In response to my post on Meaningful Use Audits and the Inconsistent Appeals Process, Todd Searls. Executive Director at Wide River LLC, offered this interesting meaningful use audit advice on LinkedIn:
We’ve assisted numerous clinics and hospitals through their audits, and you’re absolutely correct John. Those clinics that have the people and processes already in place, this ends up (most of the time), being a non -issue, just time consuming. However, we have clients that have undergone significant changes since 2011 and now that they are being audited, the changes are coming back to haunt them since tracking MU documentation through the changes may not have been the highest priority.
Even those clinics that have the right documentation are now finding that they shouldn’t just mail the documents in bulk to the auditors unless they’ve spent time creating a good summary document which clearly defines each and every appendix document being sent. Case in point, we had one clinic call us to help them with their appeal for a failed audit. When we engaged we spent a few hours trying to determine why they failed the audit since the documents they had on file to support their attestation were excellent. Then we reviewed how they sent them in (in just one mass mailing with no cover letter or explanation beyond a title for each document (ie, In Reference to Measure 2)).
Once we created a clear cover letter and resubmitted, they were notified very quickly that their appeal was successful. The clinic had mixed feelings – great that they passed, but unhappy about having to ‘mind-read’ the preferred format that the auditor was looking for. Right or wrong, many clinics are in the same place – frustrated with the process.
I don’t know anyone who enjoys an audit. However, an audit can at least be bearable if it’s clear what’s expected in the audit. I think we’re going to have a lot more stories about meaningful use audits coming down the pipe. Hopefully Todd’s advice helps some who run into a meaningful use audit.
I think that most of us in the industry figured this was just a matter of time, but it’s nice that we were right and CMS is working to modify the requirements and reporting periods for meaningful use. I imagine they heard all the many voices that were calling for a change to meaningful use stage 2 and it’s just taken them this long to work through the government process to make it a reality.
Before I act like this change is already in place, CMS was very specific in the wording of their announcement about their “intent to modify requirements for meaningful use” and their “intent to engage in rulemaking” in order to make these “intended” changes. Basically they’re saying that they can just change the rules. They have to go through the rule making process for these changes to go into effect. That said, I don’t think anyone doubts that this will make it through the rule making process.
Here’s the modifications that they’re proposing:
They also added this interesting clarification and information about the meaningful use stage 3 proposed rule:
To clarify, we are working on multiple tracks right now to realign the program to reflect the progress toward program goals and be responsive to stakeholder input. Today’s announcement that we intend to pursue the changes to meaningful use beginning in 2015 through rulemaking, is separate from the forthcoming Stage 3 proposed rule that is expected to be released by early March. CMS intends to limit the scope of the Stage 3 proposed rule to the requirements and criteria for meaningful use in 2017 and subsequent years.
I think everyone will welcome a dramatic simplification of the meaningful use program. The above 3 changes will be welcome by everyone I know.
In the email announcement for this, they provided an explanation for why they’re doing these changes:
These proposed changes reflect the Department of Health and Human Services’ commitment to creating a health information technology infrastructure that:
- Elevates patient-centered care
- Improves health outcomes
- Supports the providers who care for patients
Personally, I think they saw the writing on the wall and it wasn’t pretty. Many organizations were going to opt out of meaningful use stage 2. These changes were needed and necessary for many organizations to continue participating in meaningful use. They believe meaningful use will elevate patient-centered care, improve health outcomes, and support the providers who care for patients. I’m glad they finally chose to start the rulemaking process to make the changes. I think many that started meaningful use can still benefit from the rest of the incentive money and will be even happier to avoid the penalties.
Value based payments. Value based care. Meaningful use. Is there a place for an independent doctor in a suburban location? This article says that these and all the technology to go with them along with physician acceptance is “Inevitable”.
I have four physicians. I don’t see a place for them long term. My first is my Internist. A few years ago he was given a cell phone as a gift. It does all he will ever want. If it rings, he answers it. If he has to make a call, he dials the number. He has no computers in his office. All his files are paper. As a Doctor he is recognized as one of the best in the state. EHR is not in his future. Phones, fax, copier suit him just fine. The article that raised these questions for me was a report from Deloitte. You might end up with some of the same questions after reading it.
My second physician has been using EHR for as long as I have known him. He has 2 offices and four other doctors working for him. He needs the technology. He hates it, upgrades only when he has to and would never do it again. He is also recognizes as one of the best in the state. His daughter is now in her residency and will join him next year. My gut feel is that in 3-4 years he turns the business over to her, let’s her worry about it and sails off into the sunset.
My radiation oncologist was great. He treated me 8 years ago. My last visit with him was 4 years ago. The company he worked for terminated him for not generating enough revenue. His waiting room was always filled but with little to no wait. His staff was great and could have easily made more money by moving to a large city. They, like he, enjoyed the suburban life. All were dumbfounded when he was terminated. They also learned that for this big city practice, profit was the only incentive. He’s in FL now, out in the sticks and owns his own practice.
Doctor #4 is a general surgeon. He is probably the only one that could/would survive in the “inevitable market”. His office is at the medical arts building at the local hospital. There are 3 other surgeons in his practice. He has a fairly up to date computer system, though not in his location and not compatible with the hospitals new system. I know that his definition of value based anything and mine differ. On my last visit he kept me waiting for 45 minutes because lunch went longer than scheduled. He’s all business.
For 3 of these 4 I see the choice of conforming and or selling out. They are all rated in the top 25 physicians in the state. They are not going to increase their patient base to increase revenue.
I am sure that Doctor #4 will succeed. He is all and only business. He holds the purse strings for his practice and has absolutely no problem in spending whatever it takes for technology to increase profit. As long as he doesn’t have to use it.
The area that I live in is not unique The hospital‘s area of reach is a bit under 60,000. As part of that is a resort area, add another 10K for the summer months. Is there a future for physicians like this? If so, what will they need to do to stay viable? Hire a business manager? More nurse Practitioners? Sell, retire or join together a form their own physician groups? Any thoughts?
Today we held the first ever #HITMC (Healthcare IT Marketing and PR Community) Twitter chat. The turnout for the chat was amazing and it was so active I don’t think anyone could keep up. That’s pretty amazing for a first time chat. In case you missed it and are interested in health IT marketing and PR, here’s my tweet that links to the transcript:
— HIT Marketing and PR (@HITMarketingPR) January 27, 2015
I’m particularly interested to look back at the answer to question 3 on the chat which talks about the tools that people use to make their lives easier.
Here’s a look at the stats for the first HITMC chat:
— HIT Marketing and PR (@HITMarketingPR) January 27, 2015
All of this tells me that I should have started this twitter chat sooner. It’s amazing how a Twitter chat can really bring a community together. Plus, it always leads to interesting new connections that wouldn’t have happened otherwise. Tomorrow I’ll be participating in another new Twitter chat that’s focused on Health Information Governance. If that topic interests you, be sure to join us on #InfoTalk at Noon ET on January 28th.
We’re also 5 days away from the end of Early Bird Registration for the Health IT Marketing and PR Conference. Register now and save $500 off the registration price. Plus, as a reader of EMR and HIPAA, use the promo code “emrandhipaa” and you’ll save an extra $100. We’ve just started uploaded the speaker profiles for those who will be speaking at the event. It’s going to be a fantastic 2+ days of the best in healthcare IT marketing and PR. I can’t wait!
For those not interested in the above topics. Tomorrow we’ll be back with our regularly scheduled programming.
Stephen Claypool, M.D., is Vice President of Clinical Development & Informatics, Clinical Solutions, with Wolters Kluwer Health and Medical Director of its Innovation Lab. He can be reached at email@example.com.
Three-week-old Jose Carlos Romero-Herrera was rushed to the ER, lethargic and unresponsive with a fever of 102.3. His mother watched helplessly as doctors, nurses, respiratory therapists and assorted other clinicians frantically worked to determine what was wrong with an infant who just 24 hours earlier had been healthy and happy.
Hours later, Jose was transferred to the PICU where his heart rate remained extremely high and his blood pressure dangerously low. He was intubated and on a ventilator. Seizures started. Blood, platelets, plasma, IVs, and multiple antibiotics were given. Still, Jose hovered near death.
CT scans, hourly blood draws and EEGs brought no answers. Despite all the data and knowledge available to the clinical team fighting for Jose’s life, it was two days before the word “sepsis” was uttered. By then, his tiny body was in septic shock. It had swelled to four times the normal size. The baby was switched from a ventilator to an oscillator. He received approximately 16 different IV antibiotics, along with platelets, blood, plasma, seizure medications and diuretics.
“My husband and I were overwhelmed at the equipment in the room for such a tiny little person. We were still in shock about how we’d just sat there and enjoyed him a few hours ago and now were being told that we may not be bringing him back home with us,” writes Jose’s mother, Edna, who shared the story of her baby’s 30-day ordeal as part of the Sepsis Alliance’s “Faces of Sepsis” series.
Jose ultimately survived. Many do not. Three-year-old Ivy Hayes went into septic shock and died after being sent home from the ER with antibiotics for a UTI. Larry Przybylski’s mother died just days after complaining of a “chill” that she suspected was nothing more than a 24-hour bug.
Sepsis is the body’s overwhelming, often-fatal immune response to infection. Worldwide, there are an estimated 8 million deaths from sepsis, including 750,000 in the U.S. At $20 billion annually, sepsis is the single most expensive condition treated in U.S. hospitals.
Hampering Efforts to Fight Sepsis
Two overarching issues hamper efforts to drive down sepsis mortality and severity rates.
First, awareness among the general population is surprisingly low. A recent study conducted by The Harris Poll on behalf of Sepsis Alliance found that just 44% of Americans had ever even heard of sepsis.
Second, the initial presentation of sepsis can be subtle and its common signs and symptoms are shared by multiple other illnesses. Therefore, along with clinical acumen, early detection requires the ability to integrate and track multiple data points from multiple sources—something many hospitals cannot deliver due to disparate systems and siloed data.
While the Sepsis Alliance focuses on awareness through campaigns including Faces of Sepsis and Sepsis Awareness Month, hospitals and health IT firms are focused on reducing rates by arming clinicians with the tools necessary to rapidly diagnose and treat sepsis at its earliest stages.
A primary clinical challenge is that sepsis escalates rapidly, leading to organ failure and septic shock, resulting in death in nearly 30 percent of patients. Every hour without treatment significantly raises the risk of death, yet early screening is problematic. Though much of the data needed to diagnose sepsis already reside within EHRs, most systems don’t have the necessary clinical decision support content or informatics functionality.
There are also workflow issues. Inadequate cross-shift communication, challenges in diagnosing sepsis in lower-acuity areas, limited financial resources and a lack of sepsis protocols and sepsis-specific quality metrics all contribute to this intractable issue.
Multiple Attack Points
Recognizing the need to attack sepsis from multiple angles, our company is testing a promising breakthrough in the form of POC Advisor™. The program is a holistic approach that integrates advanced technology with clinical change management to prevent the cascade of adverse events that occur when sepsis treatment is delayed.
This comprehensive platform is currently being piloted at Huntsville Hospital in Alabama and John Muir Medical Center in California. It works by leveraging EHR data and automated surveillance, clinical content and a rules engine driven by proprietary algorithms to begin the sepsis evaluation process. Mobile technology alerts clinical staff to evaluate potentially septic patients and determine a course of treatment based on their best clinical judgment.
For a truly comprehensive solution, it is necessary to evaluate specific needs at each hospital. That information is used to expand sepsis protocols and add rules, often hundreds of them, to improve sensitivity and specificity and reduce alert fatigue by assessing sepsis in complex clinical settings. These additional rules take into account comorbid medical conditions and medications that can cause lab abnormalities that may mimic sepsis. This helps to ensure alerts truly represent sepsis.
The quality of these alerts is crucial to clinical adoption. They must be both highly specific and highly sensitive in order to minimize alert fatigue. In the case of this specific system, a 95% specificity and sensitivity rating has been achieved by constructing hundreds of variations of sepsis rules. For example, completely different rules are run for patients with liver disease versus those with end-stage renal disease. Doing so ensures clinicians only get alerts that are helpful.
Alerts are also coupled with the best evidence-based recommendations so the clinical staff can decide which treatment path is most appropriate for a specific patient.
The Human Element
To address the human elements impacting sepsis rates, the system in place includes clinical change management to develop best practices, including provider education and screening tools and protocols for early sepsis detection. Enhanced data analytics further manage protocol compliance, public reporting requirements and real-time data reporting, which supports system-wide best practices and performance improvement.
At John Muir, the staff implemented POC Advisor within two medical/surgical units for patients with chronic kidney disease and for oncology patient populations. Four MEDITECH interfaces sent data to the platform, including lab results, pharmacy orders, Admit Discharge Transfer (ADT) and vitals/nursing documentation. A clinical database was created from these feeds, and rules were applied to create the appropriate alerts.
Nurses received alerts on a VoIP phone and then logged into the solution to review the specifics and determine whether they agree with the alerts based on their clinical training. The system prompted the nursing staff to respond to each one, either through acknowledgement or override. If acknowledged, suggested guidance regarding the appropriate next steps was provided, such as alerting the physician or ordering diagnostic lactate tests, based on the facility’s specific protocols. If alerts were overridden, a reason had to be entered, all of which were logged, monitored and reported. If action was not taken, repeat alerts were fired, typically within 10 minutes. If repeat alerts were not acted upon, they were escalated to supervising personnel.
Over the course of the pilot, the entire John Muir organization benefited from significant improvements on several fronts:
Finally, physicians reported higher confidence in the validity of information relayed to them by the nursing staff because they knew it was being communicated based on agreed upon protocols.
Within three months, John Muir experienced significant improvements related to key sepsis compliance rate metrics. These included an 80% compliance with patient screening protocols, 90% lactate tests ordered for patients who met screening criteria and 75% initiation of early, goal-directed therapy for patients with severe sepsis.
Early data from Huntsville Hospital is equally promising, including a 37% decline in mortality on patient floors where POC Advisor was implemented. Thirty-day readmissions have declined by 22% on screening floors, and data suggest documentation improvements resulting from the program may positively impact reimbursement levels.
This kind of immediate outcome is generating excitement at the pilot hospitals. Though greater data analysis is still necessary, early indications are that a multi-faceted approach to sepsis holds great promise for reducing deaths and severity.