Last week we attended HIMSS12 the national conference of HIMSS in Las Vegas. The pace of adoption of electronic medical records is increasing, and Dr. Farzad Mostashari, Director of the Office of the National Coordinator (ONC) from Health and Human Services (HHS) made a breath taking statement in his key note that he expects more care to be delivered in 2013 by providers using an EMR than not.   Wow – did he just suggest over 50% adoption of Electronic Health Records?

Dr. Mostashari, Director of ONC at his HIMSS Keynote

Current data suggests that we have achieved perhaps 15% of U.S. Medicare and Medicaid providers achieving meaningful use attestation via a regional extension center and CMS web portal, with perhaps 30% in some stage of development of implementing an EMR.

We also attended a session given by the primary author of Stage 2 meaningful use, Travis Broome from CMS.  There are revisions in the attestation process, timing of incentives and also a carrot and stick for industry adoption of standards for supporting quality measures (a key driver of payment reform and the shift away from fee for service medicine) in EMRs whereby CMS can either sweeten incentives or reduce them.

Although $27 billion has been put forth by HHS and CMS for EMR adoption, the real prize will be in determining who has access to the data of the EMR and how interoperability will be facilitated.  Vendors who are either providing EMRs or integrating with them are attempting to both embrace the Clinical Document Architecture (CDA) as well as differentiate from their competition.

One of the key questions will be how the EMR provides a foundation with the Health Information Exchanges (HIEs) for comparative effectiveness data over the life span of  a patient (sometimes called the continuum of care) and whether CDA standards currently proposed will accomplish that.   Informatics people call this “longitudinal clinical data.”  We’ll be speaking this spring on these topics and analyzing in future reports whether Accountable Care Organization enablement is on track.  While the $billions in meaningful use incentives are getting the spotlight today, the shift from Fee for Service (FFS) to evidence based medicine represents a tectonic shift in the $3 trillion health care economy.  When blended with ICD-10, we have a perfect storm for innovation and redistribution of wealth in healthcare.  Although ICD-10 has likely been delayed and some providers are relieved, the interaction between CMS, ONC, and HIPAA standards creates some interesting opportunities in the next five to ten years.  ICD-10 will provide the underlying content of diagnosis and procedure codes that will populate the EMRs and HIEs.

Keep watching the interchange between CMS, who sets the standards for Meaningful Use (i.e adoption of EMRs) and ONC that sets the standards for interoperability.  And, look for vendors with vision that can capitalize on the standards while achieving commercial adoption to enable Accountable Care Organizations.

Related posts:

• Electronic Medical Records and Analytics
• ICD-10 Mandate postponement and talk of ICD-11

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With CMS confirming that they are considering a delay in the final mandate for ICD-10 past the October 1, 2013 current deadline,  there are some discussions going on about skipping it entirely in favor of ICD-11.

Some things about ICD-11 – The base version from WHO is expected in May 2015.  After that, the United States will probably need another two years for development of the US version.  The earliest it would be available for study would be 2017, and we would need another 4 years to implement it – so that brings us out to 2021, way too far in the future.

Second and most importantly, we do not favor penalizing the companies that have started work on time on ICD-10.  The health care industry has spent hundreds of $millions already on ICD-10 education, assessments, etc.  Some hospital organizations are not happy about the delay, either.

It would be best for health plans, hospitals, and physicians to use the extra time to implement ICD-10 correctly.  There are consortiums that have sprung up to help with this effort.  We’ll be discussing this more at HIMSS 12 this week in Las Vegas, NV.

Discussion has been that ICD-10 is a steppingstone to ICD-11, so it is probably a good thing to do.  Also, ICD-9 has about had it, so we can’t see keeping it around another 10 years.  Note that ICD-10 procedure codes have nothing to do with the diagnosis codes or ICD-11, so that is a non- factor.  The ICD-10 procedure codes for use in hospitals are a significant improvement.

The theory of a staggered start to ICD-10 has also been floated – that CMS might continue to mandate the October 1, 2013 date for some plans or providers while offering relief to others.  One theory is that smaller entities or rural providers might get relief.   This seems equitable – that those who have invested in ICD-10 and can afford to meet the ICD-10 date would continue on their current path, while those who cannot afford it get a break.  However if one considers the national impact of a staggered start, it means that payors would have more dual processing of ICD-9 and ICD-10 claims to consider, based on a new factor – size of the provider and perhaps their location.  Would this relief really help or cause more havoc?  We’ll all learn more when CMS clarifies their statement that “certain entities” might be impacted.

There are clear benefits in our mind of ICD-11, including SNOMED CT clinical vocabulary supporting Electronic Medical Records.  However, the ICD-10 train has left the station.  It should be arriving – just later than scheduled.

Related Posts:

HIPAA, ONC, and CMS incentives and regulations and their impact on Accountable Care Organizations

ICD-10 and Electronic Medical Records - 65% of the Time they might work?

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