Meaningful Use of EHR and the $44,000 Incentive: More Than Meets the Eye
Dear Editor:
Buying a certified EHR software will not make you eligible to be paid back from the stimulus package.
My response: "I have been working at EHR about 80 hours per week, 50 weeks per year for the past 22 years. I have been following the stimulus program for awhile and I have bad news for you. The government has not been proven to be Santa Claus yet. Buying a $15,000 certified software system will not entitle you to receive a penny from the stimulus package. But the good news is that I can make you save $15,000. If you are thinking of buying chiropractic EHR software with the only goal to receive $44,000, you will fail and lose $15,000. Don't buy any and you will save that money."
Don't get me wrong; I am not saying not to adopt electronic health records. If you are using a good EHR system now, you know how great it is. If you don't, you have no clue what you are missing. I have not seen any doctor switch back from EHR to paper yet, and I am talking about many thousands of chiropractic doctors I know of. What I am saying is that buying a certified software does not entitle any practitioner to receive any incentives. To be eligible to receive stimulus incentives, you must show meaningful use of a certified system. And we are talking about many meaningful use objectives. The final rules came out on July 13, 2010.
Of the 25 criteria initially proposed, 15 of them are considered "core" and necessary to qualify. The other 10 are considered "optional" items, from which only five need to be demonstrated, with the remaining ones postponed until stage 2 meaningful use (in 2013). The "core" criteria for ambulatory settings are as follows:
- Record patient demographics (including gender, race and ethnicity, date of birth,preferred language) at least 50% of the time.
- Record vital signs (height, weight, blood pressure, body mass index, and growth charts for children) at least 50% of the time.
- Maintain up-to-date problem lists at least 80% of the time.
- Maintain active medication lists at least 80% of the time.
- Maintain active medication allergy lists at least 80% of the time.
- Record smoking status for patients >13 years of age at least 50% of the time.
- Provide patients with a clinical summary for each office visit within three business days at least 50% of the time.
- On request, provide patients with an electronic copy of their health information (including test results, problem lists, meds lists, allergies) within three business days at least 50% of the time.
- Generate electronic prescriptions at least 40% of the time.
- Use Computerized Physician Order Entry (CPOE) for medication orders at least 30% of the time. (Note: CPOE for lab ordering, imaging ordering, and referrals is not addressed here - only medications.)
- Implement drug-drug and drug-allergy interaction checks at least 40% of the time.
- Be able to exchange key clinical information among providers by performing at least one test of the EHR's ability to do this.
- Implement one clinical decision support rule and ability to track compliance with the rule (this is reduced from the previous five rules to the final one rule).
- Implement systems that protect privacy and security of patient data in the EHR by conducting or reviewing a security risk analysis and taking corrective steps if needed.
- Report clinical quality measures to CMS or states - for 2011, provide aggregate numerator and denominator through attestation; for 2012, electronically submit measures (this refers to PQRI measures).
In addition to the 15 "required" elements noted above, a physician must also demonstrate meaningful use with respect to at least five of the following 10 items:
- Implement drug-formulary checking.
- Incorporate lab test data into the EHR as structured data.
- Generate lists of patients by specific conditions (to use for quality improvement, reduce disparities, research or outreach).
- Use EHR technology to identify patient-specific education resources and provide those to the patient as appropriate - and do this at least 10% of the time.
- Provide medication reconciliation between care settings at least 50% of the time.
- Provide summary of care record for patients transferred to another provider or setting at least 50% of the time.
- Submit electronic immunization data to local registries (performing at least one test of data submission where registries can accept them).
- Submit electronic syndromic surveillance to public health agencies (perform at least one test where local agencies can accept them).
- Send reminders to patients (per patient preference) for preventive and follow-up care at least 20% of the time for all patients 65 years and older or 5 years old and younger.
- Provide patients with timely electronic access to their health information at least 10% of the time.
Although it seems that chiropractors will be exempt from the meaningful use requirements concerning drugs/prescriptions, they will have to make some serious adjustment to their actual practice in order to meet all of the other meaningful use requirements. On the Web site of the only active certifier in the field to date, the Certification Commission for Health Information Technology (CCHIT; www.cchit.org), there is no chiropractic software certified, neither partially or completely, that I can see.
A software developer may have their software certified partially to meet one or a few meaningful use requirements. However, if you buy such a software, you will have to buy some others to meet all the requirements and get paid. Having to buy multiple softwares to get all the meaningful use requirements fulfilled can be very costly and may turn out to be very hard to implement.
If you have the intention of getting certified in order to be eligible to receive some money from the incentive program and you shop for a certified software, don't ask if they are certified; ask if they are certified for all of the 25 meaningful use requirements. This is particularly important. Many software providers are saying they will be certified, but a "will be" is not sufficient. They need to say they are certified for 25 meaningful use criteria. Although it is not impossible, it will not be that easy for chiropractors to get reimbursement from the stimulus package.
Back to my conversations with doctors. When I tell them that buying EHR software will not guarantee them incentive money, they ask: "Then why do we read and hear from many software vendors or doctors that we need to rush buying a certified software in order to receive the stimulus incentive? Why do they show us the payments schedule from 2011 to 2015?"
My response: This is what we call marketing. Buying a certified software is the first step, but showing 20 meaningful use objectives (out of 25) is what really matters. (The final number of meaningful use objectives to be met by chiropractors will depend on how they clearly rule out objectives relative to medications.) Legacy certification (CCHIT certification) will not suffice; meeting the meaningful use criteria with your Medicare patients is what will determine how much you receive.
Claude Cote
President,
Platinum Systems, Inc.
Exposing Research Bias
Dear Editor:
Thank you so much for the article on straw men by Dr. Anthony Rosner ["Straw Men on Parade: When Research Findings Get Misrepresented," July 15 issue]. Not only was it well-written and thoroughly referenced, [but it also] provided a welcome reminder of the sometimes misleading nature of research studies. We shouldn't be so quick to accept the findings at face value.
I've also noticed that study conclusions can be skewed by the bias of the researchers. Their interpretations can often seem completely removed from the study itself. After reading certain abstracts, I reached an entirely different conclusion. "What planet were they from?" I wondered.
We all know that four people watching an event (like an auto-accident) can interpret it four different ways. I think the same holds true for study outcomes. Perspective matters. If ever in doubt, read the entire abstract yourself and come to your own conclusions. Also, to incorporate Dr. Rosner's point, check out the methodology, too.
Lisa Moore, DC
Fair Oaks, Calif.
An Eye for an Eye?
Dear Editor:
I find it curious that in his condemnation of straw men, Dr. Rosner sets up one of his own. He implies that even though applied kinesiology fails clinical testing through multiple clinical trials and that manual muscle testing also fails to show legitimacy as an indicator of spinal pathology, there must still be merit to AK since every single aspect has not yet been thoroughly tested. This is a little like saying the sum of the parts must equal something other than the sum of the parts. Perhaps it equals straw.
Brett Kinsler, DC
Rochester, N.Y.