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Health Information Exchange
Dee Cantrell, RN, BSN, MS, FHIMSSChief Information Officer
Emory Healthcare
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Woodruff Health Sciences Center
Emory Children’sCenter
Emory RehabilitativeMedicine Center
Emory University Orthopaedics & Spine Hospital
Emory University Hospital
Emory University Hospital Midtown
Wesley Woods Geriatric Hospital
The Emory Clinic
Emory Johns Creek Hospital
Saint Joseph’s Hospital
Emory Healthcare HIE
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Emory Healthcare HIE
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Contributors to the Clinical
Integration Network
More detailed view “inside” the HIE
Emory Healthcare Continuity of Care Document
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The EHC CCD Contains:
•Patient Demographic Data•Results•Medications•Allergies, Adverse Reactions, Alerts•Problem Lists•Procedures
Emory HealthcareHIE Portal View
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Disclaimer: This record is an aggregate summary of medical information obtained from multiple participating healthcare providers. The clinical summary is intended to support optimal patient care. It is not intended to replace the patient’s medical record nor is it
guaranteed to encompass all historical information on this patient. It is provided to you in conformation with patient privacy requirements.
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TEN LESSONS LEARNED
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Lesson #1: It is Harder Than it Looks
• Stage 1 Criteria published 7/31/11
• From Aug to Nov 2011– The number of CIOs
expecting to qualify in the first 6 months of the program dropped substantially
– The number expecting to qualify in the late FY2011 or FY2012 increased
9*Source: CHIME Survey, Nov 2010
Lesson #2: Communication is Key
• Important to get buy in early• Message for MU needs to focus on patient, not the money• Find a way to address clinical efficiency in some way• Work to decrease frustration and increase communication• Some communication messages to consider:
• Make this about the patient and family• Maintain transparency• Communicate to providers at all opportunities – build
awareness
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Lesson #3: Read the Fine Print
• Certified EHR means ‘acquire’ all modules for MU– This includes the menu items you are NOT attesting to
• Additional modules from your core vendor may be required for some criteria
– Continuity of Care Document- Public Health – Immunizations– Public Health – Reportable Labs– Public Health – Syndromic Surveillance
– Did your core vendor get certified?• Are you on the right version? Do you have all required modules?
– Any third-party modules that make-up an EHR must be certified• Make sure your third-party vendors have applied for and will
achieve certification before you attest!
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Lesson #4: Keep an Audit Trail
• Hospitals and EPs can be audited for MU payments for up to 10 years after reporting/attestation
• Audit trail should include:• Documentation on relevant IT systems, system configurations, roles, and
processes for each MU criteria• Documentation on system certification (versions, certification #s, etc)• Reports/data for each reporting period & reporting entity• Any confirmations or other communication to CMS or the State
• Things we also did: • Maintain a limited access file share for audit materials• Keep screen shots of registration and of attestation• Keep rules as they existed during the time frame you are attesting• Understand data pointers and how data/patients were counted• Maintain detailed copies of all functional and quality reports
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Lesson #5: MU isn’t Just an IS Project
• “Clinical Transformation must be clinically led and IT enabled”
• Implementing MU criteria requires significant process redesign and training in addition to application enhancements
• New responsibilities & processes for clinicians, administrative staff, e.g. CPOE, smoking cessation counseling, discharge instructions
• New tracking and reporting processes (e.g., patients requesting an electronic copy of their medical record)
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Lesson #6: Clinical Quality Reporting is NOT Easy
• Capturing data for clinical quality measures may require substantial workflow & clinical documentation changes
• Current electronic documentation may not capture everything needed to meet the measure specifications for MU
• To achieve these measures, EHs and EPs will need to acquire functionality not formally part of MU:
• MD Documentation, RN Documentation
• Good news: you only have to report, there is no goal threshold to achieve
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Lesson #7: HIE – It’s Complicated
• Requires coordination with the state/regional HIE, physicians practices, and others
• It is complicated and there are many potential points of failure
• HIE analysis, policy development and implementation will require significant effort by all parties
• Defining clinical and administrative workflows• Participating in state & regional activities• Data sharing agreements & business associate agreements
• Sustainable business model is still a challenge
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Lesson #8: Registration and Attestation
• Give Yourself Plenty of Time!• Register Early - Registration takes from 2 to 6 weeks – but can do this today• Send everything overnight or certified mail• CMS / MU program registration must match up with your PECOS system
• When you are Ready to Attest:• Decide how you will handle the attestation process for the providers– can be
delegated, but providers have to authorize• Maintain collaboration on the registration and then attestation process – i.e.
make sure same players involved • Have copies of all reports, including all Quality Reporting output available• Have number for CMS “customer service” available – don’t hesitate to call;
note names and ask for documentation for anything they say• Completed attestation as a group – checking and re-checking data entry• Remember to keep all reports and documents for audit purposes
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Lesson #9:The Medicaid Incentive
Program• Remember as an EP – you have to pick between Medicare and Medicaid
programs• State programs vary – make sure you know the needs of the GA plan • State registration needs encompass several major areas and can be
complicated • Sample of Documents you may need
• Cost reports (identification of which years based on fiscal reporting year)
• Proof of moving to certified code (receipt, vendor work plan, signed contract, etc.)
• Vendor certification number(s)• Copies of Contracts (may need to be redacted by vendor)
• Maintain Audit materials (CMS already conducting audits in states with early programs)
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Lesson #10: The Incentive Money Isn’t Free!• Costs to close the gap to meet MU include
• Upgrades/enhancements to EHR software• Cost of process redesign and training • Clinician & staff time in design, training• IS Staff time
• Infrastructure requirements are often overlooked and can be significant
• Encryption and security (most notably for PHI)• Infrastructure to meet increased application load
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