The primary focus of CHIME’s Public Policy 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, we hope to inform CIOs about advocacy efforts and learning opportunities; provide updates on legislative and regulatory issues; and educate them on what CHIME is doing to help shape the implementation of federal and state policies. The discussions feature Sharon Canner, senior director of advocacy, and Jeff Smith, assistant director of advocacy for CHIME.
Chapter 1
- CHIME’s inaugural Public Policy forum
- CIOs talk ACOs and MU
- Best practices from Heichert, Oriol, Ganguly & others
- Addressing REBOOT concerns — “They echoed many of the concerns we have voiced”
- Asking for an extension — not a delay of Stage 2 — “This was a very conscious grammatical decision.”
- Three components in maximizing MU success
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Bold Statements
I think it was an eye-opener for some of them to listen to specifically, ‘this is where the rubber meets the road’ and ‘this is how it happens.’
There’s a real need for these officials to understand how the policies that they pass, either through legislation or through regulations, are playing out on the ground. I think it’s more than positive; it’s necessary.
We worry that the scenario will drive disparities between more advanced and less advanced providers, that it will compromise progress made toward interoperability, and quite frankly, that it will jeopardize nearly the entire $30 billion in tax payer investments to modernize the nation’s healthcare infrastructure.
What we see as the central problem is the timing crunch between getting the certified technology and the end of the reporting period or end of the year.
The challenges of Stage 2 are daunting, but we do believe that they’re surmountable, and if we can make this small adjustment, I think you will definitely see the gains afforded to the provider community and to patient care, costs, and outcomes.
Gamble: Hi, Jeff and Sharon. Thank you so much for taking the time to speak with us today.
Canner: We’re glad to be here.
Smith: Our pleasure.
Gamble: To start off, I wanted to talk a little bit about the public policy symposium that was held last month. This was the first one, I believe. I just wanted to get an idea of what the goals were and then what were some of the takeaways of it.
Canner: I’ll kick off with that, Kate. Yes indeed, this was our first public policy forum on Capitol Hill. We were thrilled; it was really an excellent turnout. The audience was a good substantial mix of Hill staff, of House and Senate, of individuals in federal agencies, as well as certainly those from the health IT community from a variety of associations, including physician groups. So we really had the desired audience. The goals were to communicate the CIO perspective on the complexities of two issues: 1) accountable care and 2) Meaningful Use. Because these are essentially both very complicated issues, the goal was to be able to talk in terms of what is a CIO, what are his/her responsibilities and in terms of implementing these electronic records. Let me just talk a little bit more who were some of the CIOs and what were some of the messages that they brought to bear.
To begin with accountable care, the CIO from Allina Hospitals and Clinics in Minneapolis, Susan Heichert, is part of a pioneer ACO — certainly one of the early ones. She is in the beginning stages of their ACO but brings a lot of experience to the table because her organization has had a bundled payment system for some time, so a lot of good experience to work with in developing her ACO. Second participant was Albert Oriol, who is at the Rady Children’s Center in San Diego. He’s conducting a pilot project in collaboration with California’s Department of Healthcare Services to treat children who are part of the California Children’s Services Program. He noted that the pediatric hospital is a very complicated job because you have to get both the children and the parents involved. He said it’s difficult with families with small children, but when you add adolescents, that really is a whole other level of challenge.
CIO Neal Ganguly who represents CentraState Healthcare System in Freehold, New Jersey, talked about the issue of patient data matching, which obviously does come up in a lot of our forums. He said this is a key issue that absolutely needs to be addressed, because if you can’t find the right patient when you query your HIE, you can’t ensure the best quality, and this goes across their ACO that they are building. Sort of a final comment on ACOs — they all agreed that while participating in an ACO, you obviously still have to remain competitive. But to that point, hospitals decided that they would compete on quality, really not on the amount of data that they could amass within their ACOs. We had a lot of good audience questions, and I think people got a lot out of it.
The second issue I’ll mention is Meaningful Use. Timing was a key issue, which was expressed by Chuck Christian, who is at the St. Francis Hospital at Columbus, Georgia. He indicated that we need to proceed at the appropriate speed, and that some states and hospitals are much further along than others. He said we won’t be able to realize the potential of the program unless everyone is on board. I should just make a note — and we can talk a little bit more about that, but CHIME, as you may know, recently proposed to extend the time period for Stage 2 Meaningful Use. This is both to encourage more providers to get on board as well as to give the EHR developers the necessary preparation time. That really concludes my comments on the symposium or the forum, and I think probably we’re going to repeat this again next year.
Gamble: Okay. That was one of the things I was going to ask you is that it’s something that you see doing again, because it had the benefits that you had hoped.
Canner: Absolutely, it really went beyond my expectations. I was hoping for a modest turnout, but we filled the room and then some, so that really was quite gratifying.
Gamble: What were some of the reactions you saw from the government representatives? I know it’s hard to say, but do you think that they were surprised by some of the things they were hearing? Do you think they learned a lot about the complexities of ACOs and Meaningful Use?
Canner: I think so. We were fortunate to have some pretty senior staff there, particularly from ONC, so they were not new to CHIME and some of the issues. But we also had some other attendees from agencies that are not as much involved with health IT, and I think it was an eye-opener for some of them to listen to specifically, ‘this is where the rubber meets the road’ and ‘this is how it happens.’ It’s difficult, frankly, to ask a CIO who has more than a full-time job to take the travel time to come to Washington and go up to Capitol Hill. That was a challenge to do that, and I think it was appreciated by the audience.
Gamble: I would imagine there’s tremendous value for them in hearing from the CIOs and hearing about their experiences and their challenges.
Canner: Absolutely.
Gamble: You touched a little bit on Meaningful Use State 2 and CHIME’s viewpoint that it should be delayed. When we spoke to Russ Branzell, he said he welcomes discussion from senate leaders and that he really is encouraging this dialogue between health IT industry leaders and government. Do you see something that could really become a positive and help make some changes down the road?
Canner: We do, and I want to ask Jeff if he would talk about that. We actually followed up after the forum with a meeting with ONC in particular, and have had subsequent talks since that time. So I’ll ask Jeff to summarize some of those discussions.
Smith: I’m happy to, Kate, and thanks for the question. In terms of whether dialogue between health IT industry leaders and government is positive, I think absolutely. I think more than that, though, it’s necessary. A lot of what we try to do here in Washington as a policy shop in helping get our CIOs involved in the conversation is really to help government officials, be they in the administration or congress, understand the current state of play in health IT. There’s a real need for these officials to understand how the policies that they pass, either through legislation or through regulations, are playing out on the ground. I think it’s more than positive; it’s necessary.
The event that Sharon spoke about could not have been timed more perfectly, because as you mentioned, or as you probably know, we submitted a response to a group of senators who had issued a reboot report where they questioned progress made under the policy of Meaningful Use. We thought that the reboot report actually highlighted a number of fair and responsible criticisms of the program, and we actually thought they echoed many of the concerns we have voiced over the last three years. For example, we believe that there needs to be more focus on standards development and quality measures. We recommended that congress continue its support of the S&I framework and actually look to enhance ONC’s standard-setting resources. We also encouraged congress to use its oversight powers to compel more thorough and robust evaluation of Meaningful Use. These are things that we’ve mentioned previously in comments to CMS and to ONC. We wanted to first acknowledge the validity in some of their criticisms.
Having said that though, we also believe that Meaningful Use is fundamentally the right direction, and we urge the senators not to stop, not to delay, and not to pause the program. We believe that there is a need to make some course adjustments, but that Meaningful Use is setting an integral foundation to transform healthcare.
I think that this segues into the second big point that we tried to make to the senators through our response to the reboot report, which you touched on a little bit earlier, and that was a call to extend the Stage 2. Extend is how we worded it; in our minds, this was a very conscious grammatical decision. We actually didn’t want to paint this as a call to delay Stage 2. We think that there is a need to reassess the timelines and a need to look at what course adjustments might be helpful in what we call maximizing the opportunity of program success. So CHIME’s primary concern is that eligible hospitals and eligible professionals will not achieve their required stage of Meaningful Use on schedule because of the timing crunch between when they receive 2014 edition certified EHR technology and the end of the fiscal or calendar year. We worry that the scenario will drive disparities between more advanced and less advanced providers, that it will compromise progress made toward interoperability, and quite frankly, that it will jeopardize nearly the entire $30 billion in tax payer investments to modernize the nation’s healthcare infrastructure.
As you probably know, we received quite a lot of media attention for this aspect of our letter. In the weeks since then, we’ve made the recommendation and basically have been working on how we could define such as extension. What would this look like on a practical level? In order to “maximize the opportunity of program success,” as we framed it in the senate letter, we have really tried to hone in on the message that we really do favor an approach that accomplishes three things.
First, we want to maintain Meaningful Use momentum, and that’s why we’re not suggesting a delay to the start of Stage 2. In fact, we want to keep the start of Stage 2 at the beginning of federal fiscal year 2014 or calendar year 2014, depending on if you’re a hospital or eligible professional. The other thing is we want to relieve pressure in 2014 by allowing additional time for EPs and EHs to meet their required stage measures and objectives. Thirdly, we want to give providers release from penalties if they meet their required stage in 2014 and 2015. We’ve looked at how we could accomplish these goals and we believe that we actually do have a few policy options. Chief among those that we’re really focused on right now is looking to expand the reporting period for 2014 by two or three quarters.
This would keep programmatic timelines in place while giving providers the needed time to make in particular Stage 2. I think it would be fair to characterize our focus on Stage 2 and those eligible professionals and hospitals that are looking to make Stage 2 in 2014, but we also think that other groups of Meaningful Users could use the help, because again, what we see as the central problem is the timing crunch between getting the certified technology and the end of the reporting period or end of the year.
Without going too heavily into some of the statutory and regulatory barriers, we do believe that this approach is feasible. We think that if you give hospitals and professionals an extra quarter or two in 2015 to meet Stage 2, we believe that you mitigate, to a large extent, the challenges mentioned previously. Essentially, we think that maximizing the opportunity of program success can be achieved by giving providers an extra few quarters in 2015 to meet the requirements of Stage 2 2014. The challenges of Stage 2 are daunting, but we do believe that they’re surmountable, and if we can make this small adjustment, I think you will definitely see the gains afforded to the provider community and to patient care, costs, and outcomes.
Gamble: I like how you clarified that you’re not talking about a delay, but rather an extension. From the input we’ve heard, it seems like it’s something that’s not going to necessarily cause organizations to say, ‘Okay, now Meaningful Use is moving down our priority list.’ They’re going to keep going forward with their plans and stay on course.
Smith: And that’s vital. It really is, because some of the criticisms we’ve received and that we expect to continue to receive is that this kind of change compromises the momentum, and really we don’t think that will be the case. We really do think that by keeping the current timeline — the current start date, this is actually going to allow vendors to roll out their products and help providers implement the products in a stable fashion. We think that giving extra time to providers is going to allow them to implement it and start to use the technology in ways that translate to better care, lower costs, and better population health. There are going to be hospitals that can absolutely make Stage 2 on time, and they’re not going to have much problem getting there. We are going to be helping those hospitals get to Stage 2 as fast as they can, because we think that’s the right thing to do.
But we also know that there is a significant segment of the provider community, on both the EP and the EH side, that are really going to be putting the pedal to the metal on this thing, but they’re just not going to make it. We know that there are a certain amount of hospital leaders, especially people that we talk to on a regular basis, who have looked at the cost benefit of this. And we worry that you stand to lose much more momentum by keeping the current timeframes than you do by extending the reporting periods, because at that point you’re really putting attainment of Stage 2 back within reach. We do think that there’s going to be an incentivizing factor to doing that.
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