2015 iht2 health it beverly hills summit
TRANSCRIPT
How to Survive and Sustain Meaningful Use
Sandy Summers Director of Meaningful Use
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Reflection
“Whether you think you can, or
think you can’t…you’re
right!” Henry Ford
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Learning Objectives
Learn effective program management strategies for achieving Meaningful Use for multiple sites, stages, vendors and jurisdictions for Stage 1 and Stage 2
Learn successful techniques for the most challenging Meaningful Use Stage 2 objectives:
• Patient Electronic Access (View-Download-Transmit)
• Summary of Care transmission
• Public Health Interfaces
Learn proven techniques for proactive audit defense and audit response for Figliozzi audits and OIG audits
Learn new challenging scope and targets for Stage 3
Dignity Health
Background:
• Dignity Health, one of the nation’s largest health care systems, is a 20-state network of nearly 9,000 physicians, 56,000 employees, and more than 400 care centers, including hospitals, urgent and occupational care, imaging centers, home health, and primary care clinics. Headquartered in San Francisco, Dignity Health is dedicated to providing compassionate, high-quality and affordable patient-centered care with special attention to the poor and underserved.
Mission
• Dignity Health is committed to furthering the healing ministry of Jesus. We dedicate our resources to delivering compassionate, high-quality, affordable health services; serving and advocating for our sisters and brothers who are poor and disenfranchised; and partnering with others in the community to improve the quality of life.
Community Activity:
• In FY14, Dignity Health provided nearly $2 billion in charitable care and services
HQ: San Francisco
Net Operating Revenue:
(FY14) $10.7 billion
Hospitals: 39
Clinics/Ancillary Care
Centers: 400+
Medical Groups within
Dignity Health Medical
Foundation: 15
Employees: 56,000
Physicians: 9,000
Acute Care Beds: 8,500
Skilled Nursing Beds: 700
Last updated: May 6, 2015
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Dignity Health Meaningful Use Program Management
Program Governance and Organization
Structure – Centralized
Meaningful Use Attestation Plan
Communication Plan Education Events
(workshop, webinars)
MU Objective Compliance Plans with
focus on tougher measures
Attestation Activities (Data generation and
review, sign-off, entry/submission)
Document retention (SharePoint and secure
network archives)
Financial impact analysis and monitoring
Audit defense preparation and
response
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Program Governance and Organization Structure
Clinical Program Executive
Program Director
Clinical Analyst(s)
Business Analyst(s)
Business Intelligence Analyst(s)
Regulatory Compliance
SME (s) e.g., CHAN
Interoperability SME(s)
Leadership Core Team Specialists
Security Risk SME(s)
Application Interface SME(s)
Patient Portal SME(s)
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Program History and Summary
• The MU program has grown from 8 sites to 29 sites attesting
• 77 total hospital attestations to date
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Meaningful Use Program Tools
Public health authority readiness status
tracker tool (Example follows)
Audit defense checklist and manual
(Example follows)
Audit defense toolkit (includes sample
screenshots needed)
Financial incentives and reductions log / pivot analysis tool
Audit defense materials for all known requests to date for each site (e.g., redacted vendor contracts
for certified software)
Attestation status tracker by year
Certified Health Product List / CMS
certification ID log tool by site by program year
Attestation timeline (flight plan)
(Example follows)
Helpful for …
• visualizing all sites in flight regardless of year, stage, or EHR platform
• communicating with project management and application scheduling team
Dignity Health Meaningful Use Attestation Timeline
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• ARRA Overview – Regulatory Context
• HHS Strategic Framework
• Financial Incentives and Reductions
• Attestation Timeline
• Specific MU Objectives by Stage, especially Security Risk Analysis, Public Health, Clinical Decision Support
• Audit Defense and Response
• Document retention
• Clinical Quality Measures
• MU Program Team; roles and responsibilities
• Identifying key site stakeholders; roles and responsibilities
• Workflow for key elements data capture
• Lessons learned by MU objective
• Training on report execution and monitoring
• Strategic Conversation; Identification of key decisions to be made
Meaningful Use Education Workshops Executive Overview and Deep Dive Conducted at Each Site
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Communication Strategies
Establish governance at
each site
Leverage existing meeting structures
as feasible Program calendar
Stakeholder contact list
Vendor management
Steering calls for key stakeholder
groups
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Program Management Meeting Agenda Topics
Vendor update MU measures
data monitoring & trending
RAID management
Review of regulatory
rulings
Workflow analysis
Decisions on changes needed
Communication strategy
developed
Tip Sheets developed
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Site Steering Meeting Agenda Topics
Review of MU Functional Reports
Sharing Lessons Learned & leading
practices
Speakers on Security Risk
Analysis, CHAN, patient portal
Workflow optimization discussion &
decision making
Status updates vendor code fixes,
packages, etc.
Live demonstrations on
workflow
Legal discussion/ review
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Use Dashboards to Monitor Metrics and Progress…
Each facility can evaluate their stage status with this multi-stage graph. Color coordination along with bubble presentations allow a site to review each metric, if the metric has changed from one stage or any course corrections necessary. These metrics are available monthly for site consideration.
Challenging Stage 2 Meaningful Use Objectives Patient Electronic Access
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Challenging Objectives: Patient Electronic Access
Hospital Leadership Sponsor is key for
Portal Success (CFO or CNO)
Must have a Portal lead
Patient Registration – needs to collect
35% emails
Round on Patients: Portal Lead /
Volunteers / Light Duty Worker
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Challenging Objectives: Patient Electronic Access
Meet weekly until you hit the 8% level for
inpatients/ observation then bi-weekly status
updates
Go for the two-for-one opportunities (Mom and Baby)
Portal Lead – manage the daily Unclaimed Portal Invite report
• Assign rounding duties and focus on in-house patients with portal invites
• Round on Cardiac and Orthopedic patients
• Round on Rehabilitation therapy clinic and Cardiac therapy patients
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Challenging Objectives: Patient Electronic Access
Use of volunteers, staff members, and temporary staff
Registration involvement / gather email address upon
admission
Accept invite before discharge
Patient population does matter
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• Clinical staff, HIM and Clinical Informaticists can send invite to access the portal
• Develop marketing materials
• Clinical staff needs to discuss the portal when talking with patients
• Dignity Health hired a marketing expert to develop materials and outreach to work with our hospitals marketing departments
Challenging Objectives: Patient Electronic Access
Domain A – Observation Services Method (82% of Year-long Attestation)
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Hospital Jul 26 Enroll Patients/Day 6%/Day Needed % of Goal
Site 1 9.7% 756 26 -2.8 -186 133%
Site 2 (Stage 1) 7.0% 246 12 0.2 13 95%
Site 3 (Stage 1) 5.3% 655 41 3.8 250 72%
Site 4 (Stage 1) 2.6% 256 33 7.1 468 35%
Site 5 6.5% 334 17 0.6 41 89%
Site 6 6.2% 440 24 1.2 82 84%
Site 7 8.0% 1241 52 -1.7 -110 110%
Site 8 11.4% 617 18 -3.3 -220 156%
Site 9 5.5% 189 12 1.0 65 75%
Site 10 9.5% 199 7 -0.7 -46 130%
Site 11 13.5% 1114 28 -7.7 -509 184%
Site 12 9.2% 288 10 -0.9 -60 126%
The VDT Marathon – Keeping the 6% Pace
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Key to Columns: A – Hospital Name B – Week ending date and cumulative % of goal through last week’s data end date C – Week ending date and cumulative % of goal through this week’s data end date D – Number of days into this 365 day year as of ending date for this week’s data and corresponding day into the 365 day year based on the hospital’s percent completion as of this week’s data E – Month equivalent of column D F – Visualization of corresponding month in the year for current pace of adoption G – Finish Line; current rate should achieve >5% for the year even if no more OPC enrollments
Challenging Stage 2 Meaningful Use Objectives Summary of Care Public Health Reporting
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Challenging Objectives: Summary of Care
Cleaning up problem lists (problems, allergies,
medications)
Identifying recipients with Direct email
addresses (less than 1%)
Identifying top referring providers and providing Direct emails
• Credentialing
• Training/Education
Vendor selection and procurement for Direct
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Challenging Objectives: Summary of Care
Resource needs for manual sending of summary of care
documents
Implementation and testing of the ops
job (6 month effort)
Determining content for C-CDA (e.g.,
including Radiology results and timing)
Legal considerations (referring
physicians)
NIST submission – done by corporate
MU team
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Transition of Care - Ops Job Results
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Challenging Objectives: Public Health Objectives
Dignity Health operates in 20 counties across three states
Most counties are not ready for Syndromic Surveillance
Monitor each public health authority for readiness to receive
data
Work with interface team for testing and
readiness
Keep Audit defense documentation
(emails)
Provide education and training for the
hospital sites
Coordinate with Vendor for Go lives and MU Stages for
each hospital
Participate in conference call with
vendors and state agencies
Monitor failures and recovery plan
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Public Health Status Tracker
Tracker data elements:
• Hospital, Region, County
• Cerner Domain
• Status and Notes for each public health objective:
–Registration
–Training
–Testing
–Production
Audit Defense
30 Source: MDEverywhere, Jan 2015
10,000 unique audits were conducted on
265,075 Eligible Professional attestations
4,601 have been completed
22.7% of EPs failed to meet meaningful use standards
98.9% of failing EPs did not meet appropriate measures and objectives
31 Source: MDEverywhere, Jan 2015
4,637 Eligible Hospital Attestations (13.2%)
613 post-payment audits were initiated from
4.9% of EHs failed their audits
The average incentive returned was $1.1 M
Total incentive recoupment has totaled $33 M
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Meaningful Use Attestation and Audit Statistics
Stage 2 attestations through FFY 2014:
Dignity Health 10/10 = 100%
Successful CMS/Figliozzi Audits:
• FFY 2013 2/2 = 100%
• FFY 2014 7/7 = 100%
State Medicaid Pre-payment Audits: FFY
2013 1/1 = 100%
State Medicaid On Site Financial Audits
– 1 pending
OIG Audits of State Medicaid EHR
program – 7 pending
CHAN Internal Audits – documented action
plans
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Audit Defense Template Guide
Detailed audit defense checklist documents:
• Audit documentation requirements
• Supplied by (department)
• Completion status
• Owner (individual’s name)
• Owner facility, department and title
• Document name
• Document Specifics and Comments
• Document location (electronic and paper-based)
CMS/Figliozzi Audits Against FFY 2013
Milestone Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 Site 7
Initial notification
May 20 May 20
May 20
May 20
May 20
May 20
Jun 30
Due date Jun 17 Jun 17 Jun 17 Jun 17 Jun 17 Jun 17 Jul 14
Response date Jun 13 Jun 13 Jun 11 Jun 16 Jun 13 Jun 13 Jul 3
Follow-up Request
Aug 8 N/A Aug 8 N/A
Aug 8 Aug 8 Jul 8
Follow-up Due Date
Aug 22 N/A
Aug 22
N/A
Aug 22 Aug 22 Jul 22
Follow-up Response
Aug 13 N/A
Aug 13
N/A
Aug 13
Aug 13
Jul 9
Final determination
Sep 2 Aug 25 Sep 2 Sep 8 Sep 2 Sep 8 Jul 28
Outcome PASS PASS PASS PASS PASS PASS PASS
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Figliozzi Scope of Request – Five Topics in Three Parts
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• Proof of use of a Certified EHR system
• Documentation to support the method chosen to report ED admissions
Part I – General Information:
• Supporting documentation for core measures used in the completion of the Attestation Module
• Provide proof that a security risk analysis of the Certified EHR Technology was performed prior to the end of the reporting period
Part II – Core Set Objectives/Measures:
• Supporting documentation for menu measures used in the completion of the Attestation Module; supporting documentation for non-measurable menu items claimed
Part III – Menu Set Objectives/Measures:
2015 Office of the Inspector General (OIG) Audits Summary
Milestone Site 1 Site 2 Site 3 Site 4 Site 5 Site 6
Initial notification Apr 15* Apr 17 Apr 17 Apr 15 Apr 17 Apr 15*
Due date Apr 28 Apr 30 Apr 30 Apr 28 Apr 20 Apr 28
Response date May 6 Apr 28 Apr 29 Apr 27 Apr 28 May 7
Notification letter sent to:
Administration Manager Senior
Executive Assistant
Chief Financial Officer
Vice President of Finance and
CFO
Regulatory Compliance
Manager
Facility Compliance Professional
Director of Quality
Years Audited 2013-14 2012-14 2011 & 13 2012-13 2011-13 2011-14
At Stake $4.75M $5.66M $3.213M $3.304M $3.785M $5.249M
2nd Request Jun 12 Jun 17 Jun 15 N/A Jun 11 N/A
2nd Request Due Jul 6 Jul 6 Jul 6 N/A Jul 6 N/A
2nd Submission Jul 1 Jun 26 Jun 24 N/A Jun 23 N/A
Final determination
TBD TBD TBD TBD TBD TBD
Outcome PENDING PENDING PENDING PENDING PENDING PENDING
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* Initial notification went undetected until after the response due date. OIG was contacted and a new 10 business day response period was granted.
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See Appendix for detailed questions.
OIG Audits of State Medicaid EHR Incentives Scope of Initial Request
State Medicaid Enrollment
Medicaid Patient Volume
Medicaid EHR Hospital Payment Calculation
Certified EHR
22 Questions in Four Sections, Covering…
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OIG Audits of State Medicaid EHR Incentives Submitted Documents
Cover Letter
Questionnaire and Document Request with Embedded Responses or
Reference to Attachments
Patient Volume Information
Cost Report Documents Calculation Tools Vendor Verification
Letter(s)
CMS Certification ID; Certified Product List
Screen Shots of Access to EHR
Meaningful Use Rules Update Modified Stage 2 2015-17 Stage 3 2017-18ff
New Rules – Released Oct 6; Published Oct 16, 2015
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Electronic Health Record Incentive Program -- Stage 3 and
Modifications to Meaningful Use in 2015 through 2017
Released Oct 6
https://federalregister.gov/a/2015-25595
PI version = 752 pages
2015 Edition Health Information Technology Certification Criteria,
2015 Edition Base Electronic Health Record Definition, and ONC Health
IT Certification Program Modifications
Released Oct 6
https://federalregister.gov/a/2015-25597
PI version = 560 pages
Stage Of Meaningful Use Criteria By First Payment Year
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• The focus of the first three stages remains as follows: stage 1, capture data in structured formats; stage 2, improve clinical processes; stage 3, drive patent population health outcomes
• First year measurement requirement (regardless of year) remains 90 continuous days of meaningful use in that payment year.
• All subsequent years, the measurement requirement is for the entire year. For 2015, the measurement period is 90 days within the 15 months ending Dec 31, 2015. Stage 3 period in 2017 is 90 days.
Source: 2015-25595-PI.pdf, pp. 60-61
1st Yr MU 2015 2016 2017 2018 2019ff
2011 M M M or
2012 M M M or
2013 M M M or
2014 M M M or
2015 M M M or
2016 N/A M M or
2017 N/A N/A M or
2018 N/A N/A N/A
2019ff N/A N/A N/A N/A
M = Modified Stage 2
= Stage 3
1. Protect Patient Health Information • Conduct/review Security Risk Analysis (SRA);
correct deficiencies 2. Electronic Prescribing (eRx)
• >60% Eligible Professionals; >25% Eligible Hospitals
• Permissible prescriptions only • Drug formulary checks
3. Clinical Decision Support (CDS) • 5 CDS interventions • Drug-drug/allergy checks
4. Computerized Provider Order Entry (CPOE) • >60% medication orders • >60% laboratory orders • >60% diagnostic imaging orders
5. Patient Electronic Access to Health Info • >80% can access to View, Download or
Transmit (VDT) w/in 24 hours via portal or Application Programming Interface (API)
• >35% identify patient education and electronic access to education materials
6. Coordination of Care through Patient Engagement *
• >5% 2017 >10% 2018ff VDT (portal or API) • >5% 2017 >25% 2018ff exchange secure
messages • >5% patient-generated health data from non-
Inpatient or Emergency setting 7. Health Information Exchange (HIE) *
• >50% create and send Summary of Care (SOC) electronically
• >40% SOC incorporation from other EHR • >80% clinical information reconciliation
(meds, allergies, problems) 8. Public Health and Clinical Data Registry
Reporting ** • “Active engagement” with three options:
registration, testing & validation, production • Six data types: immunizations, syndromic
surveillance, electronic case reporting, public health registry, clinical data registry, electronic reportable laboratory results
Final EP and EH Objectives and Measures for Stage 3 MU 2017 and Following
* Must report data on all three measures but only meet thresholds for two of three measures. ** Must choose four of six data types to report on for EH; three of six for EP
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Key Takeaways - Critical Success Factors
Governance and program organization are critical to
success
Executive and clinical sponsorship are essential
for decision making, resource allocation and
barrier elimination
Identify and involve all stakeholders
Use program and project management methodology
Share and leverage leading practices between
sites
Monitor performance on key measures continuously
Focus on documentation anticipating audits
Communicate, communicate, communicate!
