Tuesday, February 7, 2012

Attesting to Meaningful Use Quality Measures

I was recently asked how eligible professionals should report the Meaningful Use Clinical Quality Measures if there are zero denominators (i.e. you do not have any hypertensives, adults, or patients with 2 or more visits in the measurement period)

Here's the answer as I understand the regulations and FAQs:

1.  Report on the 3 Core measures if you can, which include
*Hypertension: Blood Pressure Measurement
*Tobacco Use Assessment and Tobacco Cessation Intervention
*Adult Weight Screening and Follow-up

2.  If any of the 3 Core measures has a zero denominator, replace them one-for-one with one of the 3 alternate core measures.   If you can’t get to 3 non-zero denominators between the core and alternate core, report on all 6 (even if it means that you have to report 6 zero denominators)
*Weight Assessment and Counseling for Children and Adolescents
*Preventive Care and Screening: Influenza Immunization for Patients ≥ 50 Years Old
*Childhood Immunization Status

3.  Regardless of the above, you MUST report on 3 of the remaining 38 Additional Set measures.  If you are reporting any zero denominators from these Additional Set measures, you must attest that you have no other non-zero denominator measures.  Essentially, you have to confirm that you’re not running away from non-zero denominator measures.

In summary, the minimal requirement is for 6 measures (3 core or alternate core, 3 additional set).  You may have to report up to 9 measures if there are zero denominators involved.  If you can’t find 3 non-zero denominators among the core and alternate core, you have to report on all 6 (even if it means that you’re reporting 6 zero denominators).  In addition, you still have to report on 3 from the remaining 38 additional set measures.  If any of these 3 additional set measures is a zero denominator, you must confirm that you don’t have a non-zero denominator for any of the remaining 35 that you’re not reporting on.
 
Micky Tripathi posted a blog about this last summer that provides additional detail.

You'll find the FAQs that address the Clinical Quality Measures here.

Monday, February 6, 2012

The Perfect Storm for Innovation

In my career, there have been a few perfect storms, defined as "a confluence, resulting in an event of unusual magnitude".

When I was an undergraduate at Stanford University in 1980, two geeky guys named Jobs and Wozniak dropped by the Homebrew Computer Club to demonstrate a kit designed in their garage.   IBM introduced the Personal Computer and MSDOS 1.0.   I purchased an early copy of Microsoft Basic and began creating software in my dorm room including early versions of tax calculation software, an econometric modeling language, and electronic data interchange tools.   Every day brought a new opportunity. The energies of hundreds of entrepreneurs created an industry in a few intensely creative months that laid the foundation for the architecture and tools still in use today.   A guy named Gates offered me a job and I decided to stay in school instead.

In 2001 when I was first hired at Harvard, a visionary Dean for Medical Education, a supportive Dean of the Medical School,  talented new development staff, and a sleepless MD/Phd student came together to create one of the first Learning Management Systems in the country, Mycourses.   Robust web technologies, voice recognition, search engines, early mobile devices, and new multi-media streaming standards coincided with resources, strong governance, and a sense of urgency.  Magic happened and in a matter of months, an entire platform was created that is still powering the medical school today.

At BIDMC in 2010, IS Clinical Systems staff and key operational leaders realized that Meaningful Use Stage 1 was within reach if we temporarily put aside other work and focused our energy, creativity, and enthusiasm on rapid innovation, process change, and education.   In a few weeks we became the first hospital in the country to certify our EHR applications - inpatient and ambulatory.    We became the first hospital to achieve Meaningful Use.  More than 70% of our eligible professionals have surpassed meaningful use performance thresholds.   We had no budget, no dedicated resources, and nothing but strength of will to make it happen.   It was one of our finest hours.

In 2011, the Massachusetts public sector (Secretary of EOHHS, CIO of EOHHS), private sector healthcare leaders, and healthcare IT experts had a bold idea - create a public utility that links together all the existing regional health information exchanges, public health, small clinician offices, payers, and patients using modular components procured and initially operated by state government.   We aligned forces and in a few weeks created budgets, project plans, a new State Medicaid Health Plan, and a guiding coalition of stakeholders.    Political, organizational, and technical barriers were broken down and unbridled optimism rekindled our health information exchange momentum.    2012 will be a transformative year in the Commonwealth, truly a perfect storm.

My advice - look for the perfect storms in your own life.  Minimize your distractions, cancel unnecessary meetings, and put aside those tasks that don't add value.   Take a risk and dive head first into the possibility of creating greatness.   I've seen opportunity come and go in my life.   No one remembers the mundane.  No one forgets the events of unusual magnitude.

Recently, I updated my BIDMC job description to include fostering healthcare information exchange among affiliates, accountable care organizations, and the community.   The Massachusetts Health Information Exchange is the next perfect storm in my career and I will devote all of my energies to the confluence being created by EOHHS CIO Manu Tandon, Massachusetts eHealth Collaborative CEO Micky Tripathi, and the dozens of volunteers lending the wisdom to the process.

Friday, February 3, 2012

Cool Technology of the Week

I recently wrote about the explosion of business spam.

One of my blog commenters introduced me to Unsubscribe.com which provides a free, timesaving, easy to use unsubscribe utility.

Numerous times a day, I click on an email scroll to the unsubscribe area, have to figure out the proprietary unsubscribe functionality of the business spammer, retype my email address, and hope it works since unsubscribe sites are generally slow and unreliable.

With Unsubscribe.com, I just download a plug in for my email client (apple mail), and simply click on the unsubscribe icon whenever unwanted email appears in my inbox.   The unsubscribe servers use natural language processing to figure out the unsubscribe methodology and send the unsubscribe request.

It has easily saved me 15 minutes a day.

Of course the ultimate answer would be for advertisers to act more ethically.   I had a great conversation with Dave Smith, Compliance Officer for Constant Contact about their efforts to enforce email advertising best practices.    A few items

1.  They ask their clients to certify pre-existing business relationships or opt-in before sending email.   Some clients do not follow this policy guidance the Constant Contact compliance team does their best to identify and stop abuses by their customers.

2.  They created "Safe Unsubscribe" to make it easier for recipients to remove themselves from mailing lists.   It really works - Safe Unsubscribe does actually stop the flow of advertising.

3.  They will honor a  global "do not call" designation for all email newsletters if such a request is made to the compliance department.

My wife uses Constant Contact for her NKG Art Gallery Newsletter, so I'm not opting out of all communications just yet.   Only a small portion of my business spam comes from advertisers using Constant Contact - a tribute to their ethical marketing compliance efforts.

A utility to automatically unsubscribe and a company using a compliance team to reduce unwanted email.    That's cool!

Thursday, February 2, 2012

Our Cancer Journey - Week 7

Tomorrow we begin the third cycle of Cytoxan/Adriamycin.   In the journey thus far, Kathy has had good days and bad days.   High energy and low energy days.    Meal days and BRAT (Bananas, Rice, Apples, Toast) days.    We frequently discuss the factors that put Kathy at risk for cancer at this point in her life.   We talk a lot about the future.

Kathy's typical pattern is

Friday - Chemotherapy infusion day, good energy, good appetite, some jitters from the steroids
Saturday - Good energy, good appetite, some jitters from the steroids
Sunday - Waning energy, moderate appetite, bone pain
Monday - No energy, moderate appetite, extra sleep needed, bone pain, bland diet
Tuesday - Low energy, extra sleep needed, bone pain, bland diet
Wednesday - Low energy, bland diet, extra rest needed
Thursday - Moderate energy, bland diet
Friday - Moderate energy, stomach pain, bland diet
Saturday - Moderate energy, stomach pain, bland diet
Sunday - Moderate energy, stomach pain, bland diet
Monday - Good energy, moderate appetite
Tuesday - Good energy, good appetite
Wednesday - Good energy, good appetite
Thursday  - Good energy, good appetite

What environmental risks caused the cancer at this point in her life?  Exposure to the cadmium and other heavy metal pigments in her traditional oil paints? Pesticides in the environment? Bisphenol in cans? Free radicals?

We've talked about psychoneuroimmunology, the impact of mood and outlook on the ability to combat disease.

The past two years have been challenging for Kathy - helping our daughter grow from high school to college, transitioning to an empty nest, creating an art gallery business in a challenging economy, sharing the stresses of my Federal/State/local work (especially Meaningful Use for several hospitals and 2000 doctors), and supporting the health needs of our parents.

Although they past few years have been stressful, all the events are consistent with our expectation for this stage of life.

One event in the past year was a bit out of the ordinary.  A 19 year old with a very poor driving record (4 points on his license, 1 high speed collision, 1 hit and run etc.) drove down the wrong side of the road around a line of traffic and hit Kathy's car as she was exiting a parking lot.   It was very clear from the position of the impact that it was caused by a driver violating the law.

Kathy filed an insurance claim and provided all the details of the accident.

The 19 year old driver lied about what happened.

Our insurance company decided Kathy was at fault, gave her a point on her driving record, and added a multi-year surcharge to her insurance.

When Kathy pursued the issue, noting that the 19 year old with the poor driving record was lying, the insurance company told her that without a photograph of the accident or an independent witness who was willing to verify the events, they would have to believe the 19 year old because Kathy was exiting a parking lot and that makes her at least 51% responsible.  Despite Kathy's over 30 year good driving record, the insurance company representative literally ended the conversation with the statement "Life isn't fair".

That episode temporarily caused Kathy to lose her faith in humanity and gave her a sense of helplessness in a hostile world.

As with any conflict or issue, for everything there is a process.

Kathy appealed the ruling to the Massachusetts Board of Insurance and wrote an eloquent letter stating the facts.

Today the Board of Insurance ruled she was not at fault, rescinded the point on her license, and demanded that the insurance company refund/rescind the surcharge.  She cried when she opened the letter. The nice guy can still finish first.

This weekend we'll continue our search for local farmland by touring Harvard, Massachusetts with locals recommended by our next door neighbor.  The cancer diagnosis constrains our possibilities but has not dulled our enthusiasm for a long and fulfilling future.

Wednesday, February 1, 2012

Provider Directories and Public Key Infrastructure for HIE

As Massachusetts prepares a Request for Response (RFR)  to procure healthcare information exchange infrastructure and applications,  many stakeholders have been hard at work documenting requirements.

The Provider Directory and Public Key infrastructure are some of the hardest specifications to write since they have not yet been widely deployed for healthcare information exchange anywhere in the country.

The leaders of the Massachusetts HIE effort have held 3 major vendor and user forums over the past month and have been told that no vendor has a standards-based provider directory in production at any customer site.

Here's our best thinking about Provider Directory and Public Key infrastructure services.

Provider Directory
The Directory will have a schema within a relational database that enables lookup of entities, which could include a person (John Halamka),  an organization (BIDMC), a department (The BIDMC Department of Emergency Medicine), a state entity (Massachusetts Department of Public Health),   a payer (Blue Cross Blue Shield of Massachusetts), a vendor (The Massachusetts eHealth Collaborative Quality Data Center), or a PHR infrastructure trusted by the HIE (Microsoft Healthvault).     There will be two ways to query this database - Lightweight Directory Access Protocol (LDAP) for  use within the Massachusetts state government firewall and SOAP-based web service APIs for all users external to the firewall.   The response to a query will include the node name for communication to the entity i.e. John Halamka will not have a node, but the BIDMC Department of Emergency Medicine or BIDMC could.   Digital certificates are not stored in the Provider Directory.

Public Key Infrastructure
Certificates will be issued by a single Certificate Authority and will be stored in one of many Domain Naming System (DNS) services capable of supporting certificate queries such as BIND or Microsoft's special implementation of DNS created for the Direct Project (http://directproject.org/).    For example, BIDMC could offer a DNS service called Direct.bidmc.org which hosts the public keys for all our nodes.

Here's how it would be used.  An EHR would look up an entity in the Provider Directory and then use DNS services to retrieve the certificate for the entity's node.

We're also considering an alternative approach using the open source tools available in the Direct Project's Reference Implementation.   These tools include administrative tools to store and manage certificates and an adapter that links the directory store to a DNS responder.    Participants could upload their certificates to this centralized data store.  For example:

DNS Responder <--DNS Web Services--> Direct Reference Implementation Web Services <--BIDMC adaptor--> BIDMC datastore

The vendor community has told us that they want a single simple directory and public key infrastructure specification they can implement one time for an entire state.   We'll give that to them and I'll write about their responses in future posts.

Tuesday, January 31, 2012

Radiology Image Exchange

In my recent blog about the Standards Work Ahead in 2012, I called DICOM a non-standard standard.

This generated numerous email messages, phone calls, and blog comments.

Let me clarify what I meant.

DICOM is a great standard that has unified many processes within organizations, linking radiology modalities and PACS systems.

Why do I believe additional work is needed?

In December, my wife visited a hospital near our home for a diagnostic mammogram. It was clear she needed followup care with a cancer care team. We decided that Beth Israel Deaconess would be ideal because of its electronic health records and personal health records that would help Kathy coordinate her care. We asked for the images to be transmitted to BIDMC and we were told that we needed to visit the radiology department Monday-Friday 9am-5pm for a CD to be created so that Kathy could drive is 20 miles to BIDMC. The CD contained a proprietary viewer that required Windows and hence was not visible on our home computers (all Mac OSX).

What would have happened in an ideal world?

1. An implementation guide for DICOM would specify required vendor neutral content - a basic set of metadata (patient identifiers, name of the radiology study, imaging techniques used etc.) that would work with any viewer - Siemens, Agfa, Philips, GE, Kodak, etc. Any vendor specific/proprietary metadata would be stored separately from the required basic content, so that extensions do not impact generic viewers. CDs with proprietary viewers and media formats should become a thing of the past.

2. DICOM combines content and transport in a single standard. Although that is create for communication within an organization, it is not sufficient for a healthcare information exchange world that uses the Direct implementation guide (SMTP/SMIME, XDR) for content exchange among organizations. The fact that vendors such as LifeImage, Accelarad, and Merge Healthcare have created their own image sharing networks suggests that more standards work is needed to create an open ecosystem of image sharing among organizations.

3. We should not require organizations who want to receive images to have PACS systems. Instead, EHRs with vendor neutral DICOM viewers should be able to incorporate DICOM content sent via Direct into patient records.

Thus our work on imaging standards should build upon the DICOM foundation we have today, but eliminate optionality for a basic set of metadata, ensure that any proprietary extensions to metadata do not interfere with vendor-neutral viewing, embrace simple transport approaches for cross organizational exchange, and enable even the simplest of EHRs to be participants in image exchange.

We'll do this work in the Healthcare IT Standards Committee from April to June, engaging the industry experts who have worked so hard on DICOM to date.

I hope that makes sense!

Monday, January 30, 2012

Update on the BIDMC ICD10 Project

I've written extensively about the challenge of implementing ICD10 and my belief that the billions of dollars required to implement it will not improve quality, safety, or efficiency.

I've spoken to many people at HHS, CMS and the White House about the need to rethink the ICD10 timeline, deferring it until after Meaningful Use Stage 3  which enables us to focus on improving our clinical documentation and adopt  SNOMED-CT  to capture structured signs and symptoms.

However, I've been told that the Affordable Care Act (ACA) includes cost savings from reduction in healthcare costs/fraud/abuse that require the implementation of ICD10.  Thus, it's not likely going to be delayed.

At Beth Israel Deaconess, we're moving forward, assuming that ICD10 must be implemented by October 1, 2013.     We held our kickoff meeting in June, hired external resources to create a project management office, and hired subject matter expert consultants to assist with the gap analysis, project plan and budget.

Today, I'm posting two resources for the benefit of other organizations planning their ICD-10 projects.

The first is the RFA we used to hire a consulting partner.   In our case, we elected to create a single unified project for the academic medical center, community hospitals, physician organization, faculty practice, and owned community practice.   We felt that creating one project for all the stakeholders would reduce costs while eliminating redundancy and aligning resources.

The second is the letter we sent to all our stakeholders, asking them to create an inventory of the software applications and processes that incorporate ICD9 and need to support ICD10.

In the next few weeks, we'll complete our detailed project plan, budgets, staffing model, and timeline.    I'll share as much as I can as soon as it is available.

ICD-10 is a costly project that will have no benefits and if we're truly successful, the best we can hope for is that no one will be too upset that we implemented it.

Given a project with this many negatives (here's the AMA letter to Speaker of the House John  Boehner), the least I can do is share everything we're implementing in the hopes that others will benefit from our experience.