This issue of the Communiqué is a keeper. On pages 6 through 10 you will find tables that lay out clearly the Electronic Health Records (EHR) incentive program’s Stage 1 Meaningful Use objectives, the recently proposed changes to Stage 1, and the potential Stage 2 objectives, measures and exclusions as proposed by CMS in March. The objectives, translated into measures, are capabilities that your EHR must have in order for you to qualify for the incentive, which is non-negligible at a maximum of $44,000 per physician, or to avoid the penalty for non-compliance. Even though the proposed changes discussed in the Meaningful Use article by Abby Pendleton, Esq. and Stephanie Ottenweis, Esq. are likely to be different in some respects when CMS issues the final regulation later in the year, it is worth familiarizing yourself with the proposals because understanding the final versions will be that much easier.
The Meaningful Use article, just as importantly, describes the bind in which the EHR incentive program places anesthesiologists and pain physicians. The Meaningful Use requirements are heavily oriented toward primary care, office-based practices and it is close to impossible for anesthesiology and pain medicine professionals to meet them even if they have invested in their own EHRs or AIMS. Not only do our physicians not qualify for the incentive; they are also subject to the financial penalties that begin in 2015. To the best of our knowledge, there is no EHR technology that meets all the requirements for certification for use by anesthesiologists.
We know that there are efforts underway either to make the Meaningful Use requirements applicable to specialists or to exempt them from the penalties. Meanwhile, anesthesiologists and pain physicians can do something to help themselves. Like other proposed regulations, this one is open for public comments, which the law requires CMS to consider. In the Notice of Proposed Rulemaking published in the Federal Register on March 7, CMS specifically invited comments on (a) how to treat physicians working in specialized hospital units who are using stand-alone, independently procured certified EHR technology and (b) a possible exemption for specialists who can demonstrate three obstacles to Meaningful Use: (1) lack of direct interaction with patients, (2) lack of need for follow-up care for patients and (3) lack of control over the availability of certified EHR technology. The deadline for the submission of comments to CMS is May 7, 2012. We encourage readers to write to CMS, and we refer those who wish to do so both to Ms. Pendleton’s and Ms. Ottenweis’s article and to the ASA Washington Office.
For the first time in ABC’s 32-year history, we will be submitting comments to CMS urging an exemption for anesthesiologists and pain physicians whose practices do not reasonably allow for compliance with the Meaningful Use requirements. Our own OneSourceAnesthesia information platform and our partnerships with other clinical software providers give us unique insight into the systems barriers to demonstrating Meaningful Use.
In The AQI: Present and Future, Anesthesia Quality Institute Executive Director Richard P. Dutton, MD, MBA updates us on multiple developments. The National Anesthesia Clinical Outcomes Registry (NACOR) is growing as hoped. It now has data from 4,500 anesthesiologists and 3,500 nurse anesthetists working in 1,100 facilities. As of April 1, NACOR includes more than 4 million cases. This number will double by the end of 2012. NACOR is the single most significant database for comparative and internal clinical anesthesia benchmarking. Questions that NACOR will help users to answer include case duration, case numbers and differences in postoperative nausea and vomiting between inpatients and outpatients, to name just a few.
Are you one of the 4,500 or 3,500 professionals contributing data? You should be. The advantages of participation, present and planned, continue to expand. The AQI is now partnering with ASA to create interactive modules for the Maintenance of Certification in Anesthesiology Practice Performance Assessment and Improvement requirements. In October 2011, it launched the Anesthesia Incident Reporting System (AIRS). Individual reports of near misses and other rare events are de-identified and protected from discovery. The aggregated data enable the anesthesia community to identify emerging risks to patient safety more rapidly and will be the basis for an important new teaching tool, a national mortality and morbidity conference to be published as a regular column in the ASA NEWSLETTER.
The AQI is also an unequaled resource for investigators in the field of anesthesiology Comparative Effectiveness Research (CER). As Dr. Dutton explains in his article, “The development of sophisticated statistical methodology for risk adjustment and propensity scoring has made it possible to advance scientific knowledge through the retrospective study of large clinical data sets.” The AQI is looking for collaborators for CER projects.
If you submit claims to Medicare and other payers electronically – and you all do – you can automate the upload of data to the AQI with relative ease. AQI staff are ready to work with you whatever claims software you may be using. ABC is proud of our AQI Preferred Vendor status and we encourage every client who has not already asked us to submit their information to NACOR to do so.
Our own staff member Arne Pedersen, MBA, FACMPE once again shares his considerable business expertise inPlanning for Payor Negotiations. AAA Leadership Committee member Franc Galinanes walks readers through the subject Knowledge is Power: Why Anesthesiologists Need to Capture, Analyze and Use Data. This issue also contains one more contribution from Neda Mirafzali, Esq., who discusses why Anesthesiologists Should Beware of HIPAA Audits
As always, we hope that these articles will be informative and helpful, and we invite your comments, questions, suggestions and proposals for future issues.