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Information Technology Compliance, Solutions

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Title: Information Technology Compliance, Solutions


1
Information Technology Compliance, Solutions
Trends
  • ABC Conference
  • Tampa Florida
  • January 2011

2
Mike Mytych Bio
  • 35 year career in healthcare
  • 20 years in Consulting with an emphasis on
    clinical systems and focus on physician adoption
    of I/T
  • Clients range from small physician groups to
    large multi-hospital organizations
  • Conducted over 200 vendor selections for both
    hospitals and physicians with over 50 cardiology
    engagements ranging from small practices to
    complete heart hospital I/T strategies
  • Worked with 6 major HIEs including Chicago,
    Minneapolis, Wisconsin, Washington DC, New York
    City
  • Spent 15 years in the vendor community and is
    former VP of Sales for the physician systems
    division at Baxter
  • Adjunct Faculty member at University of Wisconsin
    Milwaukee Healthcare Informatics Graduate program
    teaching Healthcare I/T Procurement

3
Disclosure
  • Provide industry education for CDW, GE and
    NextGen in partnership with Wakerly Partners and
    C-Suite Resources
  • We do not provide competitive analysis or
    benchmarking to any vendor
  • Participate on 3 investor advisory company panels
    for publically traded company assessment and
    prohibited from disclosing any information that
    is not included in the public domain.

4
Todays Objectives
  • What are the key I/T drivers for today's
    practice?
  • Impact of ARRA / HITECH / Healthcare Reform on
    impact on I/T decisions.
  • What are the critical EMR/EHRs CV Requirements?
  • What will the future look like for the CV
    Practice ?

5
Audience Survey
  • EMR Today?
  • Buying an EMR?
  • Integrated with Hospital?
  • Integration Discussions?

6
Todays Key I/T Drivers
7
I/T Drivers
  • ARRA / HITECH Meaningful Use Rules
  • Hospital Integration Care Coordination
  • Documenting care that enables quality /
    performance assessment
  • Maintaining reimbursement and getting greater
    operational efficiency

8
Driving Practice I/T Decisions
  • EHRs and Meeting Meaningful Use
  • Integration with Hospitals
  • PM System Decisions
  • Cardiology PACS
  • HIPAA Compliance
  • Regulatory/Quality Measure Compliance
  • PQRI and eRX Incentives
  • Device Upgrades Integration
  • Preparing for Health Reform and participating in
    ACOs Health Information Exchange
  • Others, ICD10 etc.

9
Decisions - Decisions
  • There is a lot to get done !
  • Priorities
  • Resources
  • Timing
  • Timeline
  • Dependencies

10
Questions We Hear
  • With all that is happening around us, what are my
    best options for a good long term decision
    regarding I/T?
  • How can I optimize the use of systems for better
    patient care and provider satisfaction without
    losing productivity?
  • How can I minimize wasteful decisions?
  • Will the government programs like HITECH be
    changed substantially in the near future?
  • Will my integration with a hospital change the
    way my providers will utilize EHRs?
  • What is an HIE, is it real and when do I need to
    participate?
  • Dozens of others

11
ARRA HITECH Compliance Have a Road Map as to
How you get there Operate under the new Rules
  • I don't like mysteries. They give me a bellyache
    and I got a beauty right now. James Kirk

12
Non-compliance Is An Expensive Choice
Physicians and hospitals must meet governments
definition of meaningful use of Electronic Health
Records (EHR) Technology in order to be paid
their bonuses or be prepared to have the
penalties kick in in 2015.
  • 2011 is the first year for partial qualification
    for meeting Meaningful Use (Stage 1)
  • 2013 and 2015 will have different rules that
    build out toward the HITECH objectives (Stage 2
    and Stage 3) and the preliminary objectives were
    released January 2011

13
Refresh - Meaningful Use
  • Meaningful use is defined as
  • Use of a certified EHR in a meaningful manner
    (ex clinical documentation, e-prescribing, etc.)
  • Use of certified EHR technology for electronic
    exchange of health information
  • Use of certified EHR technology to submit
    clinical quality and other measures.
  • To insure Meaningful Use and to ensure continued
    adoption and subsequent use of the EHR there are
    specific rules for demonstration of that use.

14
Reporting Requirements Summary
  • Requirements vary based on whether the applicant
    is an eligible professional or eligible
    hospital.
  • Reporting Period for any consecutive 90 days for
    first year one year subsequently  
  • For 2011 Providers required to submit summary
    quality measure data to CMS or States by
    attestation
  • For 2012 Providers required to electronically
    submit quality measure data to CMS or States

15
The March Toward Reform
  • ARRA/HITECH
  • Meaningful Use 2011 2013 2015
  • Medicare Penalties 2015
  • Data Analytics
  • Setting the Stage for Healthcare Reform
  • Increased utilization demand from the
    uninsured/underinsured
  • Changes in plans / employer offerings
  • Bundled payments reward for quality performance
  • Quality / outcomes evolution
  • Medical Home
  • Development and operation of ACO's
  • Comparative Effectiveness
  • Nationwide goal to remove cost from the delivery
    system while improving quality

16
Data and More Data
No EMR Not Enough Data
17
EHRs and Meaningful Use
18
Leadership Concerns
  • When should we buy?
  • Who is the right vendor?
  • Can they get us to meaningful use?
  • Do we have time for PM?
  • Who will help us through all of these changes?

19
Meaningful Use Implications
  • Physician clinics will have to carefully assess
    their ability to meet meaningful use by
    2011/2012.
  • Just having an EHR does not mean that a clinic
    will meet the criteria.
  • Each physicians group will need to understand
    what it will take to have the required
    interoperability, system interfaces, data
    standards and timeline requirements.
  • Physicians may be invited to participate in HIE
    technologies offered by the Hospitals to assist
    in complying with Meaningful Use criteria.
  • Few Physician Clinics have integration or
    interchange with Imaging systems for movement of
    diagnostic reporting (PACS, CPACS, RIS).

20
Common Questions from those who already have an
EMR?
  1. Is my vendor certified?
  2. What is the current state of implementation and
    quality of use by my clinicians? (still using
    dictation?)
  3. What gaps do we have to complete the EHR
    implementation (eRx Lab are key)
  4. Are we capturing the required discreet data?
  5. Lab results are discreet and complete?
  6. Interchange capabilities with our referring
    physicians and hospitals?

21
MU is not just about EHR
  • Unless you are the only practice on an island, no
    one vendor can enable the physician to meet
    meaningful use.
  • The stimulus law compels the creation of ways to
    exchange health information within states and
    across a nationwide HIT infrastructure
  • Cardiovascular Patient Records and related
    discrete data are a primary target of these
    efforts
  • http//govhealthit.com/newsitem.aspx?nid72400

22
MU Compliance
  • Reporting QC what you can do and how you are
    measuring up to the standards
  • Know how data is generated and by whom
  • Change behavior to become compliant

23
EHRs for the CV Practice
24
Vendor Selection Considerations
  • Vendor Certification
  • PM Vendor
  • Hospital Vendor
  • Vendor Stability
  • Cost
  • Performance
  • Others

25
EHR Vendor Certification
  • Surescripts LLC  - Arlington, VADate of
    authorization December 23, 2010.Scope of
    authorization EHR Modules E-Prescribing,
    Privacy and Security.
  • ICSA Labs  - Mechanicsburg, PADate of
    authorization December 10, 2010.Scope of
    authorization Complete EHR and EHR Modules.
  • SLI Global Solutions  - Denver, CODate of
    authorization December 10, 2010.Scope of
    authorization Complete EHR and EHR Modules.
  • InfoGard Laboratories, Inc. San Luis Obispo,
    CADate of authorization September 24,
    2010.Scope of authorization Complete EHR and
    EHR Modules.
  • Certification Commission for Health Information
    Technology (CCHIT) - Chicago, ILDate of
    authorization September 3, 2010.Scope of
    authorization Complete EHR and EHR Modules.
  • Drummond Group, Inc. (DGI) - Austin, TXDate of
    authorization September 3, 2010.Scope of
    authorization Complete EHR and EHR Modules

http//healthit.hhs.gov/portal/server.pt?open512
mode2objID3120
26
Certified Vendors
  • Currently 193 vendor products are certified
  • Not all are comprehensive EHRs
  • Very few offer a comprehensive CV EHR
  • Make sure your vendors are certified and
    contractually commit to remaining certified
  • http//onc-chpl.force.com/ehrcert/EHRProductSearch

27
EHR Evaluation Considerations
  • Performance
  • Depth in Cardiology and Interoperability
  • Ability to interoperate with others
  • Patient identity management
  • Inbound unsolicited data management
  • Market share in your region
  • Validation of capability and contractual
    commitment
  • Pre-contract integration and interoperability plan

28
EHR Implementation Timeline
1 to 3 months
1 to 2 months
2 to 4 months
1 to 3 months
1 to 4 months
Total 6 to 16 months depending on resources,
size of group, PM integration and other variables.
29
Summary Physician / EHR requirements
  • Meeting Cardiology Workflow
  • Flexibility of design / settings
  • Interfaces with Devices Patient ID, Orders,
    Results
  • CPACS
  • PaceArt
  • Others
  • Comprehensive one-stop shopping for all patient
    records components from the patient summary
    screen with individual settings
  • Integration into clinic workflows
  • Nursing triage
  • Physician in-box of new records / results
  • Ease of mapping to existing records both paper
    and electronic, patient identifiers
  • Ease of validation of data prior to upload into
    the permanent record from outside systems
  • Key Focal Points
  • Interoperability - Your Device Integration
  • Echo, ECG, Stress, Holter, Nuclear, CT, PV, etc.
  • Specialty Clinics Limpid, AntiCoag, Device,
    CHF, etc.
  • Lab Interfaces -
  • Quality Data / Measures how is data collected
  • Effective Clinical Decision Support
    documentation of non-std events
  • Executive Reporting / ease of use

30
Other Requirements
  • Mapping to your ACO partners
  • Management of change to national standards
  • Health Information Exchange Requirements
    Regional, State, Enterprise
  • Referral coordination for exchange changes in
    workflows
  • Patient / Consumer Compliance Requirements
    access to electronic copies of their records
  • Others

31
Example of ACO I/T Requirements
Component Early Developing Sustainable Supporting I/T
Member Engagement Episode of Care Pre-care intervention Prevention Lifestyle coaching Remote monitoring CRM HRA Patient ID Mgt
Cross Continuum Medical Management Case Management Care Coordination Disease Management Health Maintenance Patient ID Mgt Provider Directory Consent Mgt. Disease Registries EMR
Clinical Information Exchange Read only access User request pull Push Pull CCD Dynamic context sharing Patient access EMR w/ CCD Patient ID Mgt. Provider Directory HIE
Quality Reporting Manual entry into Excel EHR feed to Quality DB Real time access to data Data dashboards Executive reporting EMR w/ Clinical Documentation Analytical Data Warehouse
Business Intelligence/ Predictive Modeling Analytics Patient focused Episode encounter focused data retrospective clinical and financial data Population based continuum of care data predictive health analytics Social and network data Behavior based analytics Real time data analysis Analytical Data Warehouse cross continuum Clinical Dashboard Comparative Effectiveness Analytics
ACO Risk Revenue Management Cost accounting across the continuum of care global contracting member data management Provider management allocation of payment Pool management disease improvement RCM for ACO Analytical Data Warehouse
32
Example - Hospital / Physician Integration
  • Hospital bias toward enterprise system choices
  • Lack of granular understanding of practice
    workflows, requirements
  • Nomenclature and data integration and
    normalization between hospitals and physicians
  • Patient identifiers between hospitals and clinics
  • Orders being received by hospitals from physician
    EHRs
  • Physician use of multiple clinical documentation
    systems
  • Hospital portal access and download of data to
    EHR
  • Hospital links to office EHR via web
  • Images
  • Security issues
  • Enterprise Data Analytics common clinical model
  • E.g. Marshfield Semantic interoperability project

33
Example Physician EHR Environment Summary HIE
Requirements
  • Lab Information Systems reference labs,
    hospitals etc.
  • Orders
  • Results
  • Status
  • Pharmacy
  • Outbound eRx to Retail
  • Outbound patient record to hospital active meds
  • Inbound patient history CCD
  • Inbound patient active meds hospital discharges
    medication reconciliation
  • Documents
  • Outbound CCD/CCR
  • Outbound referral request
  • Outbound referral results (CCD)
  • Imaging
  • Links to Hospital PACS from hospital results
    records
  • Links to Clinic PACS from hospital devices
  • Orders / Results Hospitals
  • Radiology
  • Cardiology
  • Others

34
Buying an EHR
  • Have a plan as to how you will make your decision
  • Include as many clinicians and operations members
    as you can
  • Map all of the your detailed requirements to what
    the vendor says they can do and make sure they
    are transferred into the contract
  • Dont rush your decision
  • Speak to as many references as you can
  • Dont sign their standard contract

35
Health Information Exchange Care Coordination
36
No matter what the Hospital relationship CV
practices are going To be asked to be a critical
Component of care coordination
37
Data and Information Exchange

Clinical Information / Data
38
Health Information Exchange (HIE)
Definition HIE refers to the process associated
with the electronic movement of health-related
data and information among organizations at the
community, regional, statewide, or nationwide
levels according to agreed standards, protocols,
and other criteria.
39
Health Information Exchange (HIE)
Primary Functions
  • Secure clinical information sharing
  • Coordination of care
  • Support Accountable Care Organizations
  • Quality and health status reporting
  • Shared platform

State of IL
Public Health
40
Cardiovascular HIE Requirement
  • Cardiovascular groups will be a significant
    target for health information exchange over the
    next 2 years with target for implementation by
    2013 (Stage 2)
  • Coordination of care and reduction of duplicate
    testing are the primary objectives
  • ED access to CV patient records Wisconsin Study
  • CCD exchange
  • PHR service

41
Physician EHR Environment Summary HIE Requirements
  • Lab Information Systems reference labs,
    hospitals etc.
  • Orders
  • Results
  • Status
  • Pharmacy
  • Outbound eRx to Retail
  • Outbound patient record to hospital active meds
  • Inbound patient history CCD
  • Inbound patient active meds hospital discharges
    medication reconciliation
  • Documents
  • Outbound CCD/CCR
  • Outbound referral request
  • Outbound referral results (CCD)
  • Imaging
  • Links to Hospital PACS from hospital results
    records
  • Links to Clinic PACS from hospital devices
  • Orders / Results Hospitals
  • Radiology
  • Cardiology
  • Others

42
ConclusionsDawn of a New Era
  • EMR - MU Stage 1, 2 3 - CV
  • Patient Centric Care Coordination Processes
  • HC Reform Rule Flexibility
  • ACO Development
  • Data supports Quality Outcomes
  • Consumer Focus Engagement

43
Thanks !
Health Information Consulting, LLC Mike
Mytych mmytych_at_hicllc.com 262-253-9110
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