When it comes to the transitions of care (TOC) requirement for Stage 2 of meaningful use, providers have had their share of difficulties. In fact, a study published last year in Health Affairs that looked at the adoption of electronic health record (EHR) systems in hospitals since the enactment of the Health Information Technology for Economic and Clinical Health (HITECH) Act found this measure to be a major pain point for healthcare organizations trying to attest to Stage 2. Researchers came to the conclusion that “Functions related to electronic data exchange, both with other providers and with patients (in particular, providing summaries of care during transitions and giving patients the ability to view online, download, and transmit their health information) are critical gaps.”
While the transitions of care objective in Stage 1 is optional, the Stage 2 requirement includes three measures, two of which rely solely on the use of Certified EHR Technology (CEHRT) to electronically transmit summary care records for transitions of care and referrals. Naomi Levinthal, consultant, research and insights at Washington, D.C.-based The Advisory Board Company, is an expert when it comes to meaningful use and care transitions, and was a valued source of information for Healthcare Informatics’ Top Tech Trend on transitions of care. While parts of HCI’s interview with Levinthal were in that trend piece, this interview represents a more comprehensive look at the discussion between Levinthal and HCI’s Associate Editor Rajiv Leventhal on meaningful use and transitions of care.
How are policymakers closing the gaps when it comes to transitions of care?
The best example is around meaningful use, which is where I spend all of my time. You can see where there is a meeting of the two groups, the vendors and the regulators, coming together trying to figure this out from a meaningful use perspective. It’s a toe in the water right now. What’s happening right now with meaningful use, in relation to transitions of care, is that there is an optional requirement in Stage 1, for which a very high percentage of providers and hospitals did not take the government up on.
Now, everyone has to meet three measures in Stage 2 around transitions of care. It’s a rudimentary functionality that you see happening and what’s required for meaningful use, that’s what I mean by toe in the water. What a doctor’s office or hospital has to do is collect information about what happened to a patient and send it off in form of a Consolidated-Clinical Document Architecture (C-CDA) or summary of care record to the next provider of care. How it gets there isn’t a concern to the Centers for Medicare & Medicaid Services (CMS) for one of the measures, but it is for the other two. That’s where we see people struggling, and we have seen some relief from CMS in terms of the flexible reporting options that they have afforded to providers for 2014 if they’ve had a hard time getting their hands on the certified upgrades that everyone needed in order to do meaningful use in 2014.
There are three measures [related to transitions of care in Stage 2]. An example from a hospital perspective is that for all of the patients you see, things happen to them, and then they get discharged. For every one of those discharges, you have to send out a summary of care record whichever way you like for the first measure, and you have to do that for 50 percent of the patients you see. For the second measure, you have to send all those summaries out electronically. But the parameter by which that has to happen have become troublesome. In 2012, when the rule first came out, the options were Direct secure messaging, or you could hop onto eHealth Exchange to send it outbound. But people couldn’t get their hands on the Direct messaging functionality of their systems, and they still have that problem today. Also, the latter option wasn’t even available until pretty recently when CMS made it clear that you could basically use any uncertified mechanism to get that summary record outbound as long as you have sent it out using the Direct messaging that is native to your system that your vendor certified. CMS has since cleared up the ways to get that message outbound. It kind of depended where you were getting that information from as to what your viable options were. Now that has relaxed some in terms of technical considerations.
The third measure is a yes or no. One option is to take an exchange you did to meet measure two, and show that you had the transmission be successful, and it went to someone who was using a different vendor system than your own. Cerner to Epic works, for example, but different versions of Epic would not work. The other option is, if you operate in area of country where there is a closed-loop environment, and most people are on the same system, you can also do a test of an exchange with an Office of the National Coordinator for Health IT (ONC) test EHR system. I have been surprised by the amount of people that have opted for that route. That’s been a good thing.