“HIT Policy Update With John Halamka, MD”healthsystemcio.com/presentation/policyupdate-2014q1-webinar.pdf · Meaningful Use Stage 3 Recommendations •Meaningful Use Workgroup

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Housekeeping

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Agenda — 45 Minutes

• 20 minutes: John Halamka, MD, CIO, Beth Israel Deaconess Medical Center

• 5 minutes: A Word From Our Sponsor: Colleen Sirhal, Director of International Healthcare Sales, Hyland

• 20 minutes: Q&A w/John Halamka


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“HIT Policy Update With John Halamka, MD”


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Meaningful Use Stage 3 Recommendations

• Meaningful Use Workgroup recommendations were approved by the Policy committee with dissenting votes

• 19 proposals

• Items related to eMAR, Reminders, Imaging, Family History, Medication Adherence, Amendments, Case Reports were removed from final recommendations but will be included in the transmittal letter

HITPC Recommended Objectives

• Improving Quality of Care and Safety 1.Clinical decision support2.Order tracking3.Demographics/patient information4.Care planning – advance directive5.Electronic notes6.Hospital labs7.Unique device identifiers• Engaging Patients and Families in their Care 8.View, download, transmit9.Patient generated health data10.Secure messaging11.Visit Summary/clinical summary12.Patient education

Improving Care Coordination

13. Summary of Care at Transitions

14. Notifications

15. Medication Reconciliation

Improving Population and Public Health

16. Immunization history

17. Registries

18. Electronic lab reporting

19. Syndromic surveillance

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Improving quality of care and safety:Clinical decision support (CDS)

3

• Use of CDS to Improve Quality of Care and Safety

• Core: EP/EH/CAH use of multiple CDS interventions that apply to CQMs in at least 4 of the 6 NQS priorities

• Recommended intervention areas:

1. Preventive care

2. Chronic disease condition management

3. Appropriateness of lab/rad orders

4. Advanced medication-related decision support

• Improving problem, meds, allergy lists

• Drug-drug /drug-allergy interaction checks

Red: Changes from stage 2 Blue: Newly introduced Bright Red: edits for clarity

Certification criteria:1.Ability to track CDS interventions and user responses 2.Perform age-appropriate maximum daily-dose weight based calculation

Standards Maturity Development Effort

Low HighNature of tracking a response is a substantive effort. Suggest aligning payment reform with an outcome, rather than prescriptive CDS.

Improving quality of care and safety:Order tracking

4

• Tracking Orders to Improve Quality of Care and Safety

• NEW Menu: EPs

• Assist with follow-up on orders to improve the management of results.

• Results of specialty consult requests are returned to the ordering provider [pertains to specialists]

• Threshold: Low

• Certification criteria:

– Display EHR should display the abnormal

flags for test results if it is indicated inthe lab-result message

– Date complete

– Notify when available or not completed

Blue: Newly introduced Bright Red: edits for clarity

‾ Record date and time results reviewed and by whom

‾ Match results with the order to accurately result each order or detect when not been completed


Low High There are a variety of different concepts with varying levels of difficulty included. Suggest including display of abnormal lab results and sign-off.

5

Reducing health disparities:Demographics/patient information

• Patient Information Captured and Used to Reduce Health Disparities

• Certification criteria to achieve goals:

– Ability to capture patient preferred method of communication

– Ability to capture occupation and industry codes

– Ability to capture sexual orientation, gender identity

– Ability to capture disability status

• Communication preferences will be applied to visit summary, reminders, and patient education

Red: Changes from stage 2 Blue: Newly introduced


LowStandards are still evolving for some of these items, although occupation and industry codes does has a high standards maturity.

MediumCould potentially be HIGH. There are significant workflow changes that could result due to the communication preferences. Patients could provide a default means of communication, without limiting to only that form of communication.

Improving quality of care and safety:Care planning – advance directive

7

Recording Advance Directives to Improve Quality of Care and Safety

•Core for EHs, introduce as Menu for EPs•Record whether a patient 65 years old or older has an advance directive •Threshold: Medium •Certification criteria: ability to store the document in the record and/or include more information

about the document (e.g., link to document or instructions regarding where to find the document or where to find more information about it).



High

Maturity is high if the intent was a simple yes/no check box and link to a URL.

Low

Development is low, if correctly assumed this was a yes/no check box and link to a URL.

Improving quality of care and safety:Electronic notes

7

• Use of Electronic Progress Notes to Improve Quality of Care and Safety

• Core: EPs record an electronic progress note, authored by the eligible professional.

• Electronic progress notes (excluding the discharge summary) should be authored by an authorized provider of the EH or CAH (Core)

– Notes must be text-searchable

• Threshold: Low High



Medium

Concerned about the significant threshold increase. Is the intent to provide the ability to search across multiple notes?

High

Creating de novo functionality and export capabilities

Discharge summary is an ambiguous term. Assume meant "Hospital Course" and "Discharge Instructions" and intends that such text notes be included in the Discharge Summary C-CDA Template or equivalent standard?

Improving quality of care and safety:Hospital Labs

9

Hospital Lab Results shared to Improve Quality of Care and Safety

•Eligible Hospitals provide structured electronic lab results using LOINC to ordering providers•Threshold: Low



High High

Concerned about LOINC readiness, development could be substantial.Arien is going to determine current status and LOINC readiness.

Improving quality of care and safety:Unique device identifier (UDI)

9

• Recording FDA UDI to Improve Quality of Care and Safety

• NEW

• Menu: EPs and EHs should record the FDA Unique Device Identifier (UDI) when patients have devices implanted for each newly implanted device

• Threshold: High



Low Low

Development is low if only want a text field, but this provides low utility. Development effort would be much higher if some type of validation is required. This would allow the ability to identify whether a device has been recalled, but would be much harder.

Engaging patients and families in their care:View, download, transmit

10

• Access to health Information to Engage Patients and Families in their Care

• EPs/EHs provide patients with the ability to view online, download, and transmit (VDT) their health information within 24 hours if generated during the course of a visit

• Threshold for availability: High

• Threshold for use: low

– Labs or other types of information not generated within the course of the visit available to patients within four (4) business days of availability

• Add family history to data available through VDT



Low

Low maturity if need structured family history. The wording is different than stage 2, was this intended?

Medium

Significant operational issues. Concerned about timing to make this available to the patient. Workflow and attestation implications, but certification itself is not difficult.

Engaging patients and families in their care:Patient Generated Health Data (PGHD)

11

• Use of PGHD to Engage Patients and Families in their Care

• New

• Menu: Eligible Professionals and Eligible Hospitals receive provider-requested, electronically submitted patient-generated health information through either (at the discretion of the provider):

– structured or semi-structured questionnaires (e.g., screening questionnaires, medication adherence surveys, intake forms, risk assessment, functional status)

– or secure messaging

• Threshold: Low



Low HighDevelopers have to incorporate functionality for both strategies which can be configurable by the provider and results in high development

Engaging patients and families in their care:Secure messaging

13

Functionality Needed to Achieve Goals

•No Change in objective•Core: Eligible Professionals•Patients use secure electronic messaging to communicate with EPs on clinical matters. •Threshold: Low (e.g. 5% of patients send secure messages)•Certification criteria:

– Capability to indicate whether the patient is expecting a response to a message they initiate– Capability to track the response to a patient-generated message (e.g., no response, secure

message reply, telephone reply)



Low High

The industry already has implemented workflow solutions to ensure closing the loop on communications, prescribe the workflow is inappropriate. Encourage the concept, but discourage the specificity.

Engaging patients and families in their care:Visit summary/clinical summary

13

• Visit summaries used to Engage Patients and Families in their Care

• Core: EPs provide office-visit summaries to patients or patient-authorized representatives withrelevant, actionable information, and instructions pertaining to the visit in the form/media preferred by the patient

• Certification criteria: EHRs allow provider organizations to configure the summary reports to provide relevant, actionable information related to a visit.

• Threshold: Medium



Low

Uncertain how to define usability or relevant and actionable with a standard. Should not mandate usability, how is usability measured?

High

This is impossible to certify. Suggest providing patient access through VDT, rather than form/media preferred by the patient.

Engaging patients and families in their care:Patient education

14

• Functionality Needed to Achieve Goals

• Continue educational material objective from stage 2 for Eligible Professionals and Hospitals

– Threshold: Low

• Additionally, Eligible Providers and Hospitals use CEHRT capability to provide patient-specific educational material in non-English speaking patient's preferred language, if material is publicly available, using preferred media (e.g., online, print-out from CEHRT).

– Threshold: Low

• Certification criteria: EHRs have capability for provider to providing patient-specific educational materials in at least one non-English language



Medium

Medium, if using infobutton and language. Unsure how useful this objective is.

Medium/High

Medium/High, depending upon the number of languages supported and the nature the materials available.

• Summary of care may (at the discretion of the provider organization) include, as relevant:– A narrative (synopsis, expectations, results of a consult)

[required for all transitions]

– Overarching patient goals and/or problem-specific goals

– Patient instructions (interventions for care)– Information about known care team members

Improving care coordination:Summary of care

3

A Summary of Care is Provided at Transitions to Improve Care Coordination

• EPs/EHs/CAHs provide a summary of care record during transitions of care

• Threshold: No Change• Types of transitions:

– Transfers of care from one site of care to another (e.g.. Hospital to: PCP, hospital, SNF, HHA, home, etc)

– Consult (referral) request (e.g., PCP to Specialist; PCP, SNF to ED) [pertains to EPs only]

– Consult result note (e.g. consult note, ER note)


Discussion: Although structured data is helpful, use of free text in the summary of care document is acceptable. When structured fields are used, they should be based on standards (not all fields need to be completed for each purpose). Summary of care documents contain data relevant to the purpose of the transition (i.e. not all fields need to be completed for each purpose)

Provider Use Effort Standards Maturity Development Effort

High Medium=3, Low=2Vendor: Medium=1, Low=1

High=2, Medium=2, Low=1Vendor: High=2

Improving care coordination:Notifications

4Red: Changes Blue: Newly introduced Bright Red: edits for clarity

• Notifications of Significant Healthcare Events are Sent to Improve Care Coordination

• NEW

• Menu: Eligible Hospitals and CAHs send electronic notifications of significant healthcare events within 4 hours to known members of the patient’s care team (e.g., the primary care provider, referring provider, or care coordinator) with the patient’s consent if required

• Significant events include:

– Arrival at an Emergency Department (ED)

– Admission to a hospital

– Discharge from an ED or hospital

– Death

• Low threshold


High Medium=2, Low=3Vendor: Low=2

High=1, Medium=1, Low=3High=2

Improving care coordination:Medication Reconciliation

21

Functionality Needed to Achieve Goals

• No Change• Core: Eligible Professionals, Hospitals, and CAHs who receive patients from another setting of care

perform medication reconciliation. • Threshold: No Change



Low High=2, Low=3Vendor: High=1, Low=1

Medium=2, Low=2Vendor: Low=2

Improving population and public health:Immunization history

6

• Use of Immunization History to Improve Population and Public Health

• Core: EPs, EHs, CAHs receive a patient’s immunization history supplied by an immunization registry or immunization information system, allowing healthcare professionals to use structured historical immunization information in the clinical workflow

• Threshold: Low, a simple use case

• Certification criteria:

– Ability to receive and present a standard set of structured, externally-generated immunization history and capture the act and date of review within the EP/EH practice

– Ability to receive results of external CDS pertaining to a patient’s immunization



Medium Medium=3, Low=2Vendor: Medium=2

High=3, Medium=1, Low=1Vendors: High=1, Medium=1

Improving population and public health:Registries

7

• Transmit Data to Registry to Improve Population and Public Health

• Menu: EPs/ Menu: EHs

• Purpose: Electronically transmit data from CEHRT in standardized form (i.e., data elements, structure and transport mechanisms) to one registry

• Reporting should use one of the following mechanisms:

1. Upload information from EHR to registry using standards c-CDA

2. Leverage national or local networks using federated query technologies

Discussion: CEHRT is capable (certification criteria only) of allowing end-user to configure which data will be sent to the registries. Registries are important to population management, but there are concerns that this objective will be difficult to implement.



High Medium=2, Low=3Vendors: Low=2

High=3, Medium=1, Low=1Vendors: High=2

Improving population and public health:Electronic lab reporting

24

Electronic Laboratory Results Submitted to Improve Population and Public Health

• No Change• Core: EHs and CAHs submit electronic reportable laboratory results, for the entire reporting period,

to public health agencies, except where prohibited, and in accordance with applicable law and practice



Low High=3, Low=1Vendors: Medium=2

High=1, Medium=3Vendors: High=2

Improving population and public health:Syndromic surveillance

25

Submit Syndromic Surveillance Data to Improve Population and Public Health

• EH ONLY• Eligible Hospitals and CAHs (core) submit syndromic surveillance data for the entire reporting period

from CEHRT to public health agencies, except where prohibited, and in accordance with applicable law and practice



Medium High=1, Medium=1, Low=2Vendors: Medium=1, Low=1

High=2, Medium=1, Low=1Vendor: High=1, Medium=1

2015 Voluntary Certification NPRM

• 50 proposals

• Fixes many shortcomings in 2014

• Adds new requirements

• Embraces Postel’s principle

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What does more incremental rulemaking accomplish?

• Less change between editions of certification criteria.

• Makes rulemaking more nimble, better able to keep up with industry updates.

• Provides ample opportunity for public comment and earlier visibility into potential policy directions.

17

2015 Edition highlights

• Lab orders & CLIA compliance– Computerized Provider Order Entry (CPOE) for lab order IG– Incorporate lab test results updated IG

• Clinical Decision Support (CDS)– Propose the adoption of the Health eDecisions work.

• Requirements for computable CDS as well as interface requirements needed to request CDS guidance from a CDS supplier.

• Implantable device list– Record and display the unique device identifiers (UDIs) associated

with a patient’s implanted devices

18

2015 Edition highlights (2)

• Transitions of Care– Propose to separately test and certify:

• “Content” capabilities (i.e., Consolidate CDA); and• “Transport” capabilities (i.e., Direct Project specification).

– Propose to require testing to an “edge protocol” implementation guide

– Propose a new “performance standard” that would require EHR technology to successfully receive Consolidated CDA’s no less than 95% of the time.

– Data quality constraints to improve patient matching19

2015 Edition highlights (3)

• Patient Population Filtering for CQMs– Ability to create different patient population groupings

by, for example:• practice site • primary and secondary insurance

• Syndromic Surveillance– Propose to revise the 2014 Edition version as well as

adopt a 2015 Edition that mirrors those revisions• Add certification alternatives for CDA and QRDA III standards

20

ONC HIT Certification Program/Definitions

• “Complete EHR” certification– Propose to discontinue

• Outlived original intent• Misnomer

– Only applies to scope of all certification criteria not entire product

• Exceeds the flexibility now provided in the Certified EHR Technology definition

• Not necessarily “complete”– No guarantee that it will included all CQM capabilities– May not include capabilities designated as “optional” certification

criteria

21

2017 Edition Topics Under Consideration

1. Additional Patient Data Collection– Disability information – US Military Service– Work Information Industry/Occupation

2. Medication Allergy Coding3. Certification Policy for EHR Modules and Privacy and Security 4. Provider Directories5. Oral Liquid Medication Dosing6. Medication History7. Blue Button +8. 2D Barcoding9. Duplicate Patient Records10. Disaster Preparedness11. Certification of Other Types of HIT and for Specific Types of Health

Care Settings– Best way to distinguish beyond “EHR technology”– Specific types of health care settings

22

Hardship Exemption

• Adds a section for challenges with implementation due to delays in product releases/certification

• Avoids 2016 penalty

• Eliminates stimulus opportunity for the missed year


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The Work Ahead

• Reorganization of HIT Standards Workgroups

• Complete MU3 evaluation

• Complete NPRM evaluation

• Rulemaking in parallel with script development (outside of rulemaking)

• Hearings and feedback


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The future: 3-year ONC Rulemaking Roadmap(milestones reflect best guestimates)

25

Q1

CY 2014 CY 2015 CY 2016

2015Ed NPRM

2015Ed Final

PublicComment 2017Ed

Final

2018Ed NPRM

PublicComment

PublicComment

2017Ed NPRM

& MU3 NPRM

& MU3 Final

MU2 EP

Start Date

Announced

Anticipated

MU3 EH

Start Date

Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

2018Ed Final


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“HIT Policy Update”Colleen Sirhal, RN, BSN, CPHIMS, Director of

International Healthcare Sales, Hyland

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Contact Information

• Colleen Sirhal, Director of International Healthcare Sales, Hyland

• [email protected]

• www.onbase.com/healthcare

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Documents

“HIT Policy Update With John Halamka, MD”healthsystemcio.com/presentation/policyupdate-2014q1-webinar.pdf · Meaningful Use Stage 3 Recommendations •Meaningful Use Workgroup