EHR in Your Future

By John Ballard

EHR is the acronym abbreviation for Electronic Health Record. It can be found among many others listed on pages 4, 5 and 6 of a 136-page document from HHS which together with another 556-page document launch the opening of an ambitious five-year mission launched by the new Obama Administration to get America's health care community all on the same page when it comes to record-keeping.  

For most of us, all we need is a quick look at the two links above, blink,and hope the doctors know what the hell they are doing as they wade into yet another data swamp. But that's just my reaction as a layman. In fact, the medical profession and its affiliates have become more adept at paperwork than practicing medicine, thanks to America's insistence on treating health care as a commodity. But don't get me started...

I have mentioned before that even without legislation this administration is bringing about important improvements to health care that have already commenced, starting with financial incentives funded by ARRA, encouraging and rewarding doctors, hospitals and other providers to adopt and use an information exchange standard which will return their investment many times over, not only in reduced paperwork but better outcomes. 

I have neither the time nor the expertise to blog the details. But I have learned enough to be informed. Readers of a wonky inclination are welcome to drill into the details. Two sources here for the curious.

David Harlow's Health Blawg...

Meaningful Use of Certified EHRs: Proposed rules come out just under the wire
Meaningful use of certified EHRs -- the long-awaited definitions were released by HHS and ONC, within HHS, before year-end, as required by law. ("Put on display," technically.) Filed at 4:15 pm on December 30, followed by a 5:15 pm conference call, the release was almost a parody of transparency. Nevertheless, the rules are out, and some spent the days around New Year's reading the 500+ typewritten pages of meaningful use criteria and 100+ typewritten pages of certification standards. (Others have called it "drivel.") The rules will be formally published in mid-January, and at that time the 60-day comment period will begin. David Blumenthal, National Coordinator for HIT, said on the conference call that final rules are expected in the Spring. So, the two sets of regulations released last week are linked to from an HHS press release on meaningful use of certified EHRs; the agency sites linked to in the press release also link to FAQs, fact sheets and other resources. (When the regulations are published in the Federal Register, there should be direct links on the agency sites linked to in the press release.) The standards apply to three parallel incentive payment programs: Medicare, Medicaid and Medicare Advantage.

[...]

These rules are the beginning, rather than the end, of the rulemaking process -- and I am not simply referring to the 60-day comment period. Last week's issuances, as long as they are, are far from comprehensive, and they contemplate significant additional rulemaking to flesh out the concepts of meaningful use and certification. The national health information network, which we've been hearing about for quite some time now, doesn't really exist yet, so the initial rules require a number of workarounds, and future rulemaking will need to define additional standards and processes.

For example, the meaningful use regulation sets out only "Stage 1" Criteria for meaningful use. These are drawn from the three sets of criteria contained in the working group's recommendations which formed the basis for this proposed rule. From the regulated community's perspective, it would be preferable to know all three sets of criteria in advance of beginning an enormous investment of money and other resources, designed to entitle providers (and certain health plans) to significant dollars reimbursing some of those costs in the near future, and to exempt them from being subject to reduced payment schedules in the more distant future.

That "three sets of criteria" link will take you to a ten-page pdf impossible to interpret version of a chart which when seen in chart form (I did it copy/cut/tape) displays the grand strategy of "fleshing out the concepts" between now and 2015. The five topic areas are quality/safety/efficiencies/disparities, patients and families, coordination, public health, and privacy issues. And as he said, the details are yet to be filled in. 

Dr. John Halamka, whom I have linked before, blogs at Life as a Healthcare CIO...

Now that the Interim Final Rule (Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology) and the Notice of Proposed Rulemaking (Medicare and Medicaid Programs Electronic Health Record Incentive Program) have been published, we can all finalize our policy and technology strategies for achieving Certification and Meaningful Use in our organizations and communities.

It's important to use these two documents together to understand what is required for Certification and to achieve Meaningful Use stage 1 measures (2011) by professionals and hospitals.

Certification is a guarantee of software capabilities and Meaningful Use describes the way software features should be implemented in actual workflows. Certification and Meaningful Use are related but different concepts. For example, Certification requires that a complete EHR or EHR module have the capability of recording, retrieving, and transmitting immunization information using HL7 2.3.1 or HL7 2.5.1 with the CVX vocabulary. The Meaningful Use stage 1 measure is to perform at least one test of the certified EHR technology's capacity to submit electronic data to immunization registries if local public health agencies are capable of receiving them. Thus, for 2011, actual submission of immunization data is not required, just the capability and a single test of that capability. Of course, by Stage 2 (2013), I expect that actual data submission will be part of every patient immunization.

When you go there you will discover the two pdf links in the first paragraph of this post. And those brave souls who venture further will do so with all my best wishes. That's about as far as I care to go on my own. Any further and I might as well be reading the techniques of how best to perform an organ transplant.

Before I quit, I do want to link that big, fat document above and refer the reader to pages 194, 200,  301, 302, 304, and 305. There you will see in an easy to read form how much money is on the table for EP's (Eligible Professionals) when they get with the program. The many charts reflect several categories involved depending on whether or not they accept Medicaid beneficiaries and whether or not they are in the HPSA (Health Professionals Shortage Area) group.