Healthcare providers and eligible primary physician practices are undergoing analysis paralysis because of all the government impositions on improving healthcare with the following list of complex problems to solve: HIPAA’s Version 5010 conversion, ICD-10 migrations, Meaningful Use (MU) of EHRs and Attestation , Accountable Care Organizations (ACOs) , Data Aggregation and mining for successful Quality Measurement Reporting and Performance Improvement Requirements, CPOE implementations, CDA and the CCD template based document generation for sharing patient information between health providers, Natural Language Processing (NLP), Private Health Information (PHI) in the Cloud, internal demand for emerging technologies, the Mayan prediction of the end of the world, Et cetera, Et cetera, Et cetera.
The list above is not a bloated aggregation of current buzz-words, terms, solutions and a potential world event, but actually projects (challenges) that most healthcare providers, large and small, have had to embark on or are getting ready to do so beginning the first quarter of this year; yes indeed, that is NOW!
The aforementioned list isn’t exhaustive either, because there are other very specialized areas that the ARRA/HITECH and the Affordable Care Act have intentionally or unintentionally triggered off as well. We will leave a discussion of this topic to another blog in the near future.
Those organizations that have been proactive and early starters or pioneers have a clear advantage over the others but yet they’ll still face their own challenges and probably very similar to the late bloomers.
Any of these challenges (which are also projects by nature) involve not only unique but also many common complexities such as:
Format: Challenge Level of Effort (1 = Least – 5 = Most)
- Stakeholder alignment 2
- Project Management 2 (communication, charter, schedule, resources, Et cetera)
- Multiple vendor selection 4
- Heterogeneous vendor alignment 5
- Multiple potential software system and hardware upgrades 4
- Reliance on Subject Matter Experts (SMEs) 4
- Managing Disruptive Emerging technologies (e.g., mobile apps, tablets) 3
- Workflow and process re-engineering 4
- Compliance with HIPAA and possibly the FDA 3
- Individual State laws regarding patient privacy that go beyond HIPAA requirements and constraints 3
- Testing, Verification and Validation 3
- Documentation 2
- Training 2
- Et cetera?
Average LOE Result: If we average the weights of the various LOEs (excluding Et cetera) the result is 3.15. An average LOE of 3.15 can bring some unexpected surprises during the execution of a project.
For those HIPAA covered entities that were unable to meet the January 1st, 2012, deadline for the ASC X12 Version 5010 conversion their focus on other projects may be substantially distracted until March 31st, 2012 which will be the trigger date for compliance enforcement by the Centers for Medicare & Medicaid Services’ (CMS) Office of E-Health Standards and Services (OESS). Only 90 days were allotted for the Enforcement Discretion period; that is the three month grace period after which the CMS will start penalizing those that are lagging.
The covered providers must use Version 5010 when conducting electronic transactions including but not limiting to: eligibility queries, claims and claims queries, referral queries and other transactions.
Some common Version 5010 message transactions are: 270/271 for eligibility requests/eligibility responses, 278 for healthcare services and 837 for healthcare claims.
For further information regarding ASC X12 Version 5010 please visit the following links:
The Meaningful Use and Healthcare Reform evolution had somewhat eclipsed ICD-10 conversions during 2010 and 2011. Many US providers decided to drag their feet with the ICD-9 to ICD-10 conversion projects using many excuses around the complexity and lack of benefits it brought, which were then highly mitigated by the successful transitions experienced by European countries, Australia, New Zealand and others.
The ICD-10 conversion timeline and the October 1st, 2013, firm deadline seems to be generous at first, but don’t let it mislead you and not only because the end of the world may occur first! Changing a coding system will potentially impact almost every one of your source systems database schemas, stored procedures, views, Et cetera. If you use the coding system in your HL7 or transactional messages there may be some significant modifications required here as well. There are two sets of ICD codes; the ICD-10-CM for diagnosis coding and the ICD-10-PCS for inpatient procedure coding. Almost all types of healthcare providers will have to convert from ICD-9-CM to ICD-10-CM with the introduction of 2 additional digits in the coding system in a subset of cases. The ICD-9-PCS to ICD-10-PCS, which only applies to inpatient settings, will introduce 3 additional digits to a subset of the coding system. Even though it’s for some cases a good designer will account for all possibilities. Also, ICD-9 being decades old has the typical implementation inconsistencies of older technologies, standards and vocabularies which should be fixed before the transition is rolled out to production. If you have custom mappings and other software artifacts of components that are designed around the older coding system than these may have to be refactored as well.
Something to be aware of is that October 1st, 2013, is a firm deadline and there are no plans for an extension.
For further reading of how Perficient Healthcare can assist your organization with your HIPAA ASC X12 Version 5010 and/or ICD-10 Conversion projects please refer to the following links:
Regulatory Compliance in Healthcare
Meaningful Use (MU) of Electronic Health Records (EHRs) – Stage 1 and its Attestation
According to information published by Robert Anthony, Health Insurance Specialist of the CMS Office of e-Health Standards and Services, almost $2 Billion had been paid out during the year 2011 for those who have been able to successfully complete the MU Stage 1 attestation of their Electronic Health Record (EHR). Payments to date, January 2012, have also been quite onerous.
Proactive organizations, anticipating the challenges of Version 5010 and ICD-10, worked steadily on EHR Meaningful Use attestation during 2011. During 2012 they have more bandwidth to focus on the upcoming stage 2 requirements.
If your practice or organization hasn’t received your share of the big carrot, well then, you simply fall in the late bloomer’s category.
In order to receive the Medicare and/or Medicaid incentives you must perform the three following steps:
- Successfully register for the Medicare EHR Incentive Program;
- Meet meaningful use criteria using certified EHR technology; and
- Successfully attest, using CMS’ Web-based system, that you have met meaningful use criteria using certified EHR technology.
For further information regarding EHR MU attestation please follow the following link: https://www.cms.gov/EHRIncentivePrograms/32_Attestation.asp
If you are a typical provider, whether a hospital or an ambulatory entity, you rely mostly on vendors to get the job done and this is the BIG CHALLENGE. Health IT vendors are currently stretched and their growth rate is limited by the low availability of qualified or expert Health IT folks and Subject Matter Experts (SMEs).
Even though the MU Stage 1 bar was set quite low it can still be a huge endeavor for most physician practices and to a lesser degree to a hospital setting organization. Choosing the right vendor, customizing the EHR, testing, implementing to a successful go-live, training staff and finally obtaining attestation require expert project management skills, technical skills, and several Subject Matter Experts (SMEs).
For more information on how Perficient’s health BI (Business Intelligence) solution can assist you with your 44 Eligible Professional (EP) or 15 Eligible Hospital (EH), depending on your particular case, of the Meaningful Use (MU) Clinical Quality Measures (CQM) – refer to the Meaningful Use Measure sheets for Eligible Professionals or Eligible Hospitals.
This video, presented by Martin Sizemore of Perficient, a Microsoft Gold Certified Partner, discusses how to successfully create a meaningful solution in your EMR environment–a solution built on the Microsoft BI stack, including SQL Server and SharePoint.
For more information regarding CMS Meaningful Use, please visit the following page https://www.cms.gov/EHRIncentivePrograms/30_Meaningful_Use.asp.
Accountable Care Organizations (ACOs)
Although in its pioneer stage ACOs will gather quite some traction this year. The ACO final rule was highly applauded by the medical community by the end of 2011.
Many organizations that have embraced this model (e.g., Partners Healthcare) albeit under different names and slightly different approaches are among the 32 pioneers selected by CMS. For a detailed list of the Pioneers please follow this link: http://innovations.cms.gov/documents/pdf/PioneerACO-Generall_Fact_SheetFINAL_12_19_11.pdf
An ACO will be required to report on 33 Clinical Quality Measures in order to be able to measure their performance. The 33 CQMs are classified by domains:
- Patient/Caregiver Experience (e.g., timely care, appointments, communication)
- Care Coordination / Patient Safety (e.g., readmissions, medication reconciliation)
- Preventive Health (e.g., tobacco use, cancer screening)
- At Risk Population (e.g., diabetes, IVD, CAD)
For more information of the 33 ACO quality measures please refer to the following fact sheet: https://www.cms.gov/MLNProducts/downloads/ACO_Quality_Factsheet_ICN907407.pdf
Learn how Perficient Healthcare can IT-Enable your ACO by following this link.
In Regards to the End of the World
As for the rumor going around about the end of the world according to the end of the Mayan calendar or planet Nibiru colliding against Earth, I prefer to ask the experts opinion: http://www.nasa.gov/topics/earth/features/2012.html.
So please don’t let 2012 pass by without you getting expert advice for all of your EHR, meaningful use, attestation or Accountable Care Organization IT needs, because if not, what can be assured is that the late-bloomers will be paying hefty penalties to good ol’ Uncle Sam.
Part 2 of 2 Preliminary
In the next part of this blog we will be presenting valuable information and tips regarding the following topics: Data Aggregation and mining for successful Quality Measurement Reporting and Performance Improvement Requirements, CPOE implementations, CDA and the CCD template based document generation for sharing patient information between health providers, Natural Language Processing (NLP), Private Health Information (PHI) in the Cloud, internal demand for emerging technologies.
Thanks for reading!