HealthData Management - December 2012

technical challenge for Sharp and everyone else, Spooner says. View/download/ transmit capability will require that the EHR receiving the request be able to format the data in addition to storing it, he explains.

The EHR will have to look at a lab result
and know it goes in the patient summary
and has to be in a format to be received in
the requesting EHR system.

A learning curve
At Greater Baltimore Medical Center, an
inpatient portal to support patient access
to their health information is just part of
the overall meaningful use plan. “We’re

The Delay In Stage 2 Delivers A Convoluted Timetable

Under the original timetable for the electronic health records meaningful use incentive program, providers who were early adopters and attested the first time for Stage 1 in 2011, then again in 2012 during the second year of Stage 1 (each stage is two years long and requires two attestations to receive payments), only had a few months to get ready for Stage 2, which was to begin in October 2012 for hospitals and January 2013 for eligible professionals.

Providers and software vendors lobbied federal officials for a delay in Stage 2 and got it in the final Stage 2 rule, with the second phase now starting in October 2013 for hospitals and January 2014 for eligible professionals. Further, those who attested in 2011 got a third year to attest to Stage 1 meaningful use.

With the delay, the feds in the final rule laid out timetables for meaningful use reporting periods in Stage 2 and subsequent stages, but the timetables are a bit confusing.

Under the new timetables, providers in their first year of participation in either stage have a 90-day reporting period of their choosing, while subsequent years of the stage require a one-year reporting period. That seems simple enough. But there is an exception for 2014 when providers have a 90-day reporting period for Medicare—fixed by quarters in the federal fiscal year for hospitals and quarters in the calendar fiscal year for eligible professionals. Hospitals and eligible professionals can choose their quarter, and hospitals also would attest for Medicaid meaningful use under the federal fiscal year.

But Medicaid reporting periods for eligible professionals will vary according to the rule: “Medicaid EPs will attest using an EHR reporting period of any continuous 90-day period between January 1, 2014, and December 1, 2014 as defined by the state Medicaid program, or if the state so chooses, any 3-month calendar quarter in 2014.” Put another way, that means no one presently knows when eligible professionals can attest to meaningful use in 2014 and that won’t been known until states start deciding.

Understanding the various timetables for 2014 isn’t rocket science, but there is a chance of trading partners not interpreting the timetables exactly the same way. “I think there’s definitely some confusion out there,” says Scott Rohleder, information technology director at Hays Medical Center, in Kansas. He strongly suggests that providers talk to all of their information systems vendors whose products play a role in achieving meaningful use to make sure they are on the same page about when certain reporting functionalities must be ready for providers so they can attest within the various 2014 attestation timetables.

Jeanne Day, director of health information management at Greater Baltimore Medical Center, doesn’t believe the timetable is confusing, nor is the first-year, fixed 90-day Medicare attestation periods a problem, with one caveat. A provider wanting to start a reporting period in January 2014 but consequently isn’t ready until February must wait two more months, until the April-June quarter, to start the reporting period. That means rather than being done in March 2014 and having six months to focus on ICD- 10, they’ll be done with meaningful use in June and may not be as far along with ICD- 10 as they hoped to be. So, the fixed reporting periods could impose some degree of time pressure for other major projects an organization is working on.

Overall, however, moving Stage 2 to 2014 remains very beneficial for all involved in meaningful use, says Lorna Green, R.N., senior business analyst for document management vendor Hyland Software in Westlake, Ohio. “It just gives us a little longer time to make sure we have the functionality in place and for hospitals to implement it, and that it’s done well.”

looking to do more with the portal than just meaningful use,” says HIM director Day. Functions such as online payment and pre-registration, among others, will offer patients more convenient services and make the portal more valuable.

The medical center already has a patient portal for its more than 40 owned multi-specialty ambulatory practices, but HIM wasn’t involved in that project and has a learning curve to learn the basics of portals. Day expects to get advice from practice administrators, and already has reached out to HIM peers in the region with an inpatient portal to get ideas on addressing such issues as providing access not just for adult patients but also minors.

Greater Baltimore hopes to do a full 90-day test reporting period for Stage 2 during the fourth quarter of 2013, then do the formal reporting period at the start of 2014 and attest in early April.

That timetable would have Stage 2 compliance off the hospital’s plate six months before the ICD- 10 compliance date in October to ease that initiative, but also give the hospital a little wiggle room during the April-June quarter if it needed more time to finish attestation, with still three months to focus on completing ICD- 10, Day explains. “Why schedule other projects to coincide with ICD- 10 if you can avoid it?”

Exchange options

A patient portal will be a core tool for complying with Stage 2’s view/download/ transmit and secure messaging requirements at Hays Medical Center serving northwest Kansas, but it won’t be the only way to get patients their information electronically.

The hospital presently uses CDs to give patients their information when requested, and is considering providing flash drives to patients who don’t have ready Internet access to satisfy the meaningful use measure, says Deloris Farthing, director of health information management.