Framework for Empowering Pathology in the Electronic Health

Record

• Walter H. Henricks, MD, FCAP, The Cleveland Clinic Foundation

• Jodi G. Daniel, JD, MPH, Office of the National Coordinator for Health Information Technology

Walter H. Henricks, MD, FCAP

Framework for Empowering Pathology in the EHR

May 8, 2012

Objectives

• Review HIT Regulatory Framework

• Discuss Two Regulatory Challenges & Policy Solutions

• Note What CAP Can Do & What You Can Do

Regulatory Framework: ARRA

Pathology’s Two Challenges

Challenge #1

• Suboptimal management of laboratory information in EHRs

• CPOE design and configurationissues

• Potential patient safety issues• Hidden costs

Suboptimal Lab Data Handling in EHR

This EHR report is

garbled, I need to call the lab

We don’t control the EHR, you’ll

have to call IT

Example: Garbled PAP report in EHR

• Example of unpublicized “nonstandard” view of Pap smear result in EHR – garbled text

• Not widely used; was not known to lab at time of interface validation

Lab Data Problem Symptoms

• Reference ranges, comments, footnotes

• Abnormal result flags, preliminary reporting and updates

• Improper handling of: • Corrected results • Unsolicited results• Reflex tests• Performing lab name & address

Poor CPOE Symptoms

• Incorrect, incomplete, inappropriate test orders

• Inefficient lab/provider operations

• Billing & compliance problems

• Pitfalls – future orders, duplicate handling, canceled orders

Policy Initiatives – CAP…• Has submitted extensive comments on ONC

Stage 2 (2014) Standards & Certification Proposed ruleoNeed for FULL testing of pending laboratory

reporting guide before implementationoNeed for laboratory data/vocabulary

integrity as it moves throughout healthcare system

• Is working for pathologist role as laboratory data stewards in EHR environmentoDeveloping white paper

• Desires to partner with ONC and others on solutionso e.g. domain expertise for standards and/or

certification criteria

Challenge #2

• Pathologists are “non-hospital based” (per CMS definition) eligible providers (EPs) for MU incentives and penalties

• Challenged by MU requirements to:oUse certified EHRsoReport specified objectivesoReport clinical quality measures

(CQMs)

Incentive/Penalty Rule Challenges

• Certified EHRs: Pathologists do not practice in EHRs

• Report certain objectives: Objectives not applicable to pathology practice (written for office-based providers)

• CQMs: Not applicable to pathology practice

Regulatory Relief Possible

• CMS considering criteria for relief from penalties for eligible providers that:

1. Lack face-to-face/telemedicine interaction with patients

2. Lack follow-up with patients

3. Lack control over availability of certified EHRs at their practices

Legislative Solution on the Table

• H.R. 4066, “The Health Information Technology Reform Act” introduced by Rep. Tom Price MD (R-GA-6) o Removes pathologists from

eligibility for MU incentives or payment adjustments

o Penalty relief would be permanent

What CAP is Doing

• Advocating for regulatory relief

• Seeking passage of H.R. 4066

• Developing white paper on best practices for lab data/transmission

Partner with Stakeholders

What You Can Do at Home

• Advocate for patients’ laboratory information in EHR

• Develop some expertise:o Intradepartmentalo Institutional

• Raise awareness and provide domain expertise at institutional level

What You Can Do Here

• When you visit your Senators/Congressmen….

• Ask them to support H.R. 4066!

Summary

• ARRA hastening EHR adoption

• CAP working to advance HIT and protect pathologists

• You have a role in DC and at home

• Constructive dialogue with policymakers & other stakeholders to continue