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Federal HIT Strategic Plan – 2014 Update

December 10, 2014 Leave a comment

The HIT Policy Committee (HITPC) and HIT Standards Committee (HITSC) of the Office of the National Coordinator for HIT (ONC) focused on the recently updated Federal HIT Strategic Plan in rare back-to-back meetings December 9 and 10.

The revised Federal HIT Strategic Plan (released Monday) is an ARRA/HITECH-mandated, non-binding document to identify broad milestones over certain periods of time for federal agencies related to health IT, including dozens of agencies outside of HHS (NASA, Bureau of Prisons, DOD, Education, and so on). The update released for comment on Monday was the third version (2008 and 2011 being the priors). Critical to understanding the scope of this document, it does not address private sector/physician/industry activities or goals, but rather what outcomes government actors should strive for over the next 3 and 6 years.

Meanwhile, the anticipated “National Interoperability Roadmap” is expected to be published around January. Most importantly, the proposed rules to update the EHR Incentive Program participation and technology certification requirements are on the horizon for early 2015 (probably/maybe).

HHS Announces New ONC Data Brief on EHR Adoption Motivations

December 5, 2014 Leave a comment

Earlier today, the HHS Office of the National Coordinator for HIT (ONC) announced the publication of the ONC Data Brief No. 21, “Physician Motivations for Adoption of Electronic Health Records.” The data brief attempts to explore stakeholder decisions to move forward (or not) with EHR adoption.

Unfortunately, as with all EHR adoption reports based on the Centers for Disease Control and Prevention (CDC) NAMCS survey and supplemental surveys from 2011-2013, a large chunk of the EHR Incentive Program eligible professional (EP) population (nearly 17% if CMS’ EP denominator is to be believed)—anesthesiologists, pathologists, and radiologists—are explicitly not included. Moreover, the CDC/NAMCS concept of an “EHR” is not always aligned with the ONC’s regulatory concept of “certified EHR technology.” So, while the CDC survey data may be useful for some things, it is not particularly helpful for understanding overall physician views of CMS’ EHR Incentive Program.

This is not new.  The CDC’s annual surveys have omitted anesthesiology, pathology, and radiology data for years because they are based on a pre-ARRA understanding of the world. This kind of data would be more helpful if the surveyed population aligned with the real makeup of CMS and ONC’s stakeholders and better reflected the current, post-ARRA landscape.

Reminder: Last Chance to Participate in ACR’s Meaningful Use Survey

November 20, 2014 Leave a comment

This is the final opportunity to participate in the American College of Radiology’s (ACR) one-minute, 3-question survey for radiologists regarding the Medicare/Medicaid EHR Incentive Program. The survey will close shortly after the 2014 RSNA conference. The objective is to get a better understanding of radiologists’ decisions to participate or not participate in the program.

If you are a practicing diagnostic radiologist, interventional radiologist, nuclear medicine physician, or radiation oncologist, please take a moment of your time to complete the survey. Your responses will help inform future ACR advocacy and/or educational efforts.

Click here to participate in the ACR MU Survey

Categories: EHR, meaningful use, Medicare

Meaningful Use in 2014: Early Rookie Participation Numbers Very Low

November 6, 2014 Leave a comment

Every month, representatives from the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for HIT (ONC) provide a report to the HIT Policy Committee regarding registration and attestation statistics for the EHR Incentive Program, or “Meaningful Use” (MU). These updates are usually unremarkable in that an overly optimistic view is portrayed via registration numbers, month-to-month incremental improvements, and total dollars paid. However, the November 2014 MU attestation statistics were more interesting than usual.

So far, only 43,898 eligible professionals (EPs) have successfully attested for MU in CY 2014. Of those, only 11,478 EPs have attested to Stage 2 MU. While low, the CY 2014 numbers should exponentially rise by the MU attestation deadline of February 28, 2015 for two important reasons: 1) the vast majority of MU attestations historically occur at the last possible minute, and 2) CMS’ September 2014 rule change to allow continued use of 2011 certified EHR technology (CEHRT) for qualifying participants. Therefore, it is hard to conclude anything about the program’s health by just looking at the November totals.

The aforementioned “interesting” part is this… Only 15,481 of those 43,898 attestations were from first-year MU participants. Recall that the attestation deadline for rookie EPs to avoid 2015 payment adjustments via MU compliance passed on October 1, 2014. Therefore, the November 2014 statistics in the report to the HIT Policy Committee included all rookie participants who made that deadline. In other words, these 15.5k rookies appear to represent the highest possible increase that can occur in MU participation rates in CY 2014 beyond the previous years (under the most optimistic of circumstances).

It gets a bit more complicated though… Recall that CMS reopened the significant hardship exception application period until later this month for the specific subset of participants who were unable to fully implement 2014 Edition CEHRT in time for a CY 2014 reporting period. While this “extension” was clearly meant for veteran MU participants who already had 2011 Edition CEHRT, it is unclear how many rookie MU participants might claim that particular hardship exception and have it hold up to audit (I expect at least several thousand will). So, we should anticipate at least a handful of rookies will attest for MU in CY 2014 using 2011 Edition CEHRT, AND will avoid 2015 penalties via the extended hardship exception.

All of that said, my point is this… Unless the “new participant” stat increases by hundreds of thousands, and not merely tens of thousands, the number of U.S. physicians who will be penalized throughout next year for noncompliance with MU is going to be staggeringly high.

Categories: EHR, meaningful use, Medicare

ACR Meaningful Use Survey for Radiologists

October 17, 2014 1 comment

The American College of Radiology (ACR) is conducting a very brief, one-minute, 3-question survey for radiologists regarding the Medicare/Medicaid EHR Incentive Program. The objective of the survey is to get a better understanding of radiologists’ decisions to participate or not participate in the program.

If you are a practicing diagnostic radiologist, interventional radiologist, nuclear medicine physician, or radiation oncologist, please take a moment of your time to complete the survey. Your responses will help inform future ACR advocacy and/or educational efforts.

Click here to participate in the ACR MU Survey

Categories: EHR, meaningful use, Medicare

ONC Federal Advisory Committees Hold Joint Meeting on Interoperability; Two Senior ONC Staff Leaving the Agency

October 16, 2014 Leave a comment

On October 15, the HHS Office of the National Coordinator for HIT (ONC) held a joint meeting of the HIT Policy Committee and HIT Standards Committee to discuss the draft interoperability roadmap, health information exchange (HIE: the verb, not necessarily the noun) governance, and the JASON Task Force recommendations. The outcome of the meeting was an approved set of broad recommendations to ONC indicating a desire to leverage open Application Programming Interfaces (APIs) as the foundational approach for nationwide HIE.

ONC also announced that two senior ONC staff, Dr. Doug Fridsma and Judy Murphy, would be attending their last federal advisory committee meeting as employees of the agency. Dr. Fridsma has been with the agency for four years and most recently served as Chief Science Officer. Judy Murphy most recently served as Deputy National Coordinator for Programs and Policy.

Categories: EHR, meaningful use, Medicare

CMS Addresses Attestation System Issue by Extending Significant Hardship Exception Application Deadline for Some

October 7, 2014 1 comment

Earlier today, the Centers for Medicare and Medicaid Services (CMS) announced that the significant hardship exception application deadline has been extended until November 30, 2014 for physicians who are eligible to use the September 4, 2014 flexibility AND who were unable to attest by the October 1, 2014 deadline for first-year participants.

What does this mean? This was CMS’ answer to the problem recently identified by the Medical Group Management Association (MGMA) pertaining to the timing of a planned update to CMS’ web-based attestation system. CMS plans to implement a system patch in October that would enable the agency to receive online attestations from participants using the September 4, 2014 flexibility. Unfortunately, the deadline for first-year program participants to complete their attestations for a 2014 reporting period already came and went on October 1. Therefore, if a first-year program participant intended to use the September 4 flexibility, they would have missed the deadline because of CMS’ unpatched system.

The number of first-year participants expected to require the latest extension is small. In radiology, most diagnostic radiologists, interventional radiologists, and nuclear medicine physicians did not need to apply for a significant hardship exception because they were automatically given one.

Categories: EHR, meaningful use, Medicare
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