals achieved within an industry that has been late to adopt information technology as a tool for better clinical outcomes? The ability to address this concern is rooted in a phased approach of deploying structure to three areas of change within your organization: Technology, People, and Processes. Like a scalpel, technology is a tool that must stay sharp and work with precision. Dull outdated technology is not a good foundation upon which to build transition. The practice or organization must adopt technology that is intuitive and easy to use by the physician. Clearly, the EHR will be in the hands of physicians and must be embraced during the transition. In terms of people, everyone who touches the paper chart should be involved in the development of the EHR project. Physicians are imperative to the success of the adoption of their new tool. The role of a Physician Champion should be defined as Technology is a tool that must stay sharp and work with precision. the individual who will be relied upon as the voice of the physician body within the organization. While addressing their concerns, the Physician Champion must be cognitive of the standardization required by the use of technology while balancing the clinical requirements of his or her peers. The support staff should be included, as well. Nurses, medical assistants, and medical technicians should also be delegated responsibilities throughout the project to ensure inclusion and feedback during the decision-making process. Outside organizations and consultants who specialize in Healthcare Technology are also a great resource. While recognized as proponents of change, firms such as The Coker Group offer non biased objective strategies for healthcare organizations approaching the adoption of healthcare technologies. 8 P a g e

9 With a solid foundation rooted in the people and technology that support the pending EHR transition, developing processes to manage the change becomes a valuable advantage in a successful implementation. Having a process in place that identifies change and the impact it has on the organization reduces the concerns an fears that paralyzes healthcare practices from achieving success. A change control committee made up of key stakeholders and subject matter experts should be established to outline priority improvement goals by clearly identifying the effect the EHR has on their area of knowledge. The size of the organization will determine the range and extent of the analysis needed to qualify and quantify the impact the change has on the organization. However this approach should not be overlooked. CONCLUSION Through the HITECH Act, technology is the fundamental tool for the improvement of patient outcomes as well as the development of efficiencies within the U.S. healthcare system. The large emphasis on the use of technology to automate patient records is placing a burden on an industry that has succeeded with the absence of HIT for the majority of its existence. It is for this reason that healthcare organizations should place specific attention to the procurement, implementation, and constant change that is incumbent with the ongoing use of HIT. Note: For more information on how to successfully implement EHR technologies please contact Gabriel Harry at gharry@cokergroup.com. i American Medical Association, HIPAA Violations and Enforcements. Accessed on 12/19/2011 at assn.org/ama/pub/physician-resources/solutions-managing-your-practice/coding-billing-insurance/hipaahealth-insurance-portability- accountability-act/hipaa-violations-enforcement.page ii iicenters for Medicare & Medicaid Services, Medicare & Medicaid EHR Incentive Program Final Rule: Implementing the American Recovery & Reinvestment Act of Accessed on 12/21/2011 at 9 P a g e

10 This checklist has been provided as complimentary tool from Coker Group. Appendix A: Stage 1 Meaningful Use Checklist Priority primary care providers (PPCPs) are physicians and health care professionals with prescriptive privileges. PPCPs can be physicians, physician assistants, nurse practitioners, and nurse midwives. Primary care encompasses family medicine, geriatrics, OB/GYN, general or internal medicine, adolescent medicine, and pediatrics. I. Must meet 15 of the core meaningful use (MU) objectives: Computerized physician order entry (CPOE) for >30% of unique patients with at least one medication E Prescribing (erx) for > 40% of the permissible scripts for patients for whom the EHR was used Report ambulatory clinical quality measures to CMS/States on all your patients in the EHR Implement one clinical decision support rule Provide >50% patients seen with the EHR, an electronic copy of their health information Provide > 50% of patients seen with the EHR, a clinical summary within 3 business days Drug drug and drug allergy interaction checks turned on Record demographics on >50% of all patients seen: language, gender, race, ethnicity, DOB Maintain an up to date problem list of current and active diagnoses on >80% of all patients seen > 80% of all patients seen have at least one entry as structured data in the medication list > 80% of all patients seen have at least one entry as structured data in the medication allergy list > 50% of all patients age 2 and above seen with the EHR have vital signs Record >50% of patients smoking status for patients 13 years or older and seen with the EHR. Capability to exchange key clinical information among providers of care. Ensure adequate privacy and security protections for personal health information. II. Must meet any five of the Meaningful Use Menu Set Objectives listed below*: Implement drug formulary checks with access to at least one internal or external drug formulary 40% of clinical lab test results are stored as structured data for patients seen with the EHR Generate at least one report of patients by specific conditions to use for quality improvement > 20% of all unique patients 65 years or older or 5 years old or younger seen with the EHR were sent an appropriate reminder per patient preference for preventive/follow up care > 10% of all patients seen are provided with timely electronic access to their health information. > 10% of all patients seen are provided patient specific education resources through the use of certified EHR technology. Performs medication reconciliation on > 50% of transitions of care or relevant encounters for EHR patients. EP who transitions or refers the patient seen with the EHR to another setting of care will provide a summary of care record for > 50% of transitions and referrals. Perform at least one test of certified EHR technology s capability to submit electronic data to immunization registries/systems. * Perform at least one test of certified EHR technology s capability to provide electronic syndromic surveillance data to public health agencies. * *At least 1 public health objective must be selected 1 P a g e

11 This checklist has been provided as complimentary tool from Coker Group. III. Must track the 3 required core Clinical Quality Measures (CQMs) below or the alternatives below on patients: Core Set: Adult weight screening and follow up Hypertension: blood pressure management Tobacco use assessment and intervention Alternative Set: Childhood Immunization Status Influenza Immunization for Patients 50 Years Old Weight Assessment and Counseling for Children and Adolescents IV. Please identify at least 3 additional CQMs from the set of 38 CQMs that you commit to track on your patients Anti depressant medication management: Effective Acute Phase Treatment (b) Effective Continuation Phase Treatment Appropriate Testing for Children with Pharyngiti Asthma Assessment Asthma Pharmacologic Therapy Breast Cancer Screening Cervical Cancer Screening Chlamydia Screening for Women Controlling High Blood Pressure Colorectal Cancer Screening Coronary Artery Disease (CAD): Beta Blocker Therapy for CAD Patients w/ Prior Myocardial Infarction (MI) Coronary Artery Disease (CAD): Drug Therapy for Lowering LDL Cholesterol Coronary Artery Disease (CAD): Oral Anti platelet Therapy Prescribed for Patients with CAD Diabetes: Blood Pressure Management Diabetes: Eye Exam Diabetes: Foot Exam Diabetes: Hemoglobin A1c Poor Control (<8) Diabetic Retinopathy: Documentation of Presence or Absence of Macular Edema and Level of Severity of Retinopathy Heart Failure: ACE Inhibitor or ARB Therapy for Left Ventricular Systolic Dysfunction (LVSD) Heart Failure (HF): Beta Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD) Pneumonia Vaccination Status for Older Adults Heart Failure (HF): Warfarin Therapy Patients with Atrial Fibrillation Initiation and Engagement of Alcohol and Other Drug Dependence Treatment: (a) Initiation (b) Engagement Ischemic Vascular Disease (IVD): Blood Pressure Management Ischemic Vascular Disease (IVD): Complete Lipid Panel and LDL Control Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic Low Back Pain: Use of Imaging Studies Oncology Breast Cancer: Hormonal Therapy for Stage ICIIIC Estrogen Receptor/Progesterone Receptor (ER/PR) Positive Breast Cancer Oncology Colon Cancer: Chemotherapy for Stage III Colon Cancer Patients Prenatal Care: Anti D Immune Globulin Prenatal Care: Screening for Human Immunodeficiency Virus (HIV) Primary Open Angle Glaucoma (POAG): Optic Nerve Evaluation Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate Cancer Patients 2 P a g e

12 This checklist has been provided as complimentary tool from Coker Group. Diabetes: Hemoglobin A1c Poor Control Diabetes: Low Density Lipoprotein (LDL) Management and Control Diabetes: Urine Screening Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care Smoking and Tobacco Use Cessation, Medical assistance: Advising Smokers and Tobacco Users to Quit, Discussing Cessation Medications and Strategies For assistance or questions with achieving Meaningful Use and compliance with ARRA guidelines, please contact Gabriel Harry at or by phone at (770) for a FREE consultation. 3 P a g e