What You Should Know:

• SIVAD Diagnostic Medical Group LLC (SIVAD), a minority-owned company dedicated to addressing the unique needs of underserved and unserved communities in the United States and globally, recently announced the launch of HarmGuard FX in Delaware, the first state in the nation to distribute this groundbreaking approach to reducing overdose deaths.
• HarmGuard FX is a single, low-cost strip that provides an affordable, reliable way for people to test substances for fentanyl and xylazine (popularly known as tranq), two dangerous adulterants that are exacerbating the already critical opioid epidemic.

Tackling the Opioid Epidemic with Affordable Testing

The U.S. Drug Enforcement Administration (DEA) recently reported that it had found the deadly combination of fentanyl and xylazine in nearly a quarter of drugs sampled from 48 out of 50 states.1 According to the Centers for Disease Control and Prevention (CDC), between 2018 and 2021, deaths involving xylazine increased by 1,238%, leading the White House Office of National Drug Control Policy to designate fentanyl combined with xylazine as an emerging threat to the U.S.2

“As a company committed to leveraging technology to democratize health care and address the needs of underserved and marginalized communities, SIVAD developed our Harm Stopper™ Program to provide comprehensive resources that can reduce the harm of fentanyl and xylazine for substance users, the community advocates who support them, health professionals, and law enforcement personnel,” said Jermonica Boardley, CEO and President at SIVAD, who is leading the Harm Stopper Program. “We commend Lt. Governor Bethany Hall-Long for making Delaware the first state to pilot HarmGuard FX and are collaborating with Delaware health officials spearheaded by Susan Holloway to implement a pilot program that could serve as a blueprint for other states seeking to prevent overdose deaths. As other states receive and deploy funds from the National Opioids Settlement, we hope to work with them to implement HarmGuard FX and our Harm Stopper Portal as part of their harm-reduction strategies.” 

SIVAD’s Harm Stopper Program includes the HarmGuard FX test strip and the Harm Stopper Portal. The comprehensive, cloud-based, AI-driven portal provides education, resources, and information at the national level, and for participating states, uses advanced geolocation to provide the user with instant access to local resources and information related to harm reduction. Using the QR code on each HarmGuard FX package, people can quickly find local, free naloxone distribution locations, needle exchange programs, counseling, emergency services, and other resources – complete with hours of operation, distance from the user, and any special requirements such as training. It also provides a one-click call option on mobile devices. The portal includes information for commercial and public sites and resources, including all standalone pharmacies and pharmacies within larger stores.

What You Should Know:

• Researchers and physicians at the University of Pittsburgh and UPMC used machine learning to create and deploy an accurate and flexible model for predicting patients at high-risk for complications after surgery, according to a new study published recently in JAMA Network Open.
• Before the COVID-19 pandemic, the third leading cause of death globally was complications 30 days after surgery, killing about 4.2 million people each year. Identifying patients who are at high-risk for complications before they undergo surgery is critical to saving lives and lowering health care costs.

Predicting Post-Operative Complications Using Data-Driven Models

Improving overall health of patients prior to surgery through prehabilitation can go a long way in improving outcomes for high-risk patients,” said Aman Mahajan, M.D., Ph.D., M.B.A., chair of Anesthesiology and Perioperative Medicine, Pitt School of Medicine, and director of UPMC Perioperative and Surgical Services. “However, identifying high-risk patients can be challenging for busy clinicians, who have to integrate the wealth of health data available and frequently perform additional testing and clinical assessments. We wanted to build an easy-to-use model that provides the health care team with an automated and accurate risk assessment quickly using existing data in the electronic health record.”

To create the model, Mahajan and Oscar Marroquin, M.D., chief health care data and analytics officer at UPMC, and their teams trained the algorithm to learn from the medical records of over 1.25 million surgical patients. The model focused on mortality and whether patients had a major cerebral or cardiac event, like a stroke or heart attack, after surgery. The model was then validated against another 200,000 patients who underwent surgery at UPMC.

After validation, the model was deployed across 20 UPMC hospitals. Every morning, the program reads the electronic medical record for patients who are scheduled for surgery and flags those determined to be high-risk. This notification allows clinical teams to better coordinate care and institute some prehabilitation in advance of their surgery, like making healthier decisions or even a referral to the UPMC Center for Perioperative Care, lowering their risk of complications. Clinicians can also run the model at any time on demand.

To gain a better understanding of how their model compared to the industry standard, Mahajan and his team compared it against the American College of Surgeon’s National Surgical Quality Improvement Program (ACS NSQIP). While the ACS NSQIP is used at hospitals throughout the country, it requires clinicians to manually input patient information and cannot make a prediction if information is missing. Mahajan and his team found their model did a better job at identifying high-risk patients than the ACS NSQIP. 

As the model continues to be refined and developed, Mahajan and his team aim to train the program to predict the likelihood for sepsis, respiratory issues and other complications that often keep patients in the hospital after surgery.

athenahealth, Inc., an EHR provider for hospital and ambulatory clients nationwide, today announced the expansion of the company’s Guarantee Program to include a Meaningful Use (MU) Stage 3 Guarantee for hospitals. The Meaningful Use Stage 3 Guarantee for hospitals joins a growing portfolio of quality initiatives support offered by the company, including a Merit-Based Incentive Payment System (MIPS) guarantee and client support program. 

“Every hospital or health system —no matter the size— wants a partner who can tackle the complex work of getting reimbursed,” said Jonathan Bush, chief executive officer at athenahealth in a statement. “As government-mandated programs reinvent themselves year after year, we’ve taken on the reporting administration so our clients can remain focused. By leveraging our national network, our payer and quality measure rules engine, and years of expertise around cracking the code of the complicated, we aim to free providers and care staff to spend more time delivering care.”

What is athenahealth Guaranteeing?

Each client must agree to the Meaningful Use Stage 3 guarantee (the “Guarantee”) terms in an effective services agreement between athenahealth and client. Eligibility conditions apply, including, but not limited to, that the Guarantee is only available to new athenahealth clients and their eligible hospitals with 50 beds or fewer that are live on athenaOne for Hospitals and Health System services by June 30, 2018.

Under athenahealth’s Meaningful Use Stage 3 Guarantee for hospitals, if a hospital uses athenaOne for Hospitals & Health Systems Service in accordance with athenahealth’s best practices and experiences a downward payment adjustment to its Medicare Part A fee schedule, athenahealth will provide a service fee credit to offset such downward payment adjustment, subject to certain limitations. Clients will not be charged additional fees nor burdened with upgrades to meet Meaningful Use requirements.

athenaClinicals for Hospitals & Health Systems will be certified EHR technology in the ONC Health IT Certification program for Stage 3 ahead of the reporting period in 2018.

The Meaningful Use Stage 3 Guarantee for hospitals is the newest addition to the athenahealth portfolio of industry-leading programs for government-mandated quality reporting, including a Meaningful Use guarantee for ambulatory clients with 96.7 percent of clients successfully attesting in 2016, and a Value Modifier (VM) program in which 96.3 percent of athenahealth providers successfully avoided VM 2017 penalties.

Since entering the hospital market in 2015, athenahealth has contracted with more than 100 community, rural, and critical access hospitals across 35 states to maximize day-to-day efficiencies and staff performance by automating or eliminating the tedious tasks that divert time from patients. Even as the average hospital’s operating budget shrinks and resources become scarce, athenahealth hospitals have thrived. According to the company’s 2016 fiscal data, clients achieved an average of over 106 percent of cash flow above baseline and cut Days in Accounts Receivable by 16 percent.

Editor’s Note: Michael Nusimow is the CEO and Co-founder of drchrono, an EHR, practice management, medical billing and healthcare API platform that focuses on iPad, iPhone and web.  Michael has been working in information technology for over 15 years and implemented components of the Bloomberg Terminal, used by customers worldwide. 

Despite all of the changes happening in healthcare legislation over the past few years, 2017 is not looking any easier. It is easy to get confused with the progression of Meaningful Use and with the MACRA / MIPS rollout. For some, providers have been using their EHR over the past few years to earn incentives and others preparing to be hit with reimbursement deductions to their claims. Now you should be asking, what’s next for Meaningful Use?

Regardless of when you start, or tried to start meeting Meaningful Use, eligible providers can report either Modified Stage 2 or Stage 3 in 2017. Providers reporting Stage 2 must report a full year of data and those attempting Stage 3 early only should report 90 days of data. Only having to report 90 days is the reward for being at the cutting edge of Meaningful Use reporting.

The catch to reporting Stage 3 is ensuring your EHR capable of tracking and reporting the required measures while also having the interoperability with other EHRs. Providers that do not have interoperability to complete Stage 3 must be working towards the Modified Stage 2 measures.

It is worth mentioning that providers that are just starting to receive payments from Medicare / Medicaid start in Stage 1. While Stage 1 requirement are significantly easier – new eligible providers should take Meaningful Use seriously as their start / build their practice. Providers that are starting out in Stage 1 will not have the eligibility of incentives for Medicare. EHR incentives for Medicaid can potentially be earned by providers as late as 2021.

Capitalizing in 2017 on your hard work from 2016

Providers are now on deadline to attest, or officially report, their Meaningful Use data from 2016. All Medicare attestations (eligible providers and hospitals) are required before February 28 11:59 Eastern Time! That puts West Coast providers at a disadvantage that are working at the last minute.

Remember attesting for Medicaid is different from state to state, both in resources that might be available to help you attest or even availability to attest. A CMS provided resource for your state can be found here.

To increase the success of attestation guidelines, providers should collect all their applicable deliverables: confirmation of submissions to registries, security audits and EHR data copies in a master folder in the event of an audit. EHR data used for attestation should also be confirmed that it is being calculated correctly.

Providers should ensure their notes and work are completed for 2016 visits and that the EHR reporting is set correctly. Pulling incorrect data from your EHR not only will cause issues during attestation, but especially during future audits and reporting periods.

To help you know what information and documentation is required to attest successful, and to make the process quicker, a review of the CMS resource on how to attest is advised. It can be access at the following link.

To attest, you’ll need your EHR(s) InfoGard certification number. If your practice switched EHRs during the reporting period you are attesting to, you’ll need to attest with data from both and indicate the dual use during attestation.

A final word on the work you accomplished in 2016 and looking ahead to 2017: remember that CMS programs are linked in requirements and over time and build on past work. Any work towards program requirements is valuable.

There is also MACRA now

Eligible providers will also be working towards what has been made available to meet MACRA requirements. As with the rollout of Meaningful Use, it will be easier to get started as early in 2017 as possible rather than later in the year or program.

To meet MACRA (as it applies to providers) is either MIPS (merit-based) or APM (advanced alternative). An easy way to think about either is a more applicable, specific PQRS. Further, becoming familiar with new programs when their restrictions are not as mature and are still being rolled out makes the long-term process of meeting the program requirements easier.

Providers in 2017 and beyond need to be using their EHRs meaningfully and working to track and improve patient outcomes. More details are coming out about these programs, but more requirements (and potentially more reimbursements) are planned for the APM track.

CMS’s time table for MACRA extends as far as 2026, such as how they planned Meaningful Use through 2021. One thing is for certain – more details and rulings are in the pipeline, and providers’ best chance at meeting the new requirements placed on them is to use quality EHRs to the best of their ability.

Remember to reach out to your vendors, state and professional associations with feedback to help shape the future of CMS programs.

Editor’s Note: D’Arcy Guerin Gue is a co-founder of Phoenix, with over 25 years of experience in executive leadership, strategic planning, IT services, knowledge leadership, and industry  relations —  with a special focus on patient engagement and federal compliance issues. She currently serves as the Director of Industry Relations at Phoenix Health Systems, a division of Medsphere Systems

No, there is no Meaningful Use for behavioral health hospitals, and yes, some mental health clinicians remain skeptical about the proposed value of EHR.

And yet a steadily increasing number of behavioral health facilities nationwide have adopted an EHR to improve patient care and organization performance. According to a recent Behavioral Healthcare survey, most are satisfied with the decision to make an EHR part of their daily routine.

So, does that satisfaction make it a wise value proposition to adopt a behavioral health EHR? This highly relevant question about return on investment (ROI) is not limited to behavioral health facilities, but it might be a more pressing concern for organizations that cannot count on federal subsidies.  

What counts in determining ROI?

Because behavioral health care is complex and, more importantly, because it measures value in many non-monetary ways, we have to look at both quantity and quality.

“Some organizations have difficulty determining their EMR project’s ROI,” writes business development executive Carol Turso in Behavioral Healthcare. “Common reasons for this are failing to see an EMR’s strategic benefits and considering the initial cost as an expense rather than as an investment … An EMR is an investment because it provides long-term benefits and may be an important tool for reducing the cost of expenses.” 

Turso uses the example of a social services organization that over three years after implementing an EHR reduced bad debt by 93 percent, lowered outstanding accounts receivable of more than 151 days from 24 to 9 percent, and trimmed the time staff spent per week entering remittances and payments from 40 hours to 10 minutes. In every instance, these EHR benefits improve the organization’s bottom line. Even if they don’t technically create new revenue, they are still quantitatively relevant.

Qualitative improvements save time, prevent adverse medication events and reduce errors, which saves money. As the federal government shifts to a reimbursement model based on quality and patients vote with their feet, the qualitative approach starts to look more like a quantitative imperative.

How do non-clinical factors impact the evaluation of ROI?

You can build it, but they may still not come.

So, it’s difficult to exaggerate the importance of behavioral factors in ensuring the value of your behavioral health EHR. You must create buy-in, make clinicians feel as though they have a voice in the process, train everyone effectively on the system and take feedback on how to improve the solution and workflows after go live.

“Realizing full value of the [EMR] system typically depends not only on successful deployment of the system but also on adaptation of other organizational processes and workflows,” says an Institute of Medicine (IoM) paper that seeks to create a standard model for assessing the value of EHRs. “Functionality is also enhanced or constrained by the quality of implementation, including user training and acceptance, as well as the universe of technology with which it is used.”

The good news is that, for most behavioral health hospitals, the investment in EHR seems to be money well spent.

According to the Behavioral Healthcare survey mentioned above, the majority of those with an EHR are satisfied and putting the system to good use. Among all respondents, 23.6 percent said the EHR they use improves patient care, 18.1 percent cited the elimination of paper storage as a prime benefit, and double-digit percentages identified improved care, reimbursement and clinical outcomes as valuable results.

How can we determine if our new EHR is earning its keep?

Every behavioral health organization has to track dollars, cents and hours, so at least in those areas you can use the EHR to monitor change and increase in value over time, even if pre-EHR tracking was less than judicious.

At the core, an ROI evaluation is still a costs-versus-benefits analysis. It’s just a little more complex with behavioral health IT. If you’re not yet working with some sort of tracking system and evaluation scheme, consider starting with a table of costs and benefits. Circulate the list to clinical, administrative and technical leaders and then update until all feel confident the table is comprehensive.

To get a more complete picture of actual value and return, the IoM model looks at three overarching components: expenses, benefits and potential impacts to revenue. Each category is divided up into numerous types in an effort to determine with specificity what is the value of a particular EHR investment.

“… benefits of robust information system implementation might include savings to an organization from the reduction or more effective deployment of full-time equivalents (FTEs) associated with more efficient business practices, decreased morbidity and mortality due to more consistently delivered, high-quality care, avoided complications from improved preventive care, and enhanced patient experience and outcomes through the opportunities afforded by EHRs and patient portals for engagement,” reads the IoM paper.

 It’s worth spending some time reviewing the IoM tables if you are questioning the value of your EHR or considering different solutions.

Can you afford a comprehensive EHR with reliable ROI without federal government help?

Absolutely.

There are many behavioral health EHRs out there with dramatic differences in both price and payment structure. Some acute care hospital EHRs also adapt well to the behavioral health environment. Yes, some of these systems are expensive and require substantial upfront expenditures for software licensing fees, infrastructure, consultants, network, etc. But other less expensive and robust options require almost no spending upfront if you have the infrastructure in place, and enable you to pay as you go via subscription.

Ultimately, much of the ROI for the healthcare IT system you choose is dependent on how you make it work for your behavioral health facility. Create organizational buy-in (especially among clinicians), evaluate workflows and how they might change to accommodate the EHR, and choose a solution that incorporates behavioral health-specific functionality and is a realistic financial fit.

Put the foundational pieces in place and the likelihood of positive ROI increases dramatically, even if that federal subsidy never materializes.

Opinions expressed by HIT Consultant Contributors are their own.

The Consumer Partnership for eHealth (CPeH) is urging the Centers for Medicare & Medicaid Services (CMS) to maintain robust objectives and measures that promote health information access and exchange between patients and eligible hospitals. In comments submitted today on proposed modifications to the rules governing Stages 2 and 3 of the Electronic Health Record Incentive (Meaningful Use) program, CPeH notes that measures designed to give individuals access to their health information and help them use it are critical enablers of high-quality care and delivery system reforms.

If kept strong, CPeH writes, the Meaningful Use program holds great promise for improving the quality of care and health outcomes for patients. CPeH represents more than 127 million consumers, patients, caregivers, seniors, people in underserved communities, people with disabilities and other stakeholders.

“The national imperative to transform our health care system into one that delivers better care and better outcomes at lower cost cannot possibly succeed without the active engagement of patients and family caregivers,” said Debra L. Ness, president of the National Partnership for Women & Families, which leads CPeH. “The ability to access and share health information online is an essential tool. We urge CMS not to retreat on measures in the Meaningful Use program so we can realize its full potential to help patients and family caregivers access and use critical health information to improve care and health.”

In the comment letter, CPeH expresses concern with CMS’ decision to reduce Stage 3 thresholds back to the Modified Stage 2 thresholds, describing it as a “retreat from the very activities that hold the most promise for improving the quality of care and health outcomes for patients.” In response to CMS’ rationale that the proposed changes can reduce hospital administrative burden and allow hospitals to focus more on patient care, CPeH writes that, far from being administrative burdens or inconveniences, these activities are integral to developing more collaborative and engaged relationships among patients, their family caregivers and their care teams in the mutual pursuit of better care and improved health outcomes.

In its comments, CPeH specifically urges CMS to:

·         Abandon the “one patient” threshold – where hospitals need show that just one patient uses online access (View/Download/Transmit) – and instead keep the threshold at 5 percent of patients. CMS’ own data in October 2015 showed that hospitals already well exceeded this threshold for Stage 2;

·         Keep Stage 3 thresholds strong to prepare providers for new models of care, rather than backtracking to Stage 2 thresholds on measures of patient electronic access, secure messaging, patient specific education materials and health information exchange;

·         Preserve but modify a clinical decision support measure (CDS) to encourage greater use of patient-facing CDS that engages patients and families in treatment decisions; and

·         Maintain full-year reporting in 2016, rather than only 90 days in a year, to maximize the benefit to patients and encourage providers to make sustained changes to workflow and organizational procedures that support interoperability and patient engagement.

Editor’s Note: Thomas Grove is a Principal of Consulting and Compliance Services at Phoenix Health Systems, a division of Medsphere Systems. As a healthcare management executive with 20+ years of experience, Thomas has extensive expertise in strategic assessments and planning, revenue cycle management, and process improvement.

Early in July, CMS released a new set of proposed rules to modify Meaningful Use. If all goes well through the comment period and final updates, by fall we will see many Meaningful Use Stage 2 and 3 changes that will significantly reduce the burden on providers struggling to meet MU requirements. Assuming most of you would not relish burning midnight oil to review this 764-page MU modifications document, following is our contribution to the cause: a hopefully readable and worthwhile summary.

Meaningful Use Stage 2

Proposed Changes for Meaningful Use Stage 2 CMS’ new proposed rule makes changes to requirements for Meaningful Use Stage 2, which impacts hospitals in 2016 and 2017, and which are the subject of this article. In addition, there are changes proposed for the Meaningful Use Stage 3 goals, which we will cover in a separate post next week. For returning hospital participants in the Medicare incentive program, four substantial changes have been proposed for Stage 2. The proposed rules will:

• For 2016 only, establish a 90-day measurement period.

• For 2017 only, reduce the threshold of the View, Download, and Transmit (VDT) objective to require “at least 1 patient.” This is already the established requirement for 2016.

• For 2017 and beyond, eliminate the Clinical Decision Support (CDS) goals. These requirements called for demonstrating 5 ways clinical decision support was used, and required drug-drug interaction and drug-allergy checking.

• For 2017 and beyond, eliminate the Computerized Provider Order Entry (CPOE) requirements, which called for CPOE of lab, radiology, and medication orders.

The Impact of Proposed Changes to Stage 2

A focused set of hospitals will see significant benefits from the proposed changes, but most hospital participants will experience little impact:

• The impact of the 90-day measurement period will be greatest on the small subset of hospitals changing EHRs during 2016. These hospitals will now have the opportunity to use a 90-day period on either side of their transition date for meaningful use purposes instead of having to combine data from the pre- and post-transition systems into one attestation.

• The reduction of the VDT measure to require only a single patient could be substantial for a significant subset of hospitals struggling to meet that goal, and essentially provides another year for these hospitals to reshape their patient portal program.

• The elimination of the CDS and CPOE goals should have minimal impact, as these are being eliminated because they already have widespread acceptance. CMS refers to this condition as “topped-out.”

Hospitals should also be aware that the 90-day reporting period change will not allow them to receive their 2016 Medicare incentive program money more quickly. We must wait while the proposed rules remain open for comment for 60 days, and then for the 60 to 90 days CMS will need to process the comments and prepare a final rule for publication. At that point, CMS will generate a task order to modify its portal to accept attestations under the new guidelines — an effort likely to take another 60 to 90 days. Ultimately the rule-making process will push the ability to attest to Meaningful Use well into the first quarter of 2017.

A Major Question Remains

CMS indicates that the proposals to eliminate the CDS and CPOE objectives and reduce the VDT thresholds apply to hospitals participating in the Medicare program, but do not impact the Medicaid program. In many cases, hospitals are still actively participating in both programs. It remains unclear how this disparity of measures would work, particularly in states that rely primarily on federally collected data for their attestations.

Meaningful Use Stage 3

CMS also has proposed significant changes stage 3 requirements for 2017-2018, several of which reduce participation thresholds that have been widely controversial. Many providers are likely to welcome these proposed modifications, which we have summarized as follows:

Patient Access Measure

This measure requires hospitals to provide patients’ electronic access to clinically relevant information about their care in a timely fashion. As originally proposed in stage 3, this would require hospitals to make information available for view, download, and transmit, and also to provide access via application programming interface (API). In the proposed rule, CMS would lower the threshold from 80 percent of patients to 50 percent.

Inadequate API technology was cited as a reason that this measure may be difficult for hospitals to meet. This logic doesn’t entirely make sense, because the primary barrier to meeting the API measure will be the development of the technology by certified electronic health record technology (CEHRT) vendors. Once the technology is available, hospitals should be able to make the API interface fully available to 50% or 80% of patients with nearly the same effort.

Patient Education Measure

This measure, which requires hospitals to use their CEHRT to identify and provide electronic, patient-specific educational material, is also significantly reduced from 35% to 10%. CMS expressed concern that not all patient users are sufficiently computer savvy to download electronic instructions, rendering them essentially unable to access their instructions.

View, Download, and Transmit (VDT) Measure

CMS has again proposed reducing the measure to only require one unique patient to view, download, or transmit his or her data during the reporting period. CMS has expressed a concern that many healthcare providers have already noted: patient participation is the limiting factor in attaining this goal. The expectation now is that as the technology matures, and hospitals find new ways to engage patients with their patient portals, patient participation will naturally increase.

Secure Messaging Measure

The requirement of providers to use secure messaging to communicate with patients, a new requirement for stage 3, is substantially reduced from 25 % to 5%. Again, CMS cited uncertainties in patient participation and not-fully mature technology as primary reasons.

Transition of Care Measure

This measure’s threshold, which was slated to increase substantially to require 50% of patient transitions from one care provider to another to include the exchange of information in stage 3, will remain at 10%. CMS cited hospitals’ concerns that there are insufficient receiving providers available to meet the higher numbers.

Request/Accept Patient Care Record Measure

This measure balances the previous measure, by reducing the threshold from 40% to 10% of patients for which hospitals must receive and incorporate an electronic summary of care document accepting them as new patients via transition of care. The threshold originally established at 40% would be substantially reduced to 10%. Ironically, with CMS’ reduction of the threshold of sent documents to 10%, meeting this requirement may now become even more difficult than before.

Clinical Information Reconciliation Measure

CMS proposes to reduce the number of patient transitions where a reconciliation of clinical information is performed from more than 80% to 50%, citing interoperability concerns that would impair the easy incorporation of external data into the EHR.

Public Health and Clinical Data Registry Reporting Measure

CMS proposes to reduce the number of required reporting partners from four to three, citing the challenges hospitals have in many states with the lack of availability of qualified registries.

What to Do About Meaningful Use Stage 2 and/or Stage 3 Today?

Remember that this discussion is about a proposed rule. It doesn’t have the force of law until it’s been finalized. While it’s true that CMS rarely backtracks on proposed changes to make them more difficult, we recommend staying the course until the rule is finalized in the fall. Hospital Meaningful Use teams should, however, review the proposed rule to see how it impacts their attestation efforts and consider submitting comments to CMS, using the procedure outlined in the proposed rule.

If you are in a specific situation that might be impacted by the changed rule, such as implementing a new EHR, by all means devote some time considering how the changes may affect your plans for 2016 — and perhaps positively. For example, we are working with three hospitals that are currently replacing EHRs, for whom a change to an October 2 start date for a 90-day measurement period will make collecting 2016 Meaningful use dollars a possibility.

Another note of caution: while CMS’ apparent direction is to lower the bar for meeting Meaningful Use stage 3 in 2017 and 2018, no commitment has been made to continue reductions into 2019 and beyond. Recognize that the proposed lowered thresholds for meeting Meaningful Use has in no way affected the true goal of the program – making us all meaningful users of our EHR technology.

If you’d like to comment on the proposed rules, you may submit electronic comments on this regulation at http://www.regulations.gov.

(This summary was compiled from two Phoenix Health Systems blog posts published in July 2016 on HITpoint Blog.)

On Thursday, Senate REBOOT members introduced the EHR Regulatory Relief Act (S. 3173), legislation that would provide regulatory flexibility and hardship relief to providers and hospitals operating under the meaningful use program.  

EHR Regulatory Relief Act Legislation Overview

Regulatory flexibility is necessary to help hospitals and medical providers focus on transitioning into the new, patient-focused payment policies created by Congress by the Medicare Access and CHIP Reauthorization Act of 2015 instead of the “check-the-box” meaningful use program.

The proposed legislation would:

Shorten the 90-day reporting period for eligible physicians and hospitals:

– While CMS has proposed a 90-day reporting period for reporting year 2016, this bill will codify this proposal to ensure hospitals and eligible providers will be able to attest with 90 days of reporting, as they were able to do in 2015.

Removing the All-or-Nothing Approach to Meaningful Use:

– The 100%-is-passing approach to meaningful use creates an unfair burden of compliance. Missing a threshold by a small amount or failure to meet an individual part of an objective results in failure, despite good faith efforts.

– This bill would create a new threshold that requires eligible hospitals or eligible providers to meet no more than 70% of the required metrics to satisfy meaningful use requirements.

Flexibility in the Hardship Exception:

– This bill extends current law providing hardship relief to providers for 2016 and 2017.

– Reasons for hardship include insufficient internet connectivity, natural disasters, unexpected practice closures, vendor and certification issues, lack of face-to-face patient interaction, etc. 

In April, the senators wrote to U.S. Department of Health and Human Services Secretary Sylvia Burwell and Centers for Medicare and Medicaid Services Acting Administrator Andy Slavitt to request input on a draft bill, and with the feedback they received, developed the version that was introduced today.

“This legislation will help ease the burden of the meaningful use program for doctors and hospitals who have told me they want to spend more time caring for patients instead of trying to comply with government regulations,” said Senate health committee Chairman Lamar Alexander in a statement. “Specifically, it will give hospitals the same flexibility that Congress passed for doctors with overwhelming bipartisan support last April, and it will give doctors and hospitals the certainty of law that the 90-day reporting window for meaningful use proposed by CMS earlier this month is here to stay. I look forward to Senate passage of this legislation as we continue to work to pull the electronic medical records system out of the ditch, transforming it into something that doctors and hospitals look forward to rather than dread.”

Editor’s Note: D’Arcy Guerin Gue is a co-founder of Phoenix, with over 25 years of experience in executive leadership, strategic planning, IT services, knowledge leadership, and industry  relations — with a special focus on patient engagement and federal compliance issues. She currently serves as the Director of Industry Relations at Phoenix Health Systems, a division of Medsphere Systems

In the public mind, the needs of the mentally ill and addicted have always taken a backseat to those of the physically ill and injured. This dichotomy was never more obvious than when behavioral health and addiction providers were excluded from the Meaningful Use program created by the American Recovery and Reinvestment Act (ARRA) of 2009.

Predictably, EHRs have proliferated among incentivized providers and remain comparatively rare with behavioral health and addiction organizations. As of December 2015, 98 percent of eligible hospitals and nearly 60 percent of office-based physicians had implemented an EHR, according to HealthIT.gov. All told, these providers received over $32 billion in federal tax dollars to cover EHR-related costs.

Contrast those numbers with the relatively few behavioral health and addiction providers that have EHRs. The National Council for Behavioral Health reported in 2012 that fewer than 30 percent had one. A 2012 Health Affairs study said only 21 percent of psychiatric hospitals had EHRs. Software Advice’s 2014 study of 385 mental health software buyers found that most were from small practices; only 16 percent represented organizations with more than 11 doctors.

Now, seven years after ARRA, healthcare leaders are increasingly worried about the EHR divide between acute and mental health care. Clinicians know that physical and mental health are inextricably connected; without the ability to share care data across patient populations, comprehensive care and treatment is an unreachable goal, putting the health of millions of Americans at stake. While HIMSS, AHA, NAPHS, CMS, Congress and others have discussed these problems and proposed various solutions, financial support for EHR adoption by behavioral health and addiction providers remains elusive.

And yet, even without Meaningful Use, an increasing number of behavioral health hospitals are blazing their own trails toward better care through EHRs. In-depth interviews with leaders of three such organizations illustrate why and how they made this transition, and how working with an EHR has proved beneficial to patient care.

– IntraCare North is a 90-bed psychiatric hospital managing two care facilities in the Houston, Texas, area. IntraCare offers a continuum of inpatient and outpatient mental health and chemical dependency services to children, adolescents and adults.

– The Recovery Center at EvergreenHealth Monroe, based in Monroe, Washington, offers a multidisciplinary treatment team that provides inpatient and outpatient services for substance abuse patients throughout the Pacific Northwest. It is licensed for 32 beds.

– Silver Hill Hospital is a psychiatric hospital with 129 licensed beds. Located in New Canaan, Connecticut, the independent not-for-profit facility provides inpatient and residential transitional living programs for adolescents and adults. Its 45-acre campus includes ten buildings designated for different levels of care.

All three organizations in this study shared an upfront advantage: Each had leaders and staff that were familiar with EHRs and astute enough to observe how these systems could change the healthcare landscape. Previous interactions with acute care providers gave them valuable insight regarding the potential benefits of EHRs: better quality measurement, improved internal processes, simplified reporting, integrated care management and more accurate patient records, to name but a few. Leaders of these organizations each provided answers to the same four questions.

1. From Paper to Electronic: Why take this giant step?

Better Record Keeping and Reporting

“We knew moving to an EHR would provide a better quality record because EHRs don’t allow skipping over data fields, which often can happen in a paper record,” explained IntraCare CEO of Healthcare Operations Terry Scovill. “Moreover, online records can be monitored internally far more easily.” Scovill also noted that the simple illegibility of paper records and high costs of paper were problems that could be virtually eliminated with electronic data entry. “Staff therapists and nurses were doing so much time-consuming documentation,” added Eric Britt, an EvergreenHealth supervisor. “We knew typing would be more accurate and productive once they became accustomed to it.” IntraCare leaders also wanted to minimize the paperwork burden of reporting to the Joint Commission and state and federal agencies. “Tracking down needed records and being able to read them was a big problem that detracted from our central mission,” according to IntraCare Project Manager Phyllis Qualls.

Immediate Access to Patient Records

For Silver Hill, trying to manage documentation across ten buildings and multiple treatment programs was frustrating, so instant access to patient records was essential. “Discharge from one program to another on paper was a nightmare,” said Silver Hill President and Medical Director Sigurd Ackerman, M.D. “Clinical records were hard to find … to operate more smoothly, our staff needed immediate access to the whole patient record.” EvergreenHealth Medical Director John Patz, M.D., agreed. “Multiple access was needed, as was the ability to easily audit records. We wasted too much time hunting down records that lived on one piece of paper.”

Integrated and Improved Care

Leaders and staff from all three hospitals expected a comprehensive EHR to enable better care integration with other providers.

“IntraCare wanted the ability to easily share patient information with referrals, which was difficult to do with paper records,” Scovill explained. “We knew that if we could quickly share quality data with referring physicians, everyone would benefit, especially our patients.”

For key hospital staff, an EHR gave them the ability to quickly understand a patient’s care history and rapidly determine correct next steps.

“We expected electronic patient record sharing to help us better serve our patients by minimizing medication delays and inaccuracies—critical in a substance abuse program,” said Dr. Patz.

Imagine you’re living in Brooklyn and you have a medical emergency. If the hospital nearest you, say Lutheran Medical Center, were to close, you could go to Maimonides or New York Methodist a short taxi or ambulance ride away.

Now, let’s say you’re badly injured and you live outside rural Tulare, California, in one of the most productive agricultural counties in the U.S. If Tulare Regional Medical Center went away, you might have to life flight to Bakersfield, Los Angeles or the Bay Area. (Really, Tulare may not even be representative given that there are more than 1,300 critical access hospitals in the U.S., some far more remote than Tulare.)  

The scenario is far from unrealistic. For the most part, non-urban healthcare organizations are not doing well. In fact, almost every rural hospital in the country is operating near the margin or in the red. According to iVantage Health Analytics Senior Vice President Michal Topchik, speaking to Health Data Management, 67 rural hospitals have closed since 2010, and 283 were vulnerable to closure last year. Already in 2016 iVantage has identified 673 vulnerable rural hospitals, with 210 at very high risk.

While only about 15 percent of the American population, roughly 46 million people, live in rural areas, they do some of the nation’s most essential work. Mostly, they grow food, produce energy or provide services to the people that grow food and produce energy.

Obviously, the rural healthcare situation matters in terms of food and energy security at home, but also in terms of economics—the United States is by far the largest global exporter of food, with roughly $40 billion separating America from number two, and is on the cusp of ending energy imports for the first time since 1950.

In reality, rural healthcare is transitioning, not disappearing, mostly because doing nothing is just bad economics. People in rural areas need care. If they can’t get it locally, they have to be flown to the nearest facility, which ends up being more expensive over the long term than funding a local hospital.

To their credit, the Centers for Medicare and Medicaid Services (CMS) are already aware of the situation in rural America and have been taking steps toward fixing it.

Speaking recently to the National Rural Health Association, CMS Acting Administrator Andy Slavitt explained that the agency is “establishing a CMS Rural Health Council to work across the entire agency to oversee our work in three strategic priority areas– first, improving access to care to all Americans in rural settings; second, supporting the unique economics of providing health care in rural America; and third making sure the health care innovation agenda appropriately fits rural health care markets.”

As Slavitt points out, rural Americans tend to be older, earn less money and they generally lack health insurance—more than 60 percent of citizens without health insurance live in rural areas in states that have not expanded Medicaid through the Affordable Care Act. Nearly 75 percent of government health insurance exchange users make less than 250 percent of the federal poverty level—currently a bit less than $12,000 a year for an individual and slightly more than $24,000 for a family of four.

So, if the argument could be made that rural America is home to the greatest number of healthcare challenges, then it also represents the greatest opportunity. If we can make affordable healthcare work outside urban areas, we may have a template applicable to other scenarios.

On Slavitt’s first two points—access and economics—CMS is working to sign rural Americans up for health insurance and adjusting requirements and payment models for rural care.

Which brings us to the “innovation agenda,” Slavitt’s term for the digitization of healthcare and the all-in bet the federal government has made on the benefits of health IT. The goal here is to transform rural hospitals and clinics into efficient, wired, lean operations that can absorb the realities of rural care and still operate in the black.

With 35 percent of rural hospitals losing money and almost two-thirds running a negative operating margin, there’s simply no way rural facilities can invest in health IT without help. From CMS, that help takes the form of several planned or in-process programs:

– Medicaid State Innovation Model grants for technical support in smaller rural hospitals

– Aggregation of services in rural communities creating benefits from population health

– The Frontier Community Health Integration Project (summer 2016), developing and testing new models in isolated areas using telemedicine and integration approaches

– The ACO investment model for hospitals that can’t invest in ACO infrastructure; the model now serves 350,000 rural beneficiaries through 1,100 rural providers

– Incorporating telemedicine where appropriate; CMS is publishing a Medicaid final rule that for the first time allows for face-to-face encounters using telehealth

Related: CMS’ Next Generation ACO Model: The True Cost of Healthcare’s Transformation

It’s clear that CMS understands we can’t leave rural hospitals to fend for themselves.

But it also seems clear that a lot of hospitals invested in electronic health records (EHRs) they could ill afford to qualify for Meaningful Use funds—dollars that seldom covered implementation costs for solutions that didn’t yield significant cost savings and required additional technical personnel. By and large, that MU money has been dispensed. The carrot has been eaten. What Medicare- and Medicaid-heavy hospitals can expect next is two sticks: more stringent reporting requirements necessitating EHR use and direct penalties (for now) related to Meaningful Use non-compliance.

“The high capital and operating costs associated with health IT, specifically EHRs, have put some hospitals in a difficult position,” wrote Becker’s Hospital CFO in a prescient January 2014 article. “Do they absorb the financial hit now, even if they know they can’t afford it? Most organizations are doing so …”

Yes, CMS is trying to help lessen the impact of that metaphorical beating, but these rural hospitals also have to make decisions to help themselves. Too many are paying for systems they can’t afford to maintain. Moreover, they are unable to invest in necessary security, leaving them increasingly open to data breaches. Many are also still handicapped by the costs of ICD-10 transition, for which there was no federal reimbursement.

Rural hospitals need a comprehensive EHR platform that integrates with a revenue cycle system so they can properly capture charges and manage the billing process, and effectively collect on previously lost billing. These systems need to be available as a subscription service so that rural hospitals don’t have to come up with huge money down. And they can’t require the hiring of an additional 50 application specialists to make the new systems work.

“The benefits of IT are still to come,” Standard and Poor’s Marin Arrick told Becker’s Hospital CFO more than two years ago. Still the economic crisis in rural care rages on, certainly lessening access to care for millions of Americans and arguably impacting the labor force that produces food, energy, etc.

Despite all the fixes CMS is working diligently to implement, something more dramatic may be in order. Market-oriented reforms can be argued in urban areas where there is competition, but it’s difficult to advocate for similar approaches where there is no market. Also, Meaningful Use is coming to an end and the new regime is not yet clear, so it’s difficult to say what more might be necessary when we’re not able to predict how rural healthcare will be impacted.

Related: Meaningful Is Dead, Long Live Something Better! 

Personally, I see the programs and plans CMS is putting together to assist rural healthcare as valuable and impactful, but they are not sufficient in and of themselves. What will transform rural care is the same thing that will revolutionize American healthcare in general—affordable, interoperable, comprehensive platforms that, when combined with application programming interfaces and robust security, enhance the care provided by knowledgeable, dedicated professionals.

Does that sound like a solution you’ve heard of before? 

Opinions expressed by HIT Consultant Contributors are their own.

Interoperability.

Achieving it is a predominant theme in healthcare today, and a priority agenda item ever since Meaningful Use (MU) incentives took over the industry in 2009. To clarify (from HIMSS), the definition of interoperability is “the ability of different information technology systems and software applications to communicate, exchange data, and use the information that has been exchanged.”

Interoperability sure sounds like the next step in Meaningful Use, achieving the ability to broadly aggregate and analyze health data and manage our population’s health, right? Yet, the industry seems to be at an impasse. What is holding it up?

Anyone who has observed the evolution of healthcare IT knows that our implementation cycle of major changes is long. Look at electronic transactions. HIPAA was passed in 1996, but it was 2003 before the standards were put in place, and well into the current decade before key payers could handle all the transactions. And, while claim and remittance advices gained universal acceptance fairly quickly, claim status transactions took much longer. Even today, 20 years after HIPAA was passed, hospitals must struggle with different payers that have implemented the standards in different ways.

The industry’s road to interoperability is paved with strikingly similar bumps and ruts. Some EHR  technologies are decades old, but implementation of EHRs only became mainstream when the federal government incentivized their use through the Meaningful Use program. Interoperability was a behind-the-scenes goal then,  but with certified EHRs now in place throughout the country, it’s a front and center concern. This is because interoperability is only practical if  EHR  usage has reached enough critical mass to make the possibilities realistic, including providing the basis for common standards for data sharing.

According to an ONC report to Congress on December 2015, there are still at least five powerful barriers that are preventing interoperability in healthcare management:

– Lack of universal standards-based EHR systems’ adoption

– Impact on providers’ day-to-day workflow

– Complex privacy and security challenges associated with widespread HIE

– Need for synchronous collective action among multiple stakeholders

– Weak or misaligned incentives

This article will focus on perhaps the most problematical issues: the lack of universal standards across EHRs and their adoption, and weak or misaligned incentives.

All healthcare providers have not been equal under the Meaningful Use initiative. Many providers weren’t fortunate enough to be eligible for MU incentives, including long term care / post acute care facilities (LTPAC) and behavioral health providers. There are thousands of them, large and small. Both fields are making quantum leaps in growth, yet most continue to operate without even the most basic of EHRs (let alone ONC-certified systems).

But a strong relationship exists between behavioral health, LTCPA, and physical health, welfare, disease, and, ultimately, treatment. With the onset of the baby boomer “coming-of-age” era, this relationship is being strained as never before. A simple example: according to Mental Health America, more than two million of the 34 million Americans age 65 and older already suffer from some form of depression. Symptoms of clinical depression are often triggered by chronic physical illnesses common in later life, such as Alzheimer’s, Parkinson’s, heart disease, cancer and arthritis. Yet for all the investment put into MU-certified EHRs, hospital emergency rooms still have no access to the mental health records of a patient who arrives after taking a suicidal overdose of barbiturates.

The lack of information exchange capabilities between the MU incentives “haves” and “have-nots” has resulted in dysfunctional, even contradictory care programs for shared patients. For example, cardiac specialists prescribe beta-blockers for hypertension; psychiatrists recommend against them, knowing that notorious side effects of beta-blockers include depression and fatigue. The specialists have no access to others’ information. This problem is not different than in pre-MU years, but is much greater in magnitude, and creating increasing frustration across the provider community.  A resurgence of interest by Congress in these issues is afoot…but no decisive action seems imminent. In the meantime, this fragmentation of EHR users poses a significant barrier to nationwide interoperability.

The technical side of interoperability has been compromised by Meaningful Use’s profitability for vendors. Certainly, ONC has tightened the standards used by EHR systems, and has noted that one benefit is that “reporting to public health has expanded enormously across the country since it was included as a requirement in the EHR Incentive Programs.” But this remark is a tip-off on a major reason why EHR-to-EHR interoperability across providers has progressed slowly.  It was never a requirement of Meaningful Use.

The highly competitive EHR vendor industry has not been motivated to collaborate on technical standards for interoperability. Just the opposite. The EHR Incentive Program has been a bonanza for individual EHR vendors. Why would they compromise their profits by amping up technologies to share clients’ data with competitors?  In February, 2015, all five former and current ONC leaders came together to acknowledge and analyze this obstuctive factor in achieving interoperability.  In an ONC Meeting, they decried the discontinuity between interoperability objectives and the stance of the vendor industry. Per Farzad Mostashari: “This [problem] is not because of the data standards, it’s because of the business practices…. Vendors haven’t been incentivized to make progress on interoperability and data sharing…. this is a market failure.” Should we be surprised?

In addition to the commerical barriers to adopting standards for exchanging clinical information, the current Meaningful Use technical standard, the Consolidated-Clinical Document Architecture (CDA) standard, isn’t sufficiently robust to handle the kinds of data needed in an interoperable environment.  The proposed Fast Healthcare Interoperability Resources (FHIR) standard would go a long way to making interoperability real. If you are inclined to find your way through these technical weeds, I recommend doing so.

Meaningful Use Stage 2 has not been a rousing success. A November 2015 Health Affairs report notes that while there has been a marked increase in hospitals’ ability to meet core Stage 2 MU criteria (40.5 percent of hospitals, up from 5.8 percent in 2013), this progress is “undoubtedly still much lower than the Centers for Medicare & Medicaid Services would’ve liked to see.” According to the report, “Hospitals most often reported up-front and ongoing costs, physician cooperation and complexity of meeting meaningful use criteria as challenges.”

The number of physician practices that have attested to Stage 2 is much lower. They have not kept up. Penalties started becoming part of their accounting considerations in 2014-2015 and have continued.  The Medical Group Management Association is concerned. “Those EPs [eligible professionals] who invested considerable resources in their Stage 1 certified EHR, many of them in small or rural clinical settings, are now in danger of falling behind.” While the details of these penalties are beyond the scope of this article, you can read more about them here.

This decreased momentum in following through on meeting Stage 2 EHR usage standards offers another signal that providers as a whole are not ready for interoperability and won’t be any time soon.

For the thousands in the healthcare industry that understand that the thrust of HIPAA was long term preparation for industry-wide interoperability of health data systems and resulting data aggregation and population health research and management, ONC’s Meaningful Use program has achieved significant progress.  It has not been a holy grail, but couldn’t have been considering inevitable roadblocks such as those discussed above.  Overall, ONC should be praised…MU has been a giant step in contributing to world wide healthcare advances.

Without substantial course corrections now to fast-forward interoperabiity, the industry risks setbacks in reaching long term goals that both the federal government and many healthcare providers have embraced. The latest announcements from ONC regarding an overhaul (or replacement) of the Meaningful Use program should be welcomed.

It’s time.

Editor’s Note:  Aashima Gupta is the VP of  Healthcare Digital Transformation at Apigee leading provider of API technology and services for enterprises and developers. In her current role she is driving strategy and execution for the healthcare vertical at a API and analytics startup.

I still struggle to get simple, ubiquitous access to my health records. Trying to get my health history every time I see a specialist, giving my doctor to access my lab records, and even the extraordinarily mundane task of trying to get a copy of my daughters’ immunization records every school year — the experience is generally the same: impossibly frustrating. Tangles of red tape and labyrinthine requirements, no end in sight. If I’m lucky, multiple phone calls harassing various administrative offices begging for my records can lead to a PDF of my records, but that’s about it.

This is not the user experience modern healthcare consumers expect in today’s increasingly digital and interconnected world.

The 2009 HITECH Act brought the promise of electronic health records for every American, unlocking unprecedented new cost-saving efficiencies in the US healthcare system and better patient care all around. What we’ve ended up with instead is a question: where did the $31 billion in HITECH Act incentives go?

In addition to billions federal spending, private funding is also on the rise, with venture funding of digital health companies hitting an all time high in 2014, and 2015 investment on pace to surpass it. However, despite all this, very little has changed for the average healthcare consumer.

Long story short, we’ve hardly made any progress at all – and that’s a problem.

The key issue here is a lack of interoperability. Information still can’t move across systems freely so that software and systems can communicate, exchange data, and generally do all of the things modern consumers have come to expect from their apps.

Healthcare has long been a system of walled gardens. The IT systems used by hospitals are different from those used by pharmacies, primary care providers, and so on. Every corner of the healthcare system has it’s own custom system that doesn’t know how to communicate with the other. When it comes to electronic health records in particular, interoperability is nowhere to be found, and that’s troublesome because it’s the entire idea behind EHRs.

The walled garden problem is not unique to healthcare. Every industry transitioning from analog to digital faces the challenge of replacing inward-looking legacy systems with those designed for interoperability in order to maintain relevance in the modern era.

Proven technologies from the tech world provide a clear path forward, but the healthcare industry still needs to choose to adopt them. Specifically, APIs, OAuth, REST, and others serve to help IT systems rapidly innovate from walled gardens into the interoperable future. These technology bridges, which have seamlessly connected the consumer tech world, need to be the underpinning in the secure exchange of data in health care.

In October, officials from the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health IT made a historic announcement on Stage 3 of the Meaningful Use program (MU Stage 3)—the Medicare and Medicaid program that incentives providers using EHR technology and sets specific objectives that must achieved to qualify.

Marking the beginning of consumer and tech friendly regulations in healthcare, the “MU Final Rule,” as it’s also known, supports application programming interfaces (APIs) for opening broader patient access to their own health records. MU Stage 3 rule’s mandate of providing API-level data access is historic, and recognizes the pivot required from the inward-looking walled gardens of legacy systems to a modern interoperable model.

By supporting APIs, the MU Final Rule will expand healthcare consumers’ choices in how they manage their health and wellness. In particular, it will lead to the rise of innovative new health and wellness-focused mobile apps that can aggregate EHR data and present it in entirely new ways. It’s an exciting time for healthcare.

Healthcare is about engaging patients in managing their own health and wellness. With MU Stage 3 setting the stage for implementing APIs in transforming healthcare, patients will finally begin to see progress EHRs and the overall accessibility of their health and wellness data. By making this data available to patients, EHRs will finally begin to empower individuals to make key health decisions – and to do so using the app of their choice. 

Opinions expressed by HIT Consultant Contributors are their own.

At the J.P. Morgan Healthcare Conference in San Francisco, Mr. Andrew Slavitt, acting administrator at the Centers for Medicare & Medicaid Services (CMS),announced on January 11th that “The meaningful use program as it has existed will now effectively be over, and replaced with something better”, and later clarified on Twitter that: 

In 2016, MU as it has existed– with MACRA– will now be effectively over and replaced with something better #JPM16

— Andy Slavitt 🇮🇱 🇺🇦 (@ASlavitt) January 12, 2016

Meaningful Use is dead. Just like that. No apologies. No nothing. As someone who’s been lamenting the havoc wreaked by the program on both doctors and patients, I should be elated nevertheless. Well, I am not.

Let’s start with appearances. The J.P. Morgan Healthcare Conference is the “largest and most informative healthcare investment symposium in the industry which brings together global industry leaders, emerging fast-growth companies, innovative technology creators, globally minded service providers, and members of the investment community”.

In other words the event is all about money for the millionaire and billionaire class. J.P. Morgan Chase itself is the largest financial institution in the country. It is the embodiment of Wall Street and its death grip on our collective neck. Was this conference really the best place to make such momentous announcement?

Besides, why would these extractors of wealth be interested in the fate of something as obscure as Meaningful Use? Shouldn’t they discuss more lucrative schemes, such as running all possible blood tests on one tiny blood droplet, or how the makers of Microsoft Office and the largest online retailer of everything are going to jointly solve for cancer? Shouldn’t they be analyzing trillion dollar addressable markets of genomic rainbows, and how mergers, acquisitions and inversions can help squeeze whatever is left in the turnips that are you and me?

Of course they should, and they did all that and much more. But changes to the Meaningful Use program are of strategic importance to all other rainbows, grails and unicorns. Why? Because Meaningful Use, other than funneling a respectable amount of billions of dollars into the health tech sector, is the enabler of data collection which fuels all other investment opportunities.

Furthermore, pretty much everything that could be sold to satisfy Meaningful Use, has been sold, so what’s next? As the Meaningful Use money making opportunities are ending, CMS is “moving to a new regime”. Interesting choice of words notwithstanding, the Meaningful Use successor consists of punishing doctors for nebulous “outcomes”, and of course all sorts of new technologies to better transfer all medical data into places where J.P. Morgan clientele can monetize them.

Let’s talk about substance. Meaningful Use has been created by an act of Congress, and enshrined for posterity in a subsequent act of Congress, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). It is not clear to me how a political appointee can invalidate acts of Congress at will, although this probably makes perfect sense in the rarefied circles convened by J.P. Morgan. If nothing else, the absolute confidence that Congress will oblige, and the President of the United States will sign whatever is put in front of him/her by the Wall Street lobby, is a perfect illustration of who is running this country and how it is done. A somewhat less politically disheartening explanation is that the demise of Meaningful Use has been greatly exaggerated in this announcement.

Meaningful Use, as we discussed in the past, is not just about onerous burdens on physicians. It is also about regulating design and production of medical software to serve the needs and wants of government and large corporations. From reading Mr. Slavitt’s remarks, I suspect that the latter effort is far from being over and may actually be greatly fortified under the “new regime”. If you design clever software, and mandate its purchase and daily use, there is very little utility in paying users to show their work, which is what Meaningful Use for physicians really meant. You do however want to keep those unwittingly exploited users calm and cooperative, which may explain why CMS wants to “get the hearts and minds of physicians back”.

Related: In Retrospective, Meaningful Use was Meaningless

Enter the American Medical Association (AMA). While across the ocean, the British Medical Association (BMA) is aggressively supporting its striking members in a nationwide struggle for the soul of medicine, the AMA is launching a “Silicon Valley integrated innovation company” to monetize its members in service to the new CMS regime. In a fortuitous coincidence, the creation of this new “stand-alone, for-profit entity”, Health2047, was announced in San Francisco on the same day the J.P. Morgan conference was convened. The goal of Health2047 is to leverage physicians’ expertise to “help forge new paths and bring commercial solutions to market faster”, and of course to make boatloads of money for investors, including the AMA.

Meaningful Use is dead. Long live something better! And what is that better something? It is paying physicians for outcomes. It is the use of evidence based medicine. It is interoperability and “user-centered” design. It is Accountable Care Organizations, value, patient centeredness, coordination and such. It is also the making of markets “by leveling the technology playing field for start-ups and new entrants”, because when Epic makes money, nobody on Wall Street or in Silicon Valley gets a piece of the action. It is about engagement and analytics and population health, calculations, penalties, incentives and lots of new technology things. It is “like the second generation iPhone”.

After collectively sinking billions of dollars in Certified EHR Technology over the last five years, hospitals and doctors will now be expected to foot the bill for new software and computer products to support the lifestyles of a new generation of Silicon Valley entrepreneurs and the insatiable greed of the old generation of Silicon Valley investors. Why? Because the next app is sure to fix health care in America. It’s always the next one. There is always “something better” you can buy.

Planned obsolescence, which is fueling the obscene fortunes of Silicon Valley and destroying life everywhere else, has finally arrived to the $3 trillion health care sector. It took a bit longer than the folks at J.P. Morgan expected, I’m sure, but we’re in business now. Let the good times roll…..

Margalit Gur-Arie is the founder, BizMed. She writes regularly about the intersection of healthcare & technology on her site: On Health Care Technology. Follow her on Twitter at @margalitgurarie  

Opinions expressed by HIT Consultant Contributors are their own.

“The Meaningful Use program as it has existed, will now be effectively over and replaced with something better.””As any physician will tell you, physician burden and frustration levels are real. Programs designed to improve often distract. Done poorly, measures are divorced from how physicians practice and add to the cynicism that people who build these programs just don’t get it,” Slavitt said to the audience at the J.P. Morgan Healthcare Conference.

In response to Slavitt’s recent remarks, CHIME President and CEO Russell Branzell has issued the following statement regarding the future of meaningful use: 

“The Meaningful Use program has had a profound impact on the adoption of health information technology and furthering the digitization of the healthcare delivery system. CHIME members have long supported the underlying goals of the program and the industry has made significant progress in implementing IT systems to improve patient care, reduce costs and create a more efficient delivery system.

At the same time, CHIME has been at the forefront of advocating for refinements to the program to ensure that hospitals and physicians — can meet program requirements. We continue to call upon federal regulators to, among other things, better align clinical quality measures and adopt enforceable standards. We also believe that we need a laser-like focus on interoperability to improve health information exchange across the continuum of care. Central to that is finding a safe, accurate and private methodology for patient identification. Interoperable systems, a bigger focus on outcomes and less prescriptive use of how technology is used will better position providers for success in new payment and delivery models of care and ultimately benefit patient care.

We are encouraged that Acting Administrator Slavitt and CMS are open to improving the Meaningful Use program. It is important that we maintain momentum in digitizing healthcare. Robust IT systems are a cornerstone for achieving the Triple Aim — better population health, an improved patient experience and lower costs.

The Medicare Access and CHIP Reauthorization Act of 2015, along with other reforms being pursued by CMS, aim to dramatically shift healthcare toward value-based payment. Through these changes, we’ll see greater alignment between physicians and hospitals. CHIME believes that it is essential that we create more synergy between Meaningful Use requirements for hospitals and physicians if we are going to fully realize the potential that health IT has in promoting better patient care across the continuum.

We look forward to working with CMS as it begins to refine the Meaningful Use program.”

For the last five years I have witnessed at length the bold predictions of how many startups and app focused companies will revolutionize healthcare as they did the consumer industry. I was always a skeptic and viewed the ‘evangelizing’ of healthcare apps as being wishful thinking rather than being based on any evidence.

Don’t get me wrong, apps are a critical component of clinical IT systems for patients and clinicians but they’re just that – one component. A gateway to much more important systems in healthcare. So what will we be the key topics of 2016?

1. The Platform is King

Consider this a philosophical observation as much as it is a technological one. Health IT companies both large and small will start to increasingly view themselves as providers of solutions rather than individual products. There will be a shift from talking about apps to platforms instead as vendors seek to provide value through powerful data driven systems. This extends from broad EHR systems through to specialized document management and clinical portal modules. This shift in thinking will allow vendors to view their solutions within the larger clinical IT ecosystems they have to operate and so promote clinical and technological interoperability and integration.

2. The Rise of the Cloud

In line with the notion of interoperability, we will start to see both regulator and healthcare organization attitudes softening towards the cloud from an end-user perspective. Standards will develop to embrace the use of cloud based solutions while clinicians will seek to engage versatile systems to enhance their ability to access and action information beyond the clinic walls. Complementary to this will be the demand of patients to have greater visibility and access to their own clinical information in a secure manner.

3. Clinicians Will Become IT Leaders

For some time, I have witnessed and engaged clinical IT leaders from central government and provider settings. It’s becoming increasingly clear that their power as critical stakeholders determining the future of their organizations at strategic, procurement and deployment levels is going from strength to strength. It will be incumbent upon all vendors to ensure that they have the appropriate expertise to work with clinical IT leaders to ensure the successful delivery of their solutions across all clinical settings.

4. Interoperability Will Define Vendors

Interoperability between vendor solutions will come to define how favorably they are viewed in the market. Vendors will increasingly be assessed according to the ability of their solutions to complement an existing clinical IT ecosystem through data sharing. This is a complex area as vendors of acute setting focused solutions must be able to create access points for clinicians, for example, in the community setting. Open APIs and framework agreements between vendors will be key to this and will transform the industry.

5. Big Data will Grow Up

Big Data to this day continues to be notional in its application and restricted to research for the most part. Even population health continues to be relatively nascent. As the adoption of EHR systems and strategies matures so will the need to harness data for decision support both at micro and macro levels. Health IT vendors already recognize this and are positioning themselves to ‘own’ data through data centers so that in due course they can evolve their platform propositions to encapsulate clinically actionable analytics.

In 2016, we will see the healthcare IT industry adapt and mature as large vendors seek to establish their dominance in the marketplace. However, the only way they’ll do it is by listening closely to what the market needs in the first place.  

Dr. Saif Abed is the Founding Partner of Abed Graham Healthcare Strategies, a provider of clinical analysis and intelligence to support UK (NHS) market research, strategy development and sales acceleration. 

Opinions expressed by HIT Consultant Contributors are their own.