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Washington Debrief: ONC, CMS Launch “Test EHRs”

January 21, 2014
by Jeff Smith, Director of Public Policy at CHIME
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Jeff Smith, Director of Public Policy at CHIME

ONC Issues Guides to Bolster Safety through Health IT

Key Takeaway: The Office for the National Coordinator for Health IT has released a set of tools to improve safety and quality through health IT. A set of nine “SAFER Guides” enables providers to perform self-assessments and develop customized improvement plans.

Why it Matters: The SAFER Guides were a component of ONC’s Patient Safety Surveillance and Action Plan, signaling the agency’s intent to see the plan become reality. CIOs are encouraged to examine the SAFER Guides and determine the extent of their usefulness. CHIME will play an active role in the Guides’ evolution, with input from member feedback.

ONC released the Safety Assurance Factors for EHR Resilience (SAFER) Guides last week. The guides are a suite of tools that include checklists, worksheets and recommended best practices designed to help healthcare providers assess and optimize the safety and safe use of EHRs. Developed by leading health IT safety and informatics researchers and based on the latest available evidence, expert opinion, stakeholder engagement, and field work, each SAFER Guide addresses a critical area associated with the safe use of EHRs. Topics include:

  • High Priority Practices
  • Organizational Responsibilities
  • Patient Identification
  • Computerized Physician Order Entry (CPOE) with Decision Support
  • Test Results Review and Follow-up
  • Clinician Communication
  • Contingency Planning
  • System Interfaces
  • System Configuration

ONC believes the release of the SAFER Guides mark an important milestone in the implementation of their Health IT Patient Safety Action and Surveillance Plan. In their July 2013 plan, ONC said the SAFER Guides would “provide a foundation from which to develop additional evidence-based tools and interventions as knowledge of health IT safety continues to improve.” The SAFER Guides also are intended to meet several recommendations made by the Institute of Medicine (IOM) in their 2011 report.

CMS, ONC Announce ‘Test EHR’ Up and Running

Key Takeaway: Providers who opt to use a “test EHR” to fulfill transition of care requirements may now do so.

Why it Matters: Eligible professionals and eligible hospitals must send a Consolidated Clinical Document Architecture (CCDA) care summary record to a provider using a different system to meet the third transition of care requirement. Now, EPs and EHs have the option of sending a CCDA care summary record to the Test EHR.

In an announcement made recently, ONC and CMS have launched “Test EHRs” for providers to fulfill transition of care requirements under Meaningful Use. Under Stage 2 of Meaningful Use transition of care objective measure No. 3, EPs (click here) and EHs (click here) must either:

  1. Conduct one or more successful electronic exchanges of a summary of care document, with a recipient who has EHR technology designed by a different EHR technology developer than the sender's; or
  2. Conduct one or more successful tests with the CMS designated test EHR during the EHR reporting period.

According to an ONC FAQ, “All authorized Test EHRs will be installed and running locally at the respective vendor sites and registered on the ‘EHR Randomizer’ tool hosted at NIST. Providers will enter information about their current EHR in the Randomizer to obtain a randomly selected Test EHR that is different from their own EHR technology. The provider will establish trust with the Test EHR and send a direct message that includes a test CCDA care summary record (no live data is to be sent, only test data) to the test EHR’s designated address. After the test EHR successfully receives a direct message they will be required to send notification to the provider indicating that the direct message was successfully received. This notification may be in the form of an email to the provider. The provider will be able to use the notification as proof of meeting measure No. 3 for the purpose of Meaningful Use attestation.”

So far, only McKesson and Meditech are participating.

Bipartisan Bill Looks to Redesign ACOs, Focus on Chronic Care

Key Takeaway: Bipartisan and bicameral legislators introduced a bill last week meant to enable ACO-like providers to target chronically ill beneficiaries with the aim of preventing, delaying and minimizing the progression of disease and disability.

Why it Matters: This bill signals a new policy direction for care delivery, one that Sen. Ron Wyden is expected to pursue when he becomes chair of the Senate Finance Committee. Wyden’s deep understanding of health IT-related issues will likely become apparent as he ascends the chairmanship.

Sens. Ron Wyden (D-Ore.) and Johnny Isakson (R-Ga.) joined Reps. Erik Paulsen (R-Minn.) and Peter Welch (D-Vt.) in introducing the Better Care, Lower Cost Act. Lawmakers said the bill builds on the design of ACOs in Medicare, but said it would remove federal rules and barriers preventing providers from specializing in chronic care. For example, the new “Better Care Program,” or BPC:

  • Gives providers one payment for each patient;
  • Allows for targeted enrollment of beneficiaries; and
  • Lowers out-of-pocket costs for seniors who sign up with participating BCP providers.

Additionally, Wyden said the proposal uses telemedicine and knowledge networks to increase access in rural areas and includes vital case management services proven to increase medical compliance. The senators believe that focusing on chronic care will pay dividends beyond what ACOs can do. According to CMS, 68 percent of Medicare enrollees had two or more chronic conditions in 2010 and accounted for 93 percent of Medicare spending – roughly $487 billion – and this same group comprised 98 percent of hospital readmissions.

CHIME Public Policy Issues Stark, Anti-kickback ‘Cheat Sheet’

Key Takeaway: CHIME Public Policy has issued “CIO Cheat Sheet: Stark and Anti-Kickback EHR Donation Provisions” in response to final rules published late last year. CIOs should review to make sure they understand new changes made by CMS and OIG.

Why it Matters: Final rules extended donation provision to 2021, but they did not specify what technology meets the requirements for exception / safe harbor. Instead, regulators pose a two-factor question that must be answered affirmatively to qualify.

Click here to read about the rules’ major provisions; to learn what health IT may be covered and to understand what questions may still be unresolved.

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