Editor’s Note: We originally wrote this post detailing the reasons that Stage 2 Meaningful Use was unattainable for most eligible providers before CMS announced the proposed rule on May 20 that changes the requirements. In the article, we outlined the obstacles that were preventing most providers from successfully attesting in the existing ecosystem. As we predicted, CMS was forced to change the requirements due to these issues.
A recent article in Medical Economics entitled “Physicians, EHR vendors struggling with Meaningful Use 2, CMS data shows caught our attention—because what’s actually happening is something we predicted in a January blog post. The article’s theme is correct, but the explanation of why physicians are struggling is lacking detail. Without the detail, Medical Economics may have left providers still scratching their heads.
We felt the best way to fill in the holes in the Medical Economics article was to update our January 2014 blog entitled “Who’s in Control of My Meaningful Use Success? – It Takes a Village,” which discussed the fact that attesting for Meaningful Use Stage 2 in the first quarter of 2014 was a pipe dream for most EPs.
According to Medical Economics, only 50 eligible professionals (EPs) have attested for MU2 in the current reporting year, which began on January 1, 2014. The overwhelming majority of vendors certified for 2011 have not been certified for the Office of the National Coordinator (ONC) 2014 standard. In fact, per the ONC, the total number of vendors offering a complete EHR system with 2014 certification reached just 97 as of mid-April 2014, as compared to 454 vendors that met the 2011 certification standard.
The good news is that many reputable EHRs that have a significant provider base have met the standard, so that around 80% of the providers that use an EHR have one that was certified. So you may ask, “Where is the obstacle to Meaningful Use attestation?”
Here’s the answer: The two requirements that involve parties outside of the practice.
We have begun hearing from our users who are encountering these roadblocks. If you ask providers about Meaningful Use Stage 2 requirements, they will first offer their frustration regarding these two core patient engagement measures:
- View Medical Record Online
- Secure Messaging
The providers’ point of view is that they should not be responsible for patients contacting them via a secure message or viewing their record on a patient portal if a patient does not want to. We agree, but for motivated providers these measures are achievable because the physician has some influence over patient behavior and the thresholds are low.
But if patient engagement is frustrating, the core measure “Summary of Care Record for Each Transition of Care” that requires secure messaging is impossible for the average community-based provider.
Measure Description: The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral.
This is a multi-part measure that includes:
Part 1 Definition: The EP that transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50 percent of transitions of care and referrals.
Part 2 Definition: The EP that transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 10% of such transitions and referrals either is electronically submitted or electronically exchanged.
(Note: there is a third part of the measure that does not impact community doctors on disparate EHRs.)
Part 2 of the Core Measure “Transition of Care” is the portion that even the most motivated providers and vendors cannot overcome on their own. It requires an overhaul of each local health IT ecosystem. No single vendor or provider can change that ecosystem. For most providers, Part 2 of the measure requires the sending and receiving of Direct Messages (secure email).
There are several reasons why these requirements are a major stumbling block for most community-based providers:
1. Regarding the requirement that patients view their medical record online and secure message their provider, patient engagement measures are difficult for providers to meet due to:
- Poor patient portal technology
- Patient training issues
For the secure messaging requirement, there are several issues:
2. Just because your vendor is certified, it does not mean the software was implemented in your practice.
- Your client server-based software may be waiting for the upgrade from your vendor
- Your software may be upgraded, but important features like the direct messaging email address have not been enabled by practice
3. The ecosystem is not ready.
- Your vendor’s HISP (the service provider for Direct Messaging) is not connected to another vendor’s HISP
4. Finally, physicians just don’t feel ready:
- Related to the reasons above
- Many practices may have been focusing on ICD-10 prep and delayed efforts to connect electronically to other providers and facilities
Electronic Submission of the Summary of Care Record
Our MediTouch® EHR provides Direct Messaging for our providers; our EHR software is 2014 Meaningful Use certified, and there is no charge to our providers to get a secure email address and to connect to the Health Information Service Provider (HISP) we use. Our HISP is completely open to trading information with other EHRs; we use the Surescripts HISP, a leading provider that is also used by Epic, GE Healthcare, NextGen and others.
But as mentioned above, there are a lot of reasons that community based doctors can’t electronically transmit Summary of Care records to other care providers. Bureaucracy is playing a role in this delay, as some of the larger software providers are willing to exchange the security certificates that allow the exchange of information, but many others are either not willing or not able.
In other words, the kingdom is being lost for want of secure email. In Part II of this blog post, we’ll discuss what CMS is doing to alleviate this situation.