In response to the request from Congresswoman Renee Ellmers—a fellow North Carolinian—to exempt soon-to-retire doctors and small medical practices from the federal requirement to use an electronic health record (EHR), I say ‘Not needed.’

I am 66 years of age and I adopted an EHR in January 2011, when I was 64. The upfront cost was reasonable and training was done without interrupting my schedule. In addition, since my vendor—athenahealth—is only paid if I am paid, they have a vested interest in making certain that claims are filed and paid in a timely manner.

For the first three months in 2011, I learned to use the system. During the next three months, I fulfilled all the requirements for Meaningful Use and I attested at the end of June. A few months later, I received my check for $18,000 without any significant hassle on my part—the attestation was all done by my vendor. 

I find that using the athenahealth electronic health record has greatly improved my documentation, virtually eliminated claims denials or resubmissions, facilitated communications with other health providers and patients, and has even reduced postage and office supplies. It did not impact my workflow because the system is easily modified (by me, not the vendor). Moreover, some of the requirements of Meaningful Use helped me deliver better patient care–like the requirement that I provide a clinical summary to patients after their visit.

Physicians of my age went to medical school during the ‘60s and ‘70s. The application process was very competitive and, as a result, they are all smart people. To imply that we are incapable of adopting and learning to efficiently use an EHR is nonsense. To the good Congresswoman, I would reply that her time could be better spent concentrating her efforts on bringing Medicare reimbursement in line with private insurance carriers.

Dr. Eubanks is an athenahealth client.

If you read the athenahealth blog regularly, you know we tend to write about and discuss Meaningful Use.

Often.

We have a good reason. We have approached Meaningful Use the way we approach everything we do—by working with our providers to get them paid for doing the right thing. To that end, we offered the industry’s only incentive guarantee, established a Meaningful Use Resource Center for clients, held a multitude of MU webinars and created a cross-functional team to tackle each problem clients might face. And our CEO, Jonathan Bush, pulled a Full Monty (of his data) while in Las Vegas for the MGMA convention last October.

Our approach worked! We helped 85% of our eligible, participating physicians attest to the Stage 1 measures and receive their incentive payments.

With so much blood, sweat and tears invested in the Meaningful Use of our EHR by providers, we jumped at the opportunity offered by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) to provide comments in response to two sets of rules: The Meaningful Use Stage 2 Notice of Proposed Rulemaking (NPRM)—“CMS Rule”—and the 2014 Edition EHR Standards and Certification Criteria Proposed Rule—“ONC Rule”. In future posts, we’ll dig into key topics in greater detail but, for now, we thought it’d be helpful to summarize what we submitted on May 7th.

General Thoughts on the CMS and ONC Proposed Stage 2 Rules

We are highly encouraged by the inclusion and expansion of objectives and measures related to the exchange of health information, patient engagement, and quality reporting. The increased focus on these critical areas will lay the foundation for providers to leverage health IT to promote better care for individuals, improved population health and increased value in health care (aka the health care “Holy Grail”.)
Because there is often a variance between standards and their implementation, we believe a high degree of harmony between the ONC Rule and CMS Rule is fundamental to the Certified EHR Technology (“CEHRT”) vendors’ ability to help providers achieve Meaningful Use. We also think it’s vitally important for the ONC and CMS to create enough rules flexibility to encourage continued innovation. (PLEASE!)

In the specific case of health information exchange, we hope the ONC will consider the certification criteria as the minimum, baseline standard upon which existing and new means of electronic exchange can support providers in achieving Meaningful Use.

Last, we greatly appreciate the many ways CMS and the ONC have fostered a transparent rule-making process: public access to the Federal Advisory Committee meetings and recommendations; presence at industry events like the HIMSS12 conference; and, opportunities to participate in private-public collaborations. The efforts made by CMS and ONC representatives to educate the public on comment-making best practices have been great too.

Our Comments to the CMS and ONC

So, what did athenahealth contribute to the conversation? In our comments to CMS, we focused on:

• Why the implementation of Stage 2 should not be delayed
• Health Information Exchange
  • A logistically feasible, cross-vendor-and-organization alternative to the electronic provision of summary care record at transitions of care
  • Supply chain issues with incorporating lab results as structured data
• Patient Engagement
  • An alternative to the proposed secure messaging measure
  • Considerations for the implementation of View, Download, & Transmit
• How to aggregate data and attest with an EHR conversion

We also commented to the ONC about their Proposed Rule:

In addition to the nitty-gritty, technical issues, at a high level we also covered:

• Reporting on Patient Safety Events and the vendor’s role
• Support of a flexible and process-based approach to Quality Systems
• Ideas on how to facilitate data portability
• The importance of maintaining “Complete EHR” as a concept

Finally, we urged the ONC and CMS to continue driving transparency by a) continuing to make vendor, specialty and state attestation data publicly available; b) releasing registration-by-vendor data to inform providers during their EHR purchasing decisions; and, c) private-public sector collaboration.

So, now we wait. CMS will review 230 comments and the ONC will review 400. And what a range of comments they have to consider. To cite a few:

• The American Hospital Association has expressed its opinion that the proposed rule sets the bar for Stage 2 too high.
• The Electronic Health Record Association has also shared some concern about reporting requirements.
• Rep. Renee Ellmers, R-NC, a nurse who is married to a surgeon, asked CMS to exempt doctors from the Meaningful Use program who are in small practices or are close to retirement.

What do you think? How did you weigh in? We’ll keep you posted as the comments get reviewed during HIT Policy committee and HIT Standards committee meetings over the next couple of months. But now, we’d like to hear from you.

We are always happy to see coverage of electronic health records (EHR) pop up beyond medical or health IT news outlets. As a cloud-based service to medical practices and health care systems, we spend our time talking to those audiences because we are, well, trying to share the distinct benefits of our services. But an EHR is ultimately about an individual patient—and every patient should know more about the future of medical records.

So, recent coverage in the Boston Globe about EHR adoption got our attention. (As a company with a mantra about going paperless, a headline that says “Goodbye Paper” is particularly apt.)

The story included this infographic about the spread of EHR technology and the disbursement of federal incentive dollars under the Meaningful Use program.

And while it’s not exactly going to make the evening news, the Government Accountability Office just published a report on the first year of the Meaningful Use program. 

One of athenahealth’s concerns about the Meaningful Use program has been the lack of a method to verify that physicians across the country have met the measures. Thankfully, that’s not an issue for athenahealth. Since we operate in the cloud, we can see even the smallest grains of data in the network. In fact, we have been able to regularly report out on the progress of our client physicians on their path to Meaningful Use of an EHR as they met and attested to the measures.

While we can verify what physicians on our network do, how can that be done with software-based solutions, when they don’t afford the visibility of a cloud-based network? We hold ourselves to a high standard of integrity and we want to be sure that that the truly meaningful users get rewarded. It turns out that the government seems to agree and the auditors at the GAO would like to see a better process for verifying performance.

The GAO made the following recommendations to the Centers for Medicare & Medicaid Services (CMS), which administers the Meaningful Use program:

• Establish time frames for expeditiously implementing an evaluation of the effectiveness of the agency’s audit strategy for the Medicare EHR program.
• Evaluate the extent to which the agency should conduct more verifications on a prepayment basis when determining whether providers meet Medicare EHR program’s reporting requirements.
• Collect the additional information from Medicare providers during attestation that CMS suggested states collect from Medicaid providers during attestation.
• Offer states the option of having CMS collect meaningful use attestations from Medicaid providers on their behalf.

What do you think? How has the experience with Meaningful Use treated you and your practice of medicine?

There’s still time to weigh in on the Meaningful Use of EHR! We’re about a month away from the submission deadline for comments in response to two Notices of Proposed Rulemaking (NPRM): The Centers for Medicare and Medicaid Services (CMS) Meaningful Use Stage 2 NPRM; and the Office of the National Coordinator for Health Information Technology (ONC) 2014 Standards and Certification NPRM. And you can provide valuable feedback to the ONC and CMS. 

Why is your feedback so important?

Because officials in DC or other vendor headquarters simply do not have your clinical expertise and day-to-day insights on the use of an EHR. Yes, athenahealth is in the process of developing our own comments. And while we plan to represent the interests of our clients—primarily with respect to administrative requirements and the best utilization of health IT—we strongly encourage providers and administrators like you to submit your own comments, too. 

Luckily, CMS and the ONC have created a helpful site that tells you exactly how to submit comments. You’ll find the two proposed rules, a video overview of the Stage 2 requirements, fact sheets for both and links to where you can electronically submit your comments. 

If you don’t have time to read both rules, I recommend you focus on the CMS Rule—the Stage 2 NPRM—and that you register for our next Stage 2 webinar, scheduled for April 25th, to get an overview of what the rule entails. 

You can also zip through the rules by doing a search for “comment” using the “Ctrl+F” function on your keyboard. This isn’t an exact science, but that search should get you to all the places where CMS specifically wants feedback.

What do you think? If you have some thoughts you want to share with colleagues, comment right here.

First, thanks to all 557 of you who registered for our March 21 webinar, “The Next Step in Meaningful Use: Responding to and Preparing for Stage 2.” It was our highest registration and attendance of the year. If you missed it, all our webinars are available on-demand anytime, including the March 21 presentation— and luckily, there’s no grilling by any Supreme Court justices.   

As far as webinar success goes, this one also featured really good questions from you. We always try to answer as many as we can during a live webinar and then follow up later. Kudos to those of you who had done your Meaningful Use homework!

Given the popularity of this Stage 2 MU webinar, we’re planning to do it again April 25. In order to make it the best experience possible, we’re asking for your input: What questions do you have about Stage 2? Do you want to know how to use your EHR more efficiently to achieve the measures?  Do you have questions about health reform in general? (While I have your attention, I recommend taking a look at an awesome health care reform guide from Thomson Reuters, titled “Vocabulary of Healthcare Reform”.)  

Monitoring government and industry activities, and asking for input, is all a usual part of our software development and client service. Take, for instance, the Meaningful Use pilot and the Stage 1 testing we conducted to prepare our clients for Meaningful Use of our EHR. As we did last year for Stage 1, we’ll continue to provide you a behind-the-scenes look at what we’re doing, so you can benefit from our network of knowledge. 

Here’s an example, a video we produced when we were in the thick of it with Stage 1. There’s actually quite a bit involved … Ah, the good old days.

So now that we’re moving on to Stage 2, let us know your questions. What can we answer for you? Just email  blog@athenahealth.com or leave your question in a comment below.

Stay tuned. We’ll ask for more input next week.