The primary focus of CHIME’s Advocacy Program is to advance the role of CIOs and other senior healthcare IT leaders by providing educational, collaborative, and advocacy programs to improve the quality of care. Through our CHIME Policy Chats, healthsystemCIO.com is partnering with the organization to provide a forum to educate CIOs on advocacy efforts, learning opportunities, updates on legislative and regulatory issues, and other key issues. The discussions feature Sharon Canner, senior director of advocacy, and Jeff Smith, assistant director of advocacy for CHIME.
Chapter 2
- CHIME’s comments on MU stage 3 — “Pace is a deep concern”
- Hospital readiness for EHR-generated CQMs
- Underutilized CMS pilot programs
- StateNet opportunities
- The “hunger” for best practices
- Gearing up for HIMSS13
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Bold Statements
The message we wanted to deliver was twofold. First, evaluate before making decisions, and second, be reasonable about expectations and accomplishments heading into 2016.
Our basic assessment was that most hospitals are simply not able to report accurate and complete EHR-generated clinical quality measures. The key statement there is ‘accurate and complete.’
We called on CMS to move more heavily into promoting their pilot program that was set up to actually help hospitals work through some of the kinks. Thus far, the pilot program has been underutilized and in my estimation has been under-promoted as an avenue.
Right now we’re looking for content that can really move the ball forward on things like consent and patient data matching, because these are both issues that are being looked at both at the state level and the national level.
Once we look at various practices around the country on things like consent or patient data matching, we’ll be able to see commonalities that will drive recommendations. And if nothing else, we’ll be able to produce a number of case studies on how different situations are necessitating different responses.
Gamble: Let’s touch on Meaningful Use Stage 3. CHIME submitted some comments to ONC a few weeks ago, and in talking to CIOs, we’re hearing a lot of concern about the pace in which things need to be done. I want to talk a little bit about what you’d like to see happen with the stage 3 measures.
Smith: Absolutely. Well, I think, as was conveyed in our comments, pace was a deep concern and I think practicality was the other one. Generally, the message we wanted to deliver was twofold. First, evaluate before making decisions, and second, be reasonable about expectations and accomplishments heading into 2016. Meaningful Use is a unique and novel policy platform. If you look at EHR adoption rates, the proliferation of electronic prescribing, and the market explosion of provider and patient technologies, it would be pretty hard to say that Meaningful Use has not had an impact. CHIME has long supported the program, and each time we comment we try to be as supportive as we can in areas of agreement, and as constructive as we can when we have criticisms. So to us, it only makes sense to utilize attestation data combined with data from other parts of HITECH to determine the proper course of policy moving forward into stage 3. That’s why in our comments, we said that we saw no value in setting performance thresholds or expectations before current evaluations of what we’ve accomplished have been undertaken.
Now we also understand the difficult task of setting policy for an entire industry several years ahead of the current state. It’s another one of the fascinating aspects of regulating in the health IT space. And generally, we appreciate the work undertaken by the health IT policy committee, but we felt the need to raise flags in some areas that are definitely going to need attention as we move toward stage 3. Health information exchange, patient data matching, and electronic quality measurement are all kind of wrapped up in that.
Gamble: Yeah, I think that’s really going to point about how challenging that really is to try to set the rules for something that’s years away. We all know how much can happen in one year, and, like you said, how difficult it can be to predict where the industry is going to be. I think that’s a great point.
Smith: Yeah, and we recognize the difficulty of it, but at the same time, there were clear messages that said you need to slow down in terms of what you’re proposing, how high you’re setting thresholds. Really, we’re just asking folks to think through the types of technologies and then think through the associated workflow changes that would be necessitated by setting some of the measures and objectives that we saw in that request for comment.
Gamble: I’m sure it’s overwhelming for a lot of CIOs to even think about stage 3 at this point.
Smith: Yeah, we were really lucky. Sharon mentioned that we set up work groups, as we’ve done for the past half-dozen or so comment cycles, and we had about 18 to 20 CIOs sit on two different work groups and put a lot of time and energy over the holidays to try and come up with these comments. But it’s a very daunting task, and every time the government reaches out for input, that really is time and effort above someone else’s regular day job. So it is something where I think a lot of folks out there just get overwhelmed. I think that’s probably the perfect phrase for it.
Gamble: Unfortunately it’s a word we’re hearing a lot these days, as I’m sure you are.
Smith: Yeah. Just last week we submitted another comment, and this was in regard to a CMS request for information. They wanted to know what the hospital readiness was for submitting electronic quality data as part of the inpatient quality data reporting program. Our basic assessment was that most hospitals are simply not able to report accurate and complete EHR-generated clinical quality measures. The key statement there is ‘accurate and complete.’ Certified EHR technology has always been required to generate CQMs, but in order to have accurate and complete information, the data has to be gathered by abstractors, which is usually found in dictated reports or free form progress notes, and this data is not structured within the electronic health record.
So again, we tried to be as constructive as we could in basically saying that many of our member hospitals are not able to submit this data in a complete and accurate way. They can submit the data, but whether or not it’s true to reality is another question. So basically we called on CMS to move more heavily into promoting their pilot program that was set up to actually help hospitals work through some of the kinks. Thus far, the pilot program has been underutilized and in my estimation has been under-promoted as an avenue. But at least that lever exists and the pilot program is there, so we just encourage more folks to try and look at that and we encourage CMS to make it a more attractive offer for hospitals.
Gamble: I’m sure that feedback is really valuable to them just because one of the things that you don’t want to do is try to make hospitals and organizations feel like they’re being rushed. That doesn’t really help productivity in any cases, I don’t think.
Smith: No. And if you look at the requirements under the 2014 certification rule, EHRs are going to have to be able to do this functionality. They’re going to have to be able to submit CQMs electronically and hospitals and doctors by extension in order to be successful under stage 2 are going to have to submit electronic clinical quality measures. In their wisdom, they didn’t say in the final rule that the information has to be accurate and complete, but as we move forward, that’s a reality that we can live in for a short amount of time. So we do think that now is probably a good time to really put some emphasis on quality measurement across the board. That way we can head things off as we move beyond 2014 and 2015, and then as reimbursement rates and payment in general become more contingent on quality measures, it’s going to be important that they are complete and accurate.
Gamble: Absolutely. It just makes much more sense as a long-term solution.
Smith: Right.
Gamble: The final thing I wanted to touch on was StateNet. What are some of the programs that you think might be beneficial for CIOs whether it’s something online like a webinar or live events, things like that?
Smith: Actually, we’re getting to a point in the year where we’re getting really excited about what StateNet is going to possibly undertake over the next 9 to 12 months. StateNet is gearing up for a meeting next month and we’re going to be discussing the organization’s top priorities and projects for the next year. We’re also looking to expand StateNet’s leadership. Currently, Randy McCleese from St. Mary’s Regional and Neal Ganguly from CentraState are the chair and co-chairs of StateNet. We’re looking to establish two working groups around two topics and have the workgroup chairs join the broader StateNet leadership. We’re really hopeful to put together some kind of recommendation or white paper or some kind of deliverable that represents the views of various health IT stakeholders in conjunction with the CHIME CIO community and is something that’s really actionable for policymakers.
Right now we’re looking for content that can really move the ball forward on things like consent and patient data matching, because these are both issues that are being looked at both at the state level and the national level. There’s really a lot of variation between states and between institutions, and so we do think that these are among the issues that StateNet is going to try and tackle at a very real and meaningful way in 2013.
Gamble: That’s an area where there’s such a need and there’s such a hunger for more information.
Smith: I think you said it. There’s just a hunger for more everything — more information, more solutions, more options, and more best practices. I can’t say for sure what the topics that we’ll focus on for the first two work groups, but I do know that we’re looking to really energize the community of almost 700 stakeholders that we have on StateNet. One thing that I would remind listeners is that this is a CHIME-curated project in the sense that CHIME has leadership involved as part of our public policy process and part of our infrastructure, but it’s open to all health IT stakeholders. These work groups will also be open to help IT stakeholders across the board.
Gamble: That’s great. I’ve gotten to know Neal and I think that it’s really great to have him as a representative because he’s CIO of CentraState, which is a standalone in New Jersey, and it’s kind of a rarity. In New Jersey there are so many large health systems, and to have experience with a standalone, I think that he represents the needs of a lot of people throughout the country who might be in the same boat.
Smith: Exactly. The hope is that once we look at various practices around the country on things like consent or patient data matching, we’ll be able to see commonalities that will drive recommendations. And if nothing else, we’ll be able to produce a number of case studies on how different situations are necessitating different responses. And so I do think that there’s a lot of tremendous opportunity in 2013, for StateNet and obviously for CHIME Public Policy as a whole.
Gamble: Okay, well that’s all I had for now, unless there’s anything else you guys wanted to touch on.
Smith: I would just say — and I’m sure I speak for Sharon — that we look forward to seeing everybody in New Orleans. That’s coming up here shortly. We’ve got T-minus 30 days or so, and I think we’ve got a lot of great programs with the CIO forum, which will be happening the Sunday before a lot of the HIMSS stuff gets rolling.
Gamble: That will be here in a blink of an eye.
Smith: Without a doubt.
Canner: It will be. Will you be there, Kate?
Gamble: I will, yeah. I’m looking forward to it.
Canner: Good. It’s an incredible dash — a lot of people to see in very few days. So I think we’ll just gear up, wear our flat shoes and comfortable clothes, and get ready to charge ahead.
Smith: And I’m sure there’s going to be one, maybe even two more surprises coming from the government before or during HIMSS. We always look forward to that.
Gamble: Yeah. I’m sure we’re going to have a lot to talk about.
Smith: Absolutely.
Canner: We appreciate this opportunity, Kate, to dialogue with you on specific CHIME issues, and we’ll look forward to our next time around.
Gamble: Yeah, me too. Thanks again for your time, and I will see you guys soon.
Smith: All right, thank you.
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