Ensuring EHR compliance for Meaningful Use

Electronic health record (EHR) systems are revolutionizing the collection and standardization of patient medical information. Healthcare practitioners now have patient information readily available, enabling more efficient and accurate care. However, there are still varying views on whether providers feel they are realizing the true value from EHR technology.

Organizations originally put EHRs in place to collect data, but the market has grown more sophisticated, and healthcare reform has shifted the way providers need to operate in a more value-based environment. This requires more than just data collection and is best served by an open, connected community solution – a solution that connects both clinical and financial insights across the entire care community. This type of construction connects all systems, regardless of location or vendor, and delivers a single view of the patient record.

While the market for EHRs is now mature, there is still movement. Some vendors have announced sunset plans due to the challenges of meeting Meaningful Use requirements, which has led to a relatively active replacement market. In addition to this, the healthcare industry is reviewing recent significant regulatory developments from the U.S. Department of Health & Human Services.

Meaningful Use

Meaningful Use sets specific objectives that eligible professionals (EPs) and hospitals must achieve to qualify for Centers for Medicare & Medicaid Services (CMS) Incentive Programs. Meaningful Use requirements intend to:

• Improve quality, safety, and efficiency;
• Reduce health disparities;
• Engage patients and family;
• Improve care coordination; and
• Maintain privacy and security of patient health information.

Elements within the U.S. Department of Health & Human Services proposals are still subject to change, but there are some considerable ideas to process in each of them. Here is a summary of the big three proposed rules from CMS and the Office of the National Coordinator for Health Information Technology (ONC):

CMS: Definitions of Meaningful Use – Changes to Stage 3

It is anticipated CMS will finalize this rule in August or September this year. Focusing heavily on interoperability, it provides the foundation to focus on quality and outcomes-based payment models.¹ It proposes an option in 2017 of moving to Stage 2 or 3, with all participants moving to Stage 3 in 2018. Effectively, CMS would abolish stages at that point. All reporting periods also would become one calendar year.

ONC: Definitions of certifications – Facilitate interoperability

This proposed rule’s main purpose is to improve accessibility and exchange of data with a single certification program that serves several types of programs.² Software certification would no longer be exclusively tied to Meaningful Use under the proposals. This means that certified systems would need to be able to provide functionality that is not only about what Meaningful Use participants are measured on but also that which is helpful to other advanced payment models, such as accountable care organization (ACO) models.

CMS: Meaningful Use modification rules for 2015-17

This rule affects the year 2015, as CMS is suggesting it will finalize the rule in July for the reporting periods. 2015 becomes a 90-day floating reporting period – no matter what stage or year you are in.³ Eligible hospitals would also move to a calendar year, which would give them three extra months this year.

Tips for regulatory success

In processing these three proposed rules, it’s important to understand what steps providers can take even while the government reviews and finalizes the rules. Smart providers know that preparation is the key to success when it comes to regulatory compliance. A few specific action items include:

1. Respond to the public comment. This goes for all proposed rulings and regulations, and it is in the best interest of providers to do so. This can be simply done by visiting the CMS site, cms.gov, and sending comments to the specified address set up under that respective project title. Public comments are highly valuable to the government, and it has been said that this type of comment is the most important they receive.
2. 2015 should be treated as a full year. It is important to not stop demonstrating successes even if the reporting period may only be 90 days. If you do stop trying to achieve these goals, only to return to them later, it’s like jumping off a moving bus and trying to jump back on. The reality is the modification rule is only proposed, so take it as if it is not changing until it’s finished.
3. Get started and never let up on the effort. Be vigilant with patient engagement; it takes time and dedicated effort to build success here.
4. Watch out for workflows involving paper. It’s a good idea for organizations to wean completely off paper-based processes. Remember that giving paper to patients and documenting electronically after the fact will not count.
5. Operate openly. Ensuring you work in an open and connected way with all colleagues will ultimately help you achieve a smoother working system.
6. Fully integrate processes and resources to ensure measurable accountability. To be successful with accountable care delivery models, providers must increasingly align with the health plans that serve their populations. Those who have highly integrated EHRs and practice management systems that allow for open collaboration with their health plans will benefit.

The benefits of achieving Meaningful Use

The proposed rule would reduce required reporting, enabling providers to focus on objectives that support advanced use of EHR technology and quality improvement, including health information exchange. By simplifying the reporting requirements, the proposed rule would enable providers to focus on objectives that support advanced use of EHR technology, including quality measurement and quality improvement.

EHR vendors need to be strategic partners to their clients to maximize the value they are getting from their EHR investments. As platforms, EHRs need to be a care companion to providers, delivering insights and key information in real time to help manage patient care while helping to reduce the cost of care.

The benefits EHRs need to deliver to providers include:

• Providing clinically relevant data at the point of care;
• Improving patient adherence to improve outcomes;
• Giving access to data and insights to drive improvement; and
• Driving action at the point of care by providing information that can change behavior.

Effective compliance can lead to higher-quality data that is accessible to all, which will enable physicians to provide better care for their patients. In an open, connected community solution, patients become more satisfied and involved with their own care. Independent healthcare organizations can remain independent by being more efficient and at the forefront of new, emerging payment models. Family Practice Associates, in Lexington, KY, is a great example of how a healthy EHR core can help independent practices to succeed. It has helped the group earn $375,000 in Meaningful Use incentive payments, improve net collections to 98 percent, and enroll 20 percent of patients in their portal in less than one year.

Conclusion

The Medicare and Medicaid EHR Incentive Programs include three stages with increasing requirements for participation. CMS recently published a set of proposed rules that include the proposed rule for Stage 3 of Meaningful Use, which focuses on the advanced use of EHR technology to promote health information exchange and improved outcomes for patients.

With this in mind, it has highlighted the need and importance to maintain a secure EHR system and realize the true value of the technology and the benefits resulting from effective compliance. This will result in effectively providing patients with a secure electronic record of their health and discharge information while enabling this information to be passed on to all relevant parties to ensure a consistent standard of care.

Effective compliance can lead to higher-quality data, which can enable physicians to provide better care for their patients. Patients become more satisfied and involved with their own care, and independent healthcare organizations can remain independent by being more efficient and at the forefront of new emerging payment models.

References

1. Health IT Regulations, 2015. Meaningful Use Regulations. http://www.healthit.gov/policy-researchers-implementers/meaningful-use-regulations
2. Federal Register, 2015. 2015 Edition Health Information Technology (Health IT) Certification Criteria, 2015 Edition Base Electronic Health Record (EHR) Definition, and ONC Health IT Certification Program Modifications. https://www.federalregister.gov/articles/2015/03/30/2015-06612/2015-edition-health-information-technology-health-it-certification-criteria-2015-edition-base
3. Centers for Medicare & Medicaid Services, 2015. Meaningful Use “MU” Aligning Stage 1 and 2 with Stage 3 (CMS 3311P). http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-04-10.html