Meaningful Use Pain Point for Hospitals: Transition of Care
The transition for Eligible Hospitals (EH) from Stage 1 to Stage 2 Meaningful Use (MU) certainly has challenges. Six months ago I had imagined that patient engagement requirements would be the troublemaker. After all, getting patients to come to the hospital patient portal was a whole new ball of wax. This is a core MU requirement and would need some ingenious work flows to pull it off. Core measures are critical. Miss on those and it is goodbye to incentives and hello to penalties. But I was wrong. The portal was just a temporary stumbling block for most hospitals. The real killer for many EHs is a wolf in sheep’s clothing. Enter “Transition of Care”. I have heard from more than a few EHs that this measure is what is standing between them and meeting Stage 2 requirements.
For Stage 1 this was a Menu Set objective and therefore an EH could choose to defer it and move on to other objectives that might be easier to meet. If a hospital did choose it, the requirements weren’t too tough as outlined by CMS, “The eligible hospital or CAH that transitions or refers their patient to another setting of care or provider of care provides a summary of care record for more than 50 percent of transitions of care and referrals.” In addition CMS tell us, “The eligible hospital or CAH can send an electronic or paper copy of the summary care record directly to the next provider or can provide it to the patient to deliver to the next provider, if the patient can reasonably expected to do so.”
Stage 2 takes this Stage 1 Menu Measure and flips it to the Core side. And to add insult to injury, we can’t get away anymore with paper copies being handed to patients. We are still at the 50% threshold requirement but there are now some touchy electronic requirements. Three different underlying measures are now incorporated that must be achieved. A clear understanding of what is required for the “electronic exchange” component is paramount. Fail to properly demonstrate and document this aspect of the Measure and it is all over but the crying.
The exchange of a Summary of Care during a transition of care is a foundational element of electronic health care interoperability. It is not going away and I suggest the best policy for a hospital is to fully embrace it by adopting technology and workflows to make it a seamless aspect of continuity of care. For a good overview of how this might be accomplished, I suggest taking a look at ONC’s Eligible Hospital Tip Sheet for Meaningful Use Stage 2: Implementation Tips for Summary of Care Objective.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: firstname.lastname@example.org. This post was original published on MeaningfulUseAudits.com.