Meaningful Use Updates

Meaningful Use Updates blog provides insight into the requirements that hospitals and eligible providers must meet to achieve Meaningful Use.

speaker-rbowenRita Bowen, MA, RHIA, CHPS, SSGB is a distinguished professional with over 20 years of experience in the health information management industry. She serves as the Sr. Vice President of HIM and Privacy Officer of HealthPort where she is responsible for acting as an internal customer advocate. Most recently, Ms. Bowen served as the Enterprise Director of HIM Services for Erlanger Health System for 13 years, where she received commendation from the hospital county authority for outstanding leadership. Ms. Bowen is the recipient of Mentor FORE Triumph Award and Distinguished Member of AHIMA’s Quality Management Section. She has served as the AHIMA President and Board Chair in 2010, a member of AHIMA’s Board of Directors (2006-2011), the Council on Certification (2003-2005) and various task groups including CHP exam and AHIMA’s liaison to HIMSS for the CHS exam construction (2002).  

Ms. Bowen is an established speaker on diverse HIM topics and an active author on privacy and legal health records. She served on the CCHIT security and reliability workgroup and as Chair of Regional Committees East-Tennessee HIMSS and co-chair of Tennessee’s e-HIM group. She is an adjunct faculty member of the Chattanooga State HIM program and UT Memphis HIM Master’s program. She also serves on the advisory board for Care Communications based in Chicago, Illinois.

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  • Proposed Stage 3 MU Rules Focus on Interoperability

    May 29, 2015

    Healthcare organizations at all levels face significant pressure to achieve interoperability as a means of reducing costs while improving quality of outcomes. To that end, the HHS, CMS and Office of the ONC recently released the proposed Meaningful Use Stage 3 rules [J1] to promote nationwide interoperability. The rules target three core areas of improvement—provider payment, care delivery and information sharing.

    One of the most notable updates is the 2015 Edition Health IT Certification Criteria rule regarding the secure, efficient and effective sharing and use of health information to support care improvement, cost reduction and patient safety. ONC’s “path to interoperability” is detailed in their Shared Nationwide Interoperability Roadmap[J2] .

    According to Karen DeSalvo[J3] , M.D., M.P.H, M.Sc., national coordinator for health IT, ONC’s proposed rule will be critical to achieving nationwide interoperability “through provisions that consider the range of health IT users and uses across the care continuum, including those focused on interoperable standards, data portability, improved transparency, privacy and security capabilities, and increased oversight through ONC’s Health IT Certification Program.”

    Aligned with the push for interoperability, HFMA published an article “Making Interoperability a Reality in Healthcare”[J4]  (May 2015) featuring commentary from healthcare professionals on the challenges, risks, rewards and strategies. As a contributor, I had an opportunity to weigh in from several angles, including HIM, IT and financial perspectives. Here are ten key takeaways:

    • Financial incentives make interoperability a priority.
    • Senior sponsorship is essential, filtering down to clinical staff, administration, patients, community.
    • Making the business case gets the attention of top leaders.
    • Incremental change is the most sensible approach.
    • Interoperability initiatives start with information governance.
    • Collaboration among stakeholders drives success.
    • Interoperability requires investment in culture change.
    • Good security is a nonnegotiable requirement.
    • Strategic value—“Big Data” can have a transformational impact on health outcomes.
    • Health systems that succeed with interoperability and analytics initiatives outperform their peers.

    Various stakeholders may have opposing views on how to handle information-sharing challenges. And senior executives must take a leadership role. Making interoperability a priority is the first step—making it a reality is where the work begins. Take a close look at AHIMA’s principles [J5] for information governance, see where you stand, and then design a path to achieve the real goal of interoperability—sharing information to improve the cost and quality of care.

  • Preparation for Meaningful Use Audits Pays Off

    May 05, 2015

    The best way to prepare for an onslaught of CMS EHR incentive audits is to conduct a mock audit for eligible hospital (EH) and eligible professional (EP) 2014 attestations. Hospitals that fail to take this approach are at greater risk of having their CMS EHR incentives recouped.

    One hospital recently hit by 33 separate audits realized the value of a pre-planned response process to ensure:

    ♣    Efficient access to items requested by the auditor
    ♣    Prompt delivery of documents to the auditor (portal upload or other format)
    ♣    Proof of meeting public health measures

    A critical part of preparation is creating what MU experts call a “book of evidence” in advance of an audit.

    Click here to learn more about the latest trend in MU audits and how your hospital can be prepared.

  • Information Governance Principles for Healthcare (IGPHC)™

    Nov 06, 2014

    And Other Takeaways from AHIMA 2014

    San Diego was predictably warm, sunny and serene last month as HIM professionals from across all fifty states and several territories attended the 86th AHIMA Convention and Exhibit. With Meaningful Use Stage 2 and ICD-10 delayed, attendees focused on a new horizon for HIM—information governance.

    Information governance is the planning, collecting, monitoring and enforcement of patient data assets. It mandates when to take action with patient information, under what circumstances to act, and which methods to use.

    Information governance is similar to HIM’s ownership of medical record completeness, integrity, privacy and security in a paper world. It’s based on the same driving principles that HIM professionals have always upheld—but in electronic environments.

    Industry’s First Guidelines Released

    During the convention, AHIMA released the industry’s first principles for governing information in healthcare. They are available on the association’s web page for information governance.

    The principles include eight focus areas: accountability, transparency, integrity, protection, compliance, availability, retention and disposition of health information. Look for more information in this blog and on my ADVANCE Privacy Points web column about the IGPHC.

    Regulatory compliance, privacy, the chase for MU, and general HIM operational improvements were also top of mind in San Diego.

    Strong Business Partnerships Support HIM Success

    For Ikae Barnett, RHIA, the liaison between HIM/Legal/Risk/Compliance at MD Anderson Cancer Center, AHIMA’s 86th Convention solidified her strategy: build strong business partnerships to support day-to-day HIM operations.

    According to Barnett, during a video interview with Health IT Outcomes, “healthcare laws change continuously every day—having an outside partner responsible for our release of information means we don’t have to read up on everything every day, we can rely on them.” Barnett also cites specific instances of how her partners have helped MD Anderson educate staff, meet patient needs and comply with auditor requests.  

    Onward and Upward for HIM
    From MPI cleanup to clinical coding and information governance, the trend toward relying on business partners was reiterated by many in attendance at the 2014 convention.

    The reality? HIM directors are being pulled into all types of technology projects and leadership roles such as patient portals, privacy and security, and information governance. However, day-to-day operations must go on.

    The solution! Partner with expert HIM firms to manage operations while you—the HIM leader—focus on new, strategic information initiatives. Onward and upward!

  • Patients and MU: The Right Information Access Means Everything

    Aug 19, 2013

    Under Meaningful Use (MU) Stage 2, eligible providers (EPs) and hospitals are set to lose incentive dollars if patients can’t electronically view, download and transmit records. Access must be through a secure channel that encrypts and protects the content. Furthermore, the patient’s information must be available within four business days for EPs and within 36 hours of discharge in hospital settings. Fifty percent of patients must have access with 5% actually viewing, downloading or transmitting to meet the Stage 2 measure.

    According to a 2012 KLAS survey, 57% of providers interviewed already have a portal in place through their EHR or a third-party vendor. But not all portals are created equal. Many portals exist solely for appointment scheduling, medication refills and lab results viewing. Defining your portal strategy and having the right amount of patient access means everything under MU Stage 2.

    Patient portals are usually the domain of EHR companies. However, most will need modular plug-in software and HIM expertise to ensure patient utilization and MU Stage 2 compliance. Simply building a patient portal doesn’t ensure patients will use them. And beyond MU Stage 2, state-by-state requirements for patient information access must also be met.

    Sheila Green-Shook, Director of HIM and Privacy Officer at Evergreen Health in Kirkland, Washington, has worked with both Cerner and Epic patient portals. I met with her at HealthPort’s HIM Educational Summit. She confirms that “some portals are excellent for patient access to records and others are not,” and adds, “EHR portals are only as robust as the physicians documenting within them.”

    The wide-spread adoption of patient portals already has a positive effect on healthcare. HealthPort looks forward to being an active participant on the journey.              
  • Meaningful Use Stage 2 and ROI: A Look Ahead for HIM

    Aug 16, 2013
    At the end of June 2013, CMS had cumulatively paid out $15.5 billion in EHR incentive payments to eligible professionals (EPs) and hospitals according their June 2013 EHR Incentive Program report. More than half of all doctors and other eligible providers have now received Medicare or Medicaid incentive payments for Stage I Meaningful Use (MU) of their EHRs according to HHS’s Secretary Kathleen Sebelius.  In only two short years, the EHR incentive program has driven technology adoption and successfully bolstered bottom lines.  Now with Stage 1 behind us, it’s time to focus on MU Stage 2.

    The next stage of EHR adoption focuses on information sharing and patient access to medical records. Stage 2 is where HIM expertise shines. Alongside ICD-10 demands, HIM professionals must get fully on board and involved with MU. One of the first steps for HIM is to understand which technology modules within their departments are players in the Stage 2 game. 

    Modules or component technologies within an EHR are MU-certifiable as pre-coordinated, integrated bundles of software. These include such applications as patient portals, electronic document management systems and release-of-information software. For example, HealthPort’s eSmartLog is a certified EHR module for meaningful use. 

    MU Stage 2 changes the game for HIM’s processing of record requests. It pushes electronic, online patient access to records primarily through patient portal technology. Some EHR portals are well-suited for this function, however, others are not. Furthermore, portals are only as robust as the physician documentation included within them. 

    At this point in the MU journey, EPs and hospitals must still possess some type of secure, protected vehicle to deliver complete sets of PHI to requestors—or to transmit information above and beyond that included within their patient portals. HIM professionals and ROI companies must work together to address Stage 2 MU goals. And as they do, new roles and responsibilities will certainly emerge for both. 
  • HealthPort named one of the top vendors for Meaningful Use attestations

    Apr 01, 2013

    HealthPort was mention in Modern Healthcare's recent analysis identifying the top vendors for Meaningful Use Attestations.

    Click here to read the article.

  • Featured guest on MU Live, an internet talk radio show

    Jun 01, 2012
    On Tuesday, June 5th at 2 p.m. EST, I will be a guest speaker on MU Live, a weekly 30 minute internet talk radio show hosted by HITECH Answers that focuses on  Meaningful Use and Health IT. 

    Click here
    to participate and listen in as I discuss the role of patient portals in Stage 2 meaningful use.              
  • How Stage 2 Affects Record Release

    Mar 28, 2012

    The Meaningful Use Stage 2 Notice of Proposed Rule Making is out, and it will bring sweeping changes to how hospitals and eligible professionals release records and other information to patients. 

    Click here to check out my article “How Stage 2 Affects Record Release” in the April 2012 Issue of Health Management Technology where I explain how the proposed Stage 2 criteria changes will drive organizations to implement a patient portal or personal health record application.

  • Meaningful Use Stage 2 – Patient Access – Data Requirements

    Mar 21, 2012

    As we mentioned in an earlier blog post, the proposed Stage 2 requirements replace the release of information (ROI) related item for patient “electronic copy of health information” with a new online access requirement.  In that post, we promised to list the data elements which must be available through a portal or PHR in order to satisfy Meaningful Use.

    The below lists are different for Eligible Professionals (EPs) vs. Hospitals


    • Patient name
    • Provider's name and office contact information
    • Problem list
    • Procedures
    • Laboratory test results
    • Medication list
    • Medication allergy list
    • Vital signs (height, weight, blood pressure, BMI, growth charts)
    • Smoking status
    • Demographic information (preferred language, gender, race, ethnicity, date of birth)
    • Care plan field, including goals and instructions, and
    • Any additional known care team members beyond the referring or transitioning provider and the receiving provider



    • Admit and discharge date and location
    • Reason for hospitalization
    • Providers of care during hospitalization
    • Problem list maintained by the hospital on the patientRelevant past diagnoses known by the hospital
    • Medication list maintained by the hospital on the patient (both current admission and historical)
    • Medication allergy list maintained by the hospital on the patient (both current admission and historical)
    • Vital signs at discharge
    • Laboratory test results (available at time of discharge)
    • Care transition summary and plan for next provider of care (for transitions other than home)
    • Discharge instructions for patient, and
    • Demographics maintained by hospital (gender, race, ethnicity, date of birth, preferred language, smoking status)


    NOTE:  Providers still hold full rights to withhold information if they judge (strictly a la HIPAA) that the information is better communicated another way or not at all.  CMS does not believe there is a legitimate case for withholding ALL information from an encounter with a patient – just parts.

    What effect will this have on HIM?
    HealthPort believes that meeting this MU requirement may eliminate some patient requests for medical records, particularly if lab results are the focus, but that some patient requests would continue to arrive in the HIM department for a more complete release. This will all depend on patient awareness of the online option, and on how much of the record the facility makes available on-line beyond these minimum requirements.

    If you want to look these up in the rule:

    1.  Click here to access the pdf version of the rule
    2.  The new proposed objective for “Access” starts on page 91 for EPs, page 144 for hospitals.
    3.  The list of required record data for online access starts on page 97 for EPs, page 145 for hospitals.
    4.  If you prefer the table form for reviewing the requirements, that starts on page 156.
    5.  And the actual rule verbiage (not the comments and table mentioned above) is on page 406 for EPs, page 414 for hospitals.

    In my next post, I’ll explore the encryption aspects of Stage 2.  Stay tuned...

  • Meaningful Use Stage 2 Would Replace ROI Requirements With Online Access

    Feb 27, 2012
    On February 23rd, CMS released the Meaningful Use Stage 2 Notice of Proposed Rule Making which will make sweeping changes to the release of information (ROI) requirements after January 1, 2014 for ALL Eligible Professionals, and after October 1, 2013 for ALL Hospitals. In addition, the changes will apply for facilities still at Stage 1 for 2014.

    What is CMS Proposing?

    Drop the requirements in the 2014 reporting period for:
    1.       Patient electronic copies of medical records within three business days
    2.       Electronic copies of discharge instructions at time of discharge
    3.       The “menu” requirement for “Timely Access” on the Eligible Provider list

    And replace all three of these with a core requirement of patient online access.

    Eligible Professional (EP) Objective: Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP.

    EP Measures: (Note: You must pass TWO measures for this objective)
    1.       More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information subject to the EP's discretion to withhold certain information.
    2.       More than 10 percent of all unique patients seen by the EP during the EHR reporting period (or their authorized representatives) view, download or transmit to a third party their health information.

    Hospital Objective: Provide patients the ability to view online, download and transmit information about a hospital admission.

    Hospital Measure: (Note: You must pass TWO measures for this objective):
    1.       More than 50 percent of all patients who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH have their information available online within 36 hours of discharge.
    2.       More than 10 percent of all patients who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH view, download or transmit to a third party their information during the EHR reporting period.

    The following will probably receive comment: The “unique patient” item in the EP Measure. For example, if a patient sees the provider three times in the reporting period, and in two of the instances the data is available within 4 business days, but in the third instance the data wasn’t available for the patient until six business days had elapsed, do you count the patient or not? The “within 36 hours of discharge” item in the hospital measure.

    BOTTOM LINE - These changes will drive every facility to own or outsource a patient portal or PHR and to connect their EHR system to the portal so records are automatically available. Will this reduce patient HIM department requests for medical records?  Depends on two things:
    1.       How well the facility advertises the portal, and gets patients to use it (instead of requesting copies of records in the traditional ways).  The requirement that 10 percent of patients actually access their records means that providers must actively persuade patients to go to the portal.
    2.       How much information is actually available on the portal, and in what  format.  CMS did specify a minimum set of data that must be available – and it’s not the entire record (watch for a later blog post on this).  So patients will likely still request their records in traditional ways, depending on the patient’s reason for the request, and the health information they need.

    Read the rule for yourself and utilize the tips below to speed you on your way:
    1.       The pdf version of the rule (pre Federal Register) can be found by clicking here.
    2.       The new proposed objective for “Access” starts on page 91 for EPs or page 144 for hospitals.
    3.       The list of required record data for online access (if you want to get ahead of our next blog post) starts on page 97 for EPs or page 145 for hospitals.
    4.       If you prefer the table form for reviewing the requirements, that starts on page 156.
    5.       And the actual rule verbiage (not the comments and table mentioned above) is on page 406 for EPs or page 414 for hospitals.

  • Meaningful Use and Patient Access to Record: Understanding the Fine Print

    Dec 09, 2011
    This month I authored an article in Becker’s Hospital Review titled, “Meaningful Use and Patient Access to Record: Understanding the Fine Print.”  In the article, I explore the five stage-one MU criteria focused on patient access to information and how patients directly benefit from HITECH's meaningful use incentive program. 


    Click here to read the article in its entirety.

  • Certification Versus Meaningful Use

    Oct 25, 2011
    Just because your EHR was CERTIFIED to do it doesn’t mean you HAVE to do it for Meaningful Use.

    CMS and ONC (the Office of the National Coordinator for Health IT) were the authors of the Meaningful Use rule and the EHR Certification Rule, respectively. The clearly stated intention of the certification rule is to give providers and facilities a way to know that basic capabilities exist in their EHR system. Those capabilities must then be used and tracked to prove Meaningful Use, but CMS explicitly described some differences in the MU rule, usually in the name of “flexibility.”

    For instance, Certified EHR systems must provide a way for users to encrypt files containing PHI. On the other hand, however, the Meaningful Use rule clearly states that it will not mandate when or how the facility should use this encryption capability, if at all. The rule does note that HIPAA and HITECH already provide guidance on privacy and security. The long and short of this is that as facilities create electronic copies of medical records for patients, they are at liberty to decide when and how to encrypt, or even to decide not to encrypt at all. This means they can use the encryption tools within the Certified EHR, or other tools. At HealthPort, we feel strongly that electronic copies should all be encrypted, as the hard-drives of all HealthPort PCs are encrypted, so that maximum protection can be ensured no matter where that electronic copy may travel. And we work with our partners to create an encryption password process that works for the facility and for the patients.

    In another example, Certified EHR systems must be able to produce a CCD or CCR (“Continuity of Care Document” or “Continuity of Care Record”) - two national standards for electronic layouts of medical data – in xml format and a human readable version.  However, to meet Meaningful Use for patient electronic copies of medical records, only the human readable version must be provided to the patient. CMS understands that the most common use of the patient copy will be for humans to view and read it, not machines, and so at this point, CCD or CCR is not required for patient copies.

    Nearly every facility HealthPort has spoken to about this is planning to deliver just the human readable version.  Many have said they would not pass CCD or CCR versions to patients because they believe it will only lead to questions and it may also lead to debates about payment for the CCD/CCR portion of the copy.  CCD and CCR were designed for system-to-system exchange of medical record data, and the patient copy is not seen, yet, as part of that type of transfer.

    As your facility is working through the other MU requirements, it’s important to know the difference between what was certified and what is required for MU. Many MU requirements do mandate that the exact certified process or format be used in order to qualify, but some do not. Wherever possible, the rule makers wanted to allow room for facilities and vendors to innovate, and many of those breathing spaces show up as differences between the certification and the MU requirements.

    A terrific resource for learning about these breathing spaces, and CMS interpretation of the rule, is the CMS EHR Incentive Programs website – particularly the FAQ page. Click here and look for the Frequently Asked Questions link on the lower left side of the EHR Incentive Programs site.

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