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View the CLMA presentation: ARRA/HITECH and its Impact on Labs
View the presentation Curt Johnson, COO of Orchard Software, gave at CLMA's annual conference, ThinkLab '11, for the must up-to-date information on final Stage 1 and proposed Stage 2 rules and definitions for certification and meaningful use criteria. Stay tuned for our upcoming webinar after the final Stage 2 meaningful use criteria are published. |
What does “Meaningful Use” mean to me and my laboratory?
Overview | Incentives | EMR Certification | LIS Certification | Meaningful Use | Integration | More Information | Request Information
Overview
The ARRA/HITECH bill was introduced in 2009, where financial incentives are being offered to both physicians and hospitals to stimulate the adoption of certified EMR/EHR technology and use it in a meaningful way. In January 2010, proposed Stage 1 rules and definitions for EMR/EHR certification and meaningful use criteria were published and then commented on throughout the spring of 2010. On July 28, 2010, Stage 1 rules and definitions were made final and published. In December 2010, proposed Stage 2 rules and definitions were released for review and comments.
Here is a summary of what has been published thus far.
Incentives
Financial incentives are being offered to both physicians and hospitals. The total incentive that can be earned over time by physicians is $44,000 per physician. The incentive for hospitals is determined by a more complex equation, but for most hospitals, it will be over $2 million. These incentives are earned and paid out over a five- to six-year period of time, depending on the use of a certified EMR/EHR and meeting meaningful use criteria. Down the road after 2015 or so, the government is proposing a penalty of a reduction in Medicare reimbursements for those physicians and hospitals who do not comply with these EMR/EHR initiatives. For more specifics regarding incentives, download the PDF of the slides from the ARRA webinar and review slides 8-16, or go to this page, www.cms.gov/EHRIncentivePrograms/, on the CMS website.
EMR Certification
Use of “certified EHR technology” is a core requirement for providers and hospitals who seek to qualify to receive incentive payments authorized in the ARRA/HITECH Act for 2009. Certification assures healthcare providers and hospitals that the EMR/EHR technology they adopt has been tested and includes the required capabilities they need in order to use the technology in a meaningful way to improve the quality of care provided to their patients.
In the summer of 2010, the ONC began accepting applications from entities and organizations interested in becoming ONC-ATCB (Authorized Testing and Certifying Bodies). As of this writing, the following six organizations have been selected as ONC-Authorized Testing and Certification Bodies (ATCBs):
- Certification Commission for Health Information Technology (CCHIT) - Chicago, IL
- Drummond Group Inc. (DGI) - Austin, TX
- ICSA Labs - Mechanicsburg, PA
- InfoGard Laboratories, Inc. - San Luis Obispo, CA
- SLI Global Solutions - Denver, CO
- Surescripts LLC - Arlington, VA (Pharmacy only)
Please note that while CCHIT is one of the ATCBs, EMR/EHRs certified by CCHIT prior to this announcement will need to reapply for certification under ONC-ATCB.
Will my existing EMR/EHR qualify? The answer is yes, as long as your EMR/EHR vendor applies for and obtains certification from one of the ONC-ATCBs. We recommend that you check with your existing EMR/EHR vendor to determine their plans for certification. Some EMR/EHR vendors are not applying for certification on earlier versions of their software, and an upgrade by your organization may be necessary to qualify for incentives.
The ONC has begun listing certified EMR/EHRs on their website. Visit http://healthit.hhs.gov for that listing.
For more specifics regarding EMR/EHR certification, download the PDF of the slides from the ARRA webinar and review slides 17-23, visit http://healthit.hhs.gov/certification, or read the PDF of the certification criteria for EHR technology from the Federal Register.
Does my Lab Information System (LIS) need to be certified?
The answer is, "It depends." On the ONC’s Regulations FAQs, Question [9-10-010-1], it states that "Other IT systems that act as data sources and are not intended to perform required capabilities in accordance with adopted certification criteria do not need to be certified simply because they supply data to a Complete EHR or EHR Module."
However, if your LIS is performing any of the functions necessary to meet meaningful use criteria, acting as an "EHR Module," then the answer is "Yes, your LIS will need to be certified." Examples of meaningful use criteria that might be performed by the LIS instead of through the EMR/EHR are physician order entry and electronic lab reporting.
If you are using an EMR Module to perform a task necessary for proving meaningful use, then that module must be certified. Because our systems are being used for some of the necessary criteria, such as Computerized Physician Order Entry (CPOE), sending surveillance data, and Electronic Lab Reporting (ELR), Orchard Software has obtained its Eligible Provider certification and is in the process of obtaining our Eligible Hospital certification for Orchard Harvest LIS. For more information regarding this certification click the link for the press release or visit our blog, colLABorate.
[Return to Top]Meaningful Use
In addition, the Centers for Medicare & Medicaid Services (CMS) issued final regulations to implement the EMR/EHR incentive programs. The final rule on Stage 1 MU has also been published in the Federal Register. As you may recall, to qualify for these financial incentives and avoid penalty, physicians and hospitals need to adopt certified EMR/EHR technology, achieve MU objectives, and then apply for the incentive payment.
In summary, Stage 1 MU criteria established 15 Core Objectives for providers and 14 for hospitals. You must select five out of ten objectives from a Menu of Objectives, of which one must be a public health objective. In addition to that, there are six total Clinical Quality Measures required, of which three must be from core measures (or alternate core measures) and an additional three chosen out of a menu of 38 measures.
Summary of Stage 1 Meaningful Use Criteria:
- 15 Core Objectives (14 for hospitals)
- 5 out of 10 Objectives from a Menu of Objectives
- 6 total Clinical Quality Measures
- 3 from Core Measures (or alternate core measures)
- 3 out of 38 Measures from a Menu
For more specifics regarding stage 1 meaningful use criteria, download the PDF of the slides from the ARRA webinar and review slides 24-40. You may also visit www.cms.gov/EHRIncentivePrograms/, which features information about who is eligible for the programs, how to register, meaningful use, upcoming EHR training and events, and other information. Or, read the PDF of the meaningful use criteria for EHR users from the Federal Register.
What’s coming for Stage 2 and Stage 3 Meaningful Use?
Stage 2 proposed criteria were published in December 2010. The “comment period” has ended, and we are now waiting for those comments to be made public. We believe it will suggest moving most menu items to core. It is expected that by Stage 3, ALL of the menu items will become core objectives for MU. To read more on the proposed Stage 2 criteria go to http://healthit.hhs.gov/ or read the PDF of the preliminary thinking of the HITPC and its Meaningful Use Workgroup. Below is a table showing the proposed MU criteria for Stage 2 that impact the lab.
Stage 1 Final |
Proposed Stage 2 |
Proposed Stage 3 |
CPOE for medication orders (30%) |
CPOE (by licensed professional) for at least 1 medication, and 1 lab or radiology order for 60% of unique patients who have at least 1 such order (order does not have to be transmitted electronically) |
CPOE (by licensed professional) for at least 1 medication, and 1 lab or radiology order on 80% of patients who have at least 1 such order (order does not have to be transmittted electronically) |
Incorporate lab results as structured data (40%)* |
Move current measure to core, but only where results are available |
90% of lab results electronically ordered by EHR are stored as structured data in the EHR and are reconciled with structure lab orders, where results and structured orders available |
Submit reportable lab data* |
EH: move Stage 1 to core EP: lab reporting menu. For EPs, ensure that reportable lab results and conditions are submitted to public health agencies either directly or through their performing labs (if accepted and as required by law).
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Mandatory test. EH: submit reportable lab results and reportable conditions if accepted and as requred by law. Include complete contact information (e.g., patient address, phone and municipality) in 30% (EH) of reports. EP: ensure that reportable lab results and reportable conditions are submitted to public health agencies either directly or through performing labs (if accepted and as required by law) |
* Menu Option in Stage 1
When will Final MU Criteria Stage 2 be published? HIT Policy Committee meets April 5, 2011 and Final Recommendations are expected May 13, 2011. We estimate that final Stage 2 MU Criteria will be published in late summer 2011 based on the publication timeline for final Stage 1 MU Criteria.
What does this mean for your laboratory?
Integration and the ability to send structured data are the biggest issues facing laboratories regarding the ARRA and aiding their facility in meeting MU criteria. While the proposed criteria that directly affected the laboratory was not made mandatory to meet MU objectives in Stage 1, we believe, based on the ultimate goals of the HITECH program and what has been proposed in stage 2 [incorporate lab results is proposed as a core (mandatory) item], that electronic integration of the lab to the EMR and the ability to send results in a structured format will become mandatory in the upcoming stages. Electronic integration for order entry and result delivery is the future. The use of LOINC and SNOMED codes are also in the future. These integration and portability issues will affect all labs, including POLs, hospitals, and reference laboratories. The ability to integrate your laboratory and send data to your facility’s EMR or your laboratory clients’ EMR system will be the number one issue facing all laboratories for the next couple of years.
For More Information
We encourage you to stay abreast of these proposals and determine how they will impact you. We here at Orchard will do our best to keep you aware of the proposals and final rulings for “Meaningful Use” as they are announced. We are holding complimentary webinars to keep you informed and posting on this page recordings and PDFs of the slides for your review. Monitor our website regularly and check our colLABoration blog to stay abreast of this topic and of future webinar offerings. And, don’t hesitate to send us your ARRA questions surrounding the lab or your LIS via the buttons at the top and bottom of this page.
You can also use your favorite search engine to find many postings and white papers on the subject of meaningful use. Another good source will be your EMR vendor, as most EMR companies are very aware of this topic and have information on their websites.
Request Information on Meaningful Use and EMR Integration
We are experts in integration, and our systems are designed to generate, store, and share structured data. With over 1,000 laboratory customers—including physician offices, clinics, hospitals, independent reference labs, and university student health centers, Orchard has successfully interfaced our lab systems to hundreds of instruments, healthcare information systems, reference laboratories, public health centers and EMRs. As a best-of-breed vendor, our products have been designed with electronic integration in mind. Click the link to learn more on how our lab systems and our Copia laboratory outreach and integration system aid you in EMR integration. To request more information and arrange to speak with one of our representatives about how Orchard can help your lab connect to your EMR or your clients' EMR, click the button below.