EHR technology’s capacity to submit electronic data to immunization registries

The Stage 1 meaningful use criteria focus on the elec- tronic capture of health information in a coded or struc- tured format; using that information to track key clinical conditions and communicating that information for care coordination purposes (whether that information is struc- tured or unstructured, but in structured format whenev- er feasible); implementing clinical decision support tools for disease and medication management; and reporting clinical quality measures and public health information. Stage 2 goals will expand upon the Stage 1 criteria to en- courage the use of health information technology (IT) for continuous quality improvement at the point of care and the exchange of information in the most structured format possible, such as the electronic transmission of orders entered using computerized provider order entry (CPOE) and the electronic transmission of diagnostic test results (such as blood tests, microbiology, urinalysis, pa- thology tests, radiology, cardiac imaging, nuclear medi- cine tests, pulmonary function tests, and other such data

Journal of Health Care Compliance — May – June 201034

HIPAA

needed to diagnose and treat disease). In Stage 3, HHS plans to focus on promoting improvements in quality, safety, and effi – ciency, with an emphasis on clinical deci- sion support for national high priority con- ditions, patient access to self-management tools, and collecting and providing access to comprehensive patient data sets.

Here are the 25 things contained in the Phase 1 proposed rule that eligible provid- ers must achieve with their certifi ed EHRs to qualify for bonus payments. They must per- form each of these tasks for 90 continuous days prior to the end of calendar year 2011 to earn their fi rst year maximum payment. 1. Use CPOE — Measure: CPOE is used for

at least 80 percent of all orders. 2. Implement drug-drug, drug-allergy, drug-

formulary checks — Measure: The eligible provider has enabled this functionality.

3. Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT® — Mea- sure: At least 80 percent of all unique patients seen by the eligible provider have at least one entry or an indication of “none” recorded as structured data.

4. Generate and transmit permissible pre- scriptions electronically (eRx) — Mea- sure: At least 75 percent of all permissi- ble prescriptions written by the eligible provider are transmitted electronically using certifi ed EHR technology.

5. Maintain active medication list — Mea- sure: At least 80 percent of all unique patients seen by the eligible provider have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data.

6. Maintain active medication allergy list — Measure: At least 80 percent of all unique patients seen by the eligible provider have at least one entry (or an indication of “none” if the patient has no medication allergies) recorded as structured data.

7. Record demographics — Measure: At least 80 percent of all unique patients seen by the eligible provider or admit-

ted to the eligible hospital have demo- graphics recorded as structured data.

8. Record and chart changes in vital signs — Measure: For at least 80 percent of all unique patients age two and over seen by the eligible provider, record blood pressure and body mass index (BMI); additionally, plot growth chart for chil- dren age two to 20.

9. Record smoking status for patients 13 years old or older — Measure: At least 80 percent of all unique patients 13 years old or older seen by the eligible provider “smoking status” recorded.

10. Incorporate clinical lab test results into EHR as structured data — Measure: At least 50 percent of all clinical lab test re- sults ordered by the eligible provider or by an authorized provider of the eligible hospital during the EHR reporting pe- riod whose results are in either a posi- tive/negative or numerical format are incorporated in certifi ed EHR technol- ogy as structured data.

11. Generate lists of patients by specifi c con- ditions to use for quality improvement, reduction of disparities, research, and outreach — Measure: Generate at least one report listing patients of the eligible provider with a specifi c condition.

12. Report ambulatory quality measures to the Centers for Medicare & Med- icaid Services (CMS) or the states — Measure: For 2011, an eligible provider would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this pro- posed rule. For 2012, an eligible provid- er would submit electronically the mea- sures as discussed in section II.A.3 of this proposed rule.

13. Send reminders to patients per patient preference for preventive/ follow-up care — Measure: Reminder sent to at least 50 percent of all unique patients seen by the eligible provider that are 50 and over.

14. Implement fi ve clinical decision support rules relevant to specialty or high clini-

CONTINUED ON PAGE 68

Journal of Health Care Compliance — May – June 201068

Compliance Professional: The HCCA Code of Ethics for Health Care Compliance Professionals in Guide to Professional Development in Compliance, Jan C. Heller, Joseph E. Murphy and Mark E. Meaney (Aspen Publishers: Gaithersburg, MD, 2001) pp. 77-91.

2. For an in-depth discussion of professional ethical development and the obligations of professional associations, see also Mark E. Meaney, Professional Ethical Development in Health Care Compliance in Guide to Professional Development in Compliance, Jan C. Heller, Joseph E. Murphy and Mark E. Meaney (Aspen Publishers: Gaithersburg, MD,

2001) pp. 1-18.

MEANEY CONTINUED FROM 24

ELECTRONIC RESOURCES CONTINUED FROM 32

physician had provided. During OCR’s in- vestigation, the physician confi rmed that the complainant was not given access to her medical record because of the outstand- ing balance.

OCR provided technical assistance to the physician, explaining that, in general, the privacy rule requires that a covered en- tity provide an individual access to his or her medical record within 30 days of a re- quest, regardless of whether or not the in- dividual has a balance due. Once the phy- sician learned that he could not withhold access until payment was made, the phy- sician provided the complainant a copy of her medical record.

These OCR case examples are great to use with your own HIPAA privacy and se- curity training programs.

HIPAA CONTINUED FROM 34

cal priority, including for diagnostic test ordering, along with the ability to track compliance with those rules — Measure: Implement fi ve clinical decision support rules relevant to the clinical quality met- rics the eligible provider is responsible for as described further in section II.A.3.

15. Check insurance eligibility electronically from public and private payers — Measure: Insurance eligibility checked electronical- ly for at least 80 percent of all unique pa- tients seen by the eligible provider.

16. Submit claims electronically to public and private payers — Measure: At least 80 percent of all claims fi led electroni- cally by the eligible provider.

17. Provide patients with an electronic copy of their health information (including di- agnostic test results, problem list, medi- cation lists, and allergies) upon request — Measure: At least 80 percent of all pa- tients who request an electronic copy of their health information are provided it within 48 hours.

18. Provide patients with timely electron- ic access to their health information (in- cluding lab results, problem list, medica- tion lists, allergies) — Measure: At least 10 percent of all unique patients seen by the eligible provider are provided timely elec- tronic access to their health information.

19. Provide clinical summaries to patients for each offi ce visit — Measure: Clinical summaries provided to patients for at least 80 percent of all offi ce visits.

20. Capability to exchange key clinical in- formation (e.g., problem list, medication list, allergies, and diagnostic test results) among providers of care and patient-au- thorized entities electronically — Measure: Performed at least one test of certifi ed EHR technology’s capacity to electronically ex- change key clinical information.

21. Perform medication reconciliation at rel- evant encounters and each transition of care — Measure: Perform medication rec- onciliation for at least 80 percent of rel- evant encounters and transitions of care.

22. Provide summary care record for each transition of care and referral — Mea- sure: Provide summary of care record for at least 80 percent of transitions of care and referrals.

23. Capability to submit electronic data to im- munization registries and actual submis- sion where required and accepted — Mea-

Journal of Health Care Compliance — May – June 2010 69

puting using industry-leading platforms such as salesforce.com can enable health care and insurance companies to rapidly set up fully operational call centers, pro- viding access to all of their legacy data on procedure, patient history, case man- agement, funding management, EHRs, et cetera. Schemes can be put in place to even supply staffi ng for a rapid launch of a fully functional call center.

Health care providers also may want to use a cloud computing application built on top of a software platform like salesforce.com for financial tracking or constituent management activities, as many other government agencies and public institutions have done. Sales and marketing teams at different health care providers are using cloud computing ap- plications such as salesforce.com to im- prove their current sales processes, ef- ficiently manage sales pipelines, and improve customer insight. Applications have been developed to support inde- pendent insurance brokers to effectively market and sell health care products to the end customer.

One of the main areas of concern about cloud computing in the health care mar- ket today is in how to keep the EHR data secure. A custom cloud computing appli- cation can be configured to make sure that the highest levels of security man- dated by the government compliance re- quirements are met. Techniques can be used that only provide publicly available information to the cloud computing ap-

sure: Performed at least one test of certi- fi ed EHR technology’s capacity to submit electronic data to immunization registries.

24. Capability to provide electronic syndro- mic surveillance data to public health agencies and actual transmission accord- ing to applicable law and practice — Mea- sure: Performed at least one test of certi- fi ed EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an eligible provider or eligible hospital sub- mits such information has the capacity to receive the information electronically).

25. Protect electronic health information maintained using certifi ed EHR technolo- gy through the implementation of appro- priate technical capabilities — Measure: Conduct or review a security risk analy- sis in accordance with the requirements under 45 CFR 164.308 (a)(1) and imple- ment security updates as necessary. Exactly how eligible providers will prove

that they have met all the criteria to re- ceive the bonus payments is still somewhat vague. In section 495.8 of the rule entitled “Demonstration of meaningful use crite- ria,” HHS writes, “… [an] EP must demon- strate that he or she satisfi es each of the applicable objectives and associated mea- sures…as follows: (1) For CY 2011, (i) Attest, through a secure mechanism, in a manner specifi ed by CMS (or for a Medicaid EP, in a manner specifi ed by the State), that dur- ing the EHR reporting period, the EP used certifi ed EHR technology, and specify the technology used. (ii) Attest, through a se- cure mechanism, in a manner specifi ed by CMS (or for a Medicaid EP, in a man- ner specifi ed by the State), that during the EHR reporting period, the EP satisfi ed each of the applicable objectives and associated measures under § 495.6 of this part. The EP must specify the EHR reporting period and provide the result of each applicable measure for all patients seen during the EHR reporting period for which a selected measure is applicable.”

Since we do not yet know exactly what HHS may ask for as part of the attestation process, it would be prudent for providers to make sure that they use reporting tools that will allow them to easily drill down to the individual patient data level as they set up their certifi ed EHRs and begin to mean- ingfully use them.

INFORMATION TECHNOLOGY CONTINUED FROM 38

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