Transcript Document

Meaningful Use in HIT:
The Consumer and Purchaser Perspective
Background and Overview of the Proposed Rule
Peter V. Lee
Co-chair, Consumer-Purchaser Disclosure Project
National Policy Director, Pacific Business Group on Health
David Lansky
President and CEO
Pacific Business Group on Health
Eva Powell
Director, Consumer Partnership for e-Health
National Partnership for Women & Families
Webinar
March 9. 2010
Agenda
Welcome and Background on Meaningful Use Notice of
Proposed Rule Making (NPRM)
– Peter Lee, Disclosure Project and PBGH
Elements Most Relevant to Consumers and
Purchasers/Crosswalk with Disclosure’s Comments to
CMS
– David Lansky, PBGH
– Eva Powell, NPWF
Discussion and Q&A
– Peter Lee
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Health Reform Elements
Major Policy Area
Critical Value Policies
Coverage expansion
and Financing
1. Align public and private policies
2. Connector or Exchange promoting value
Benefits
3. Assure core benefits promote affordable “right care”
System Reforms
4. Full measures and public reporting (including release
Medicare data)
5. Promote wellness
6. Consumer and provider incentives for shared
decisions
7. Payment reform – Change payments AND the decision
process
Infrastructure
8. Patient-centered comparative effectiveness
9. HIT that promotes better care
10. Foster innovation
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HIT that Promotes Better Care – Making Sure
Information Technology is “Bridge to Somewhere
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NOT about boxes in doctors offices – it is
about fostering true “meaningful use”
Supporting decisions by clinician at the point of
care and reduce errors
Involving patient in their own information
Collecting real-time performance information for
measurement purposes
Gives feedback to patients and clinicians
Promotes innovation
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Meaningful Use Background
• HITECH provisions of ARRA created voluntary Medicare &
Medicaid incentives for meaningful users of EHRs
– Carrot and stick approach: incentives in 2011, 2013, and 2015;
penalties after 2015
• Core Criteria in HITECH:
1. Use certified EHR in a meaningful manner, including eRx
2. Engage in electronic exchange of health information to improve
quality
3. Report on clinical quality measures
• In July 2009, HIT Policy Committee recommended framework
definition of Meaningful Use.
– CMS used this as the basis for the proposed rule released in
December 2009, comments due March 15, 2010.
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The Proposed CMS Rule Moves Health
Care To Being More Patient-Centered:
– Increased focus on improving health care and outcomes
– Inclusion of patients and families as primary participants in health
information sharing.
– Criteria stages build upon each other to provide a glidepath for
phased implementation that avoids dead-ends.
– Balances achievability by a broad array of health care professionals
with the urgency to stimulate significant progress toward improved
health and health care.
– Aligns Federal policy levers and ARRA programs to support
meaningful use (Funding for RECs, Beacon, etc)
– Prioritizes use of resources to provide support to areas and providers
that have the greatest need.
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Consumer and Purchaser Opportunities
• Participate in the national dialogue to be sure
“Meaningful Use” is defined to meet patient
and purchaser needs – as well as providers
• Make sure your voice is heard:
– Sign-on to the Disclosure Project letter, and send
individual letters from your organization supporting
CMS’ proposed definition in the face of provider
challenges
– Send your own letter
– Engage nationally and locally in discussions on
Meaningful Use
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Advocacy Messages for Consumers and
Purchasers
• CMS’ proposed meaningful use definition supports the
elements necessary to create a patient-centered health care
system
– The purpose of incentive payments for meaningful use is not to
reward the status quo, or to digitize paper health records. It is to
accelerate transformation of the system and ensure that
transformation leads to significant differences for patients and their
families.
• We urge consumer, labor, and employer organizations to
voice strong support for CMS in its efforts
– CMS is facing strong opposition from the provider community, which
argues that the requirements for incentives are too burdensome.
• The proposed definition is directionally appropriate and we
encourage CMS to maintain its robust meaningful use
criteria.
– Public dollars are being devoted to assuring that HIT is used in a
meaningful way; thus public goals MUST be met despite provider
opposition
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How to Voice Your Support
• Add your organization’s name to the
Disclosure Project’s comment letter
• Submit a letter from your organization:
– Go to www.regulations.gov
– Cite CMS-0033-P
– If you submit your own letter, please send
a copy to [email protected]!
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Meaningful Use in HIT:
The Consumer and Purchaser Perspective
David Lansky
President and CEO
Pacific Business Group on Health
Eva Powell
Director, Consumer Partnership for e-Health
National Partnership for Women & Families
Webinar
March 9. 2010
The Proposed Rule: What It Is & Why It
Matters
David Lansky
President and CEO
Pacific Business Group on Health
Eva Powell
Director, Consumer Partnership for e-Health
National Partnership for Women & Families
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Bottom Line on the Proposed Rule:
• CMS is on the right track with the
proposed rule.
• The final rule must maintain its
strong and ambitious direction to
ensure that the public truly benefits from
this incredible investment of taxpayer
dollars.
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The Definition of Meaningful Use Supports
Critical Goals:
• Increasing care coordination and fostering better
doctor-patient communications
• Reducing medical errors and improving patient safety
• Supporting delivery of evidence-based care
• Reducing disparities by recording demographic
information
• Improving quality while fostering more cost-effective
delivery
• Advancing payment reform
• Providing patients with their own, portable health
information
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Definition is Directionally Appropriate
• Strongly supports a patient-centered view of
health care
• Offers providers flexibility, yet retains patient
privacy and security
• Appropriately uses clinical quality
measurement
• Makes appropriate allowances for the current
state of technology infrastructure
• Will result in vast improvements in data
collection and understanding of how care is
delivered
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A Definition that Takes Consumer and
Purchaser Concerns Into Account
• For consumers: Focuses on improving care
and outcomes and not just automating
processes and digitizing data
• For purchasers : Focuses on evidencebased strategies that can ultimately reduce
the rate of cost increases, improve care and
outcomes, and reduce spending
• Two important components:
– Quality measurement using clinical data
– Race, ethnicity, language and gender (“RELG”)
data collection
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Need for Consumer and Purchaser Voice in
Face of Provider “Slow Down”
• Providers and other health care industry
stakeholders voicing strong opposition
to this proposed definition
• Consumers and Purchasers must take
advantage of the advocacy
opportunities available in this arena
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Meaningful Use Addresses Provider
Concerns: Concerns & Responses
• Very few providers would be able to fulfill all of the criteria today. We
should scale it back so more providers can receive payments
– Rather than weakening the definition to increase participation rates, we
should take this opportunity by harnessing the efforts of various nationaland state-level technical assistance programs to support provider
participation and make great strides toward a patient-centered health
care system.
• It takes years to fully adopt and implement EHR technology. The MU
definition is asking too much, too soon for 2012
– In the first year providers will only have to demonstrate MU for 90 days,
giving them 9 months to improve their systems.
• The criteria are focused too much on primary care. Specialists will
not be motivated to meet the requirements to receive incentives
– The definition’s orientation toward primary care is appropriate and
necessary, given the role primary care providers play in our system, the
shortage of providers, and the existing inequity in reimbursement for PC
services.
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Arguments and Responses, con’t
• Small primary care practices won’t have the resources to implement
such high-level technology
– HITECH includes funding for Regional Extension Centeres to provide small
practices with technical assistance. Medicaid providers will also receive
funding in the first year to adopt, implement, or upgrade certified EHR
technology.
• Collecting RELG data is not as simple as adding a data field
– Having better information about patient demographics is critical to
eliminating health disparities and improving care for vulnerable populations.
Providers can and should communicate this to patients, while assuring them
that personal identifiable information will be protected.
• There are too many quality measures required for receiving incentives,
making it redundant with other pay-for-reporting programs
– The HITECH program is not a reporting program. We advocate for required
MU measures to be clearly linked to improved outcomes, thereby meeting
the intent behind MU of HIT.
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Make HIT Truly Meaningful to
Consumers and Purchasers
• Current definition of meaningful use focuses – appropriately
– on specific goals, objectives, and measures to determine
whether those objectives are met
• Ultimately need to get away from this silo’d view of the
system to understand whether the health care system is
truly meeting consumers’ and purchasers’ needs.
• We need processes to evaluate whether greater use of HIT
through EHRs and Personal Health Records (PHRs) is
positively affecting consumers’ experience at the point of
care, by measuring changes in how patients are actually
experiencing care.
Until we understand how consumers are reacting to the
implementation of HIT, we will not truly recognize the
investment being made by HITECH
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How to Voice Your Support
• Add your organization’s name to the
Disclosure Project’s comment letter
• Submit a letter from your organization:
– Go to www.regulations.gov
– Cite CMS-0033-P
– If you submit your own letter, please send
a copy to [email protected]!
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Appendix:
Details of the Meaningful Use
Proposed Definition
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Timeline for Phase-In
• Stage 1: Centers on health information collection and using it
to track key clinical conditions, communicate about care needs
(including provider-provider and provider-patient
communication), facilitate disease and medication management,
and report key quality and public health information.
• Stage 2: Focuses on exchanging and using information to
improve the care of individual patients.
• Stage 3: Concentrates on promoting systematic
improvements through promoting improvements in quality,
safety and efficiency, advancing decision support for national
high priority conditions, providing patient access to selfmanagement tools, facilitating access to comprehensive patient
data, and improving population health.
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Structure of Incentive Payments
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Staged Implementation
• Linked to each stage is a set of criteria for
meaningful use of EHRs that providers must
satisfy to receive an incentive or avoid a
payment reduction (in 2015)
• Staging will both reward early adopters as
well as encourage broad adoption over time
• This NPRM focuses on the Stage 1, 20112012 criteria
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Overview of Functional Criteria
• Priority Areas:
– Improving quality, safety, efficiency, and reducing
health disparities
– Engage patients and families in their health care
– Improve care coordination
– Improve population and public health
– Ensure adequate privacy and security protections for
personal health information
• The Priority Areas All Track to Those Identified by
the National Priorities Partnership
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Stage 1 Functional Criteria
• Focus is on:
– Electronically capturing health information in a coded format;
– Using information to track key clinical conditions and
communicating that information for care coordination
purposes;
– Implementing clinical decision support tools to facilitate
disease and medication management; and
– Initiating the reporting of clinical quality measures and public
health information.
• Examples: Record demographic data, maintain up-to-date
problem list, test ability to exchange information.
• Proposed rule sets thresholds for each
– E.g. Record demographic data for 80% of patients
• EPs would fulfill 25 functional criteria.
• Eligible Hospitals would fulfill 23
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Quality Reporting Component
• Eligible providers (EPs) would report summary
data on 2 sets of quality measures:
– 4 Core measures
– 3-5 Select specialty measures
• Hospitals would report on a subset of 43
proposed measures, based on public input
• Providers use attestation via survey to report
summary data on clinical quality measures in
2011, while CMS works to build infrastructure for
accepting data collected through EHRs
– Expect electronic reporting in 2012
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Flexibility That Does Not Sacrifice Privacy
Ways the proposed rule provides flexibility:
• Providers can choose the payment year in
which they start (doesn’t have to be 2011)
• Providers choosing to start in later years can
still receive significant payments
• In PY1, required to demonstrate MU for 90
days
• Thresholds vary across functional
requirements
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Appendix:
Detailed Analysis of Proposed Rule
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Strengths and Weaknesses of the Definition
• Within Specific Goal Areas:
– Care Coordination
– Reducing Medical Errors and Improving
Patient Safety
– Patient and Family Engagement
– Reducing Health Disparities
• In Cross-Cutting Areas:
– Quality Measurement
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Increased care coordination and fostering
of better doctor-patient communication
Where MU Succeeds:
• Connecting information across internal silos, improving
providers’ ability to coordinate care.
• Medication reconciliation
• Summary care records
• Test ability to exchange key clinical data, based on capabilities
of certified records today
Where Improvements Are Still Needed:
– Reinstate patient education criteria
– Add more care coordination measures (i.e. NQF measures
recently endorsed) in later stages
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Reduced medical errors and improving
patient safety
Where MU Definition Succeeds:
– CPOE Requirements
– Providers must maintain up-to-date problem lists of patients’
current and active diagnoses
– Drug-drug, drug-allergy, drug-formulary safety checks
– Implement 5 clinical decision support rules
– E-prescribing and transfer of Rx information
– Medication reconciliation
Where Improvements Still Needed:
– Definition is strong for the first year of incentives, and should
evolve to be even stronger in succeeding years.
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Increasing Patient and Family Engagement
Where MU Definition Succeeds:
• Connects patients and families to the health care system, giving
them timely access to their personal health information
• Electronic copy of medical information within 48 hours of request
• Electronic after-visit clinical summaries
• Electronic discharge instructions
• Ongoing, timely electronic access to information
Improvement Still Needed:
• Providing electronic copies of information is a success, but in the
proposed definition patients still have to request it. A better model
would be for all patients to be asked if they want this information,
since not all will know to ask for it.
• Reinstate advance directives in EHRs
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Reducing Health Disparities
Where MU Definition Succeeds:
– Requirement that EHRs collect information on
patients’ race, ethnicity, language, and gender
(RELG).
Where Improvements Still Needed:
– Require that providers stratify quality data by
RELG
– When generating lists of patients by specific
condition, require that providers stratify lists by
RELG
– Bottom line: collection of RELG is not enough;
data must be used to be effective
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Quality Measurement Strengths
• Stage 1 only requires providers to demonstrate
whether they adequately use EHR capabilities;
Defends against providers’ concerns that CMS
is moving too fast
• Initial set of measures are reasonable and align
well with the criteria set out by the HIT Policy
Committee:
– Capturing patient health information
– Using EHR tools for provider decision-making,
patient reminders and insurance activities
– Giving patients access to their health information
– Exchanging information and facilitating care
coordination
– Security and Privacy
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Quality Measurement Weaknesses
• Core Measure Set measures are not
strong or representative of true core
measures
• EP and Eligible Hospitals’ Quality
measures mainly process-oriented
• Lack of discussion in the proposed rule
of integration of registry data
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Room for Improvement in Quality Measurement
• Require all appropriate EPs to report on the three core measures in
the NPRM for 2011-2012; redesign the core measure set for 2013
and beyond
• To streamline reporting requirements, drop measures that require
manual tallying. Focus on exemplar measures that:
– Require providers to utilize different functions of the EHR in providing
care for their patients
– Can be collected easily as a byproduct of the care process
– Involve using clinical (vs. administrative) data
• Add measures that are meaningful to consumers and purchasers in
the areas of pediatrics, obstetrics/gynecology, long-term care, oral
health, and substance abuse and mental health. Meaningful
measures include ones that address outcomes and overuse of
diagnostics and procedures
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About the HIT Policy Committee and CPeH
•
HIT Policy Committee: Charged with making recommendations to the
National Coordinator for Health IT on a policy framework for the
development and adoption of a nationwide health information
infrastructure, including standards for the exchange of patient medical
information.
– Meaningful Use Workgroup included consumer and purchaser
representation
– http://healthit.hhs.gov/portal/server.pt?open=512&objID=1813&pare
ntname=CommunityPage&parentid=4&mode=2&in_hi_userid=1074
1&cached=true
•
The Consumer Partnership for e-Health: CPeH is a non-partisan
coalition led by by the National Partnership for Women & Families. It
includes over 50 consumer, labor, and patient organization members
working at both the national and local levels, and advocates for HIT that
plays a critical role in the creation of a patient-centered health care
system
– For more information go to www.nationalpartnership.org/hit
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About the Disclosure Project
The Consumer-Purchaser Disclosure Project is an initiative that is improving health
care quality and affordability by advancing public reporting of provider performance
information so it can be used for improvement, consumer choice, and as part of
payment reform. The Project is a collaboration of leading national and local
employer, consumer, and labor organizations whose shared vision is for Americans
to be able to select hospitals, physicians, and treatments based on nationally
standardized measures for clinical quality, consumer experience, equity, and
efficiency. The Project is funded by the Robert Wood Johnson Foundation along
with support from participating organizations.
Previous Discussion Forums are available at: http://healthcaredisclosure.org/activities/forums/
For More Information Contact:
Tanya Alteras, MPP
Associate Director
202-238-4820
[email protected]
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