How to Survive and Sustain Meaningful Use - Sandy Summers

1. How to Survive and Sustain
Meaningful Use
Sandy Summers
Director of Meaningful Use

2. 2
Reflection
“Whether you
think you can, or
think you
can’t…you’re
right!”
Henry Ford

3. 3
Learning Objectives
Learn
effective
program
management
strategies for
achieving
Meaningful
Use for
multiple
sites, stages,
vendors and
jurisdictions
for Stage 1
and Stage 2
Learn
successful
techniques
for the most
challenging
Meaningful
Use Stage 2
objectives:
• Patient
Electronic
Access (View-
Download-
Transmit)
• Summary of
Care
transmission
• Public Health
Interfaces
Learn proven
techniques
for proactive
audit defense
and audit
response for
Figliozzi
audits and
OIG audits
Learn new
challenging
scope and
targets for
Stage 3

4. Dignity Health
Background:
• Dignity Health, one of the nation’s largest health care systems,
is a 20-state network of nearly 9,000 physicians, 56,000
employees, and more than 400 care centers, including
hospitals, urgent and occupational care, imaging centers,
home health, and primary care clinics. Headquartered in San
Francisco, Dignity Health is dedicated to providing
compassionate, high-quality and affordable patient-centered
care with special attention to the poor and underserved.
Mission
• Dignity Health is committed to furthering the healing ministry
of Jesus. We dedicate our resources to delivering
compassionate, high-quality, affordable health services;
serving and advocating for our sisters and brothers who are
poor and disenfranchised; and partnering with others in the
community to improve the quality of life.
Community Activity:
• In FY14, Dignity Health provided nearly $2 billion in charitable
care and services
HQ: San Francisco
Net Operating Revenue:
(FY14) $10.7 billion
Hospitals: 39
Clinics/Ancillary Care
Centers: 400+
Medical Groups within
Dignity Health Medical
Foundation: 15
Employees: 56,000
Physicians: 9,000
Acute Care Beds: 8,500
Skilled Nursing Beds: 700
Last updated: May 6, 2015

5. 5
DignityHealth

6. 6
Dignity Health Meaningful Use Program Management
Program Governance
and Organization
Structure – Centralized
Meaningful Use
Attestation Plan
Communication Plan
Education Events
(workshop, webinars)
MU Objective
Compliance Plans with
focus on tougher
measures
Attestation Activities
(Data generation and
review, sign-off,
entry/submission)
Document retention
(SharePoint and secure
network archives)
Financial impact
analysis and
monitoring
Audit defense
preparation and
response

7. 7
Program Governance and Organization Structure
Clinical
Program
Executive
Program
Director
Clinical
Analyst(s)
Business
Analyst(s)
Business
Intelligence
Analyst(s)
Regulatory
Compliance
SME (s)
e.g., CHAN
Interoperability
SME(s)
Leadership Core Team Specialists
Security Risk
SME(s)
Application
Interface
SME(s)
Patient Portal
SME(s)

8. 8
Program History and Summary
• The MU program has grown from 8 sites to 29 sites attesting
• 77 total hospital attestations to date

9. 9
Meaningful Use Program Tools
Public health authority
readiness status
tracker tool
(Example follows)
Audit defense checklist
and manual
(Example follows)
Audit defense toolkit
(includes sample
screenshots needed)
Financial incentives
and reductions log /
pivot analysis tool
Audit defense materials for all known requests to
date for each site (e.g., redacted vendor contracts
for certified software)
Attestation status
tracker by year
Certified Health
Product List / CMS
certification ID log tool
by site by program year
Attestation timeline
(flight plan)
(Example follows)

10. Helpful for …
• visualizing all sites in flight regardless of year,
stage, or EHR platform
• communicating with project management and
application scheduling team
Dignity Health Meaningful Use Attestation Timeline

11. 11
• ARRA Overview – Regulatory Context
• HHS Strategic Framework
• Financial Incentives and Reductions
• Attestation Timeline
• Specific MU Objectives by Stage,
especially Security Risk Analysis, Public
Health, Clinical Decision Support
• Audit Defense and Response
• Document retention
• Clinical Quality Measures
• MU Program Team; roles and
responsibilities
• Identifying key site stakeholders; roles
and responsibilities
• Workflow for key elements data
capture
• Lessons learned by MU objective
• Training on report execution and
monitoring
• Strategic Conversation; Identification
of key decisions to be made
Meaningful Use Education Workshops
Executive Overview and Deep Dive Conducted at Each Site

12. 12
Communication Strategies
Establish
governance at
each site
Leverage existing
meeting structures
as feasible
Program calendar
Stakeholder
contact list
Vendor
management
Steering calls for
key stakeholder
groups

13. 13
Program Management Meeting
Agenda Topics
Vendor update
MU measures
data monitoring
& trending
RAID
management
Review of
regulatory
rulings
Workflow
analysis
Decisions on
changes needed
Communication
strategy
developed
Tip Sheets
developed

14. 14
Site Steering Meeting
Agenda Topics
Review of MU
Functional Reports
Sharing Lessons
Learned & leading
practices
Speakers on
Security Risk
Analysis, CHAN,
patient portal
Workflow
optimization
discussion &
decision making
Status updates
vendor code fixes,
packages, etc.
Live
demonstrations on
workflow
Legal discussion/
review

15. 15
Use Dashboards to Monitor Metrics and Progress…
Each facility can
evaluate their stage
status with this multi-
stage graph.
Color coordination
along with bubble
presentations allow a
site to review each
metric, if the metric has
changed from one stage
or any course
corrections necessary.
These metrics are
available monthly for
site consideration.

16. Challenging Stage 2 Meaningful
Use Objectives
Patient Electronic Access

17. 17
Challenging Objectives:
Patient Electronic Access
Hospital Leadership
Sponsor is key for
Portal Success (CFO
or CNO)
Must have a Portal
lead
Patient Registration
– needs to collect
35% emails
Round on Patients:
Portal Lead /
Volunteers / Light
Duty Worker

18. 18
Challenging Objectives: Patient Electronic Access
Meet weekly until you
hit the 8% level for
inpatients/ observation
then bi-weekly status
updates
Go for the two-for-
one opportunities
(Mom and Baby)
Portal Lead – manage the daily Unclaimed
Portal Invite report
• Assign rounding duties and focus on in-house patients
with portal invites
• Round on Cardiac and Orthopedic patients
• Round on Rehabilitation therapy clinic and Cardiac
therapy patients

19. 19
Challenging Objectives:
Patient Electronic Access
Use of volunteers, staff
members, and
temporary staff
Registration
involvement / gather
email address upon
admission
Accept invite before
discharge
Patient population does
matter

20. 20
• Clinical staff, HIM and Clinical
Informaticists can send invite to
access the portal
• Develop marketing materials
• Clinical staff needs to discuss the
portal when talking with patients
• Dignity Health hired a marketing
expert to develop materials and
outreach to work with our
hospitals marketing departments
Challenging Objectives: Patient Electronic Access

21. Domain A – Observation Services Method
(82% of Year-long Attestation)
21
Hospital Jul 26 Enroll Patients/Day 6%/Day Needed % of Goal
Site 1 9.7% 756 26 -2.8 -186 133%
Site 2 (Stage 1) 7.0% 246 12 0.2 13 95%
Site 3 (Stage 1) 5.3% 655 41 3.8 250 72%
Site 4 (Stage 1) 2.6% 256 33 7.1 468 35%
Site 5 6.5% 334 17 0.6 41 89%
Site 6 6.2% 440 24 1.2 82 84%
Site 7 8.0% 1241 52 -1.7 -110 110%
Site 8 11.4% 617 18 -3.3 -220 156%
Site 9 5.5% 189 12 1.0 65 75%
Site 10 9.5% 199 7 -0.7 -46 130%
Site 11 13.5% 1114 28 -7.7 -509 184%
Site 12 9.2% 288 10 -0.9 -60 126%

22. The VDT Marathon – Keeping the 6% Pace
22
Key to Columns:
A – Hospital Name
B – Week ending date and
cumulative % of goal
through last week’s data end
date
C – Week ending date and
cumulative % of goal
through this week’s data
end date
D – Number of days into this
365 day year as of ending
date for this week’s data and
corresponding day into the
365 day year based on the
hospital’s percent
completion as of this week’s
data
E – Month equivalent of
column D
F – Visualization of
corresponding month in the
year for current pace of
adoption
G – Finish Line; current rate
should achieve >5% for the
year even if no more OPC
enrollments

23. Challenging Stage 2 Meaningful
Use Objectives
Summary of Care
Public Health Reporting

24. 24
Challenging Objectives: Summary of Care
Cleaning up problem
lists (problems, allergies,
medications)
Identifying recipients
with Direct email
addresses (less than 1%)
Identifying top referring
providers and providing
Direct emails
• Credentialing
• Training/Education
Vendor selection and
procurement for Direct
email

25. 25
Challenging Objectives: Summary of Care
Resource needs for
manual sending of
summary of care
documents
Implementation and
testing of the ops
job (6 month effort)
Determining content
for C-CDA (e.g.,
including Radiology
results and timing)
Legal considerations
(referring
physicians)
NIST submission –
done by corporate
MU team

26. 26
Transition of Care - Ops Job Results

27. 27
Challenging Objectives:
Public Health Objectives
Dignity Health operates in 20 counties across three states
Most counties are not ready for Syndromic Surveillance
Monitor each public
health authority for
readiness to receive
data
Work with interface
team for testing and
readiness
Keep Audit defense
documentation
(emails)
Provide education
and training for the
hospital sites
Coordinate with
Vendor for Go lives
and MU Stages for
each hospital
Participate in
conference call with
vendors and state
agencies
Monitor failures and
recovery plan

28. 28
Public Health Status Tracker
Tracker data
elements:
• Hospital, Region,
County
• Cerner Domain
• Status and Notes
for each public
health objective:
–Registration
–Training
–Testing
–Production

29. Audit Defense

30. 30
Source: MDEverywhere, Jan 2015
10,000
unique audits were
conducted on
265,075
Eligible Professional
attestations
4,601
have been completed
22.7%
of EPs failed to meet
meaningful use standards
98.9%
of failing EPs did not meet
appropriate measures and
objectives

31. 31
Source: MDEverywhere, Jan 2015
4,637
Eligible Hospital Attestations
(13.2%)
613
post-payment audits
were initiated from
4.9% of EHs failed their audits
The average incentive returned was $1.1 M
Total incentive recoupment has totaled $33 M

32. 32
Meaningful Use Attestation and Audit Statistics
Stage 2 attestations
through FFY 2014:
Dignity Health 10/10
= 100%
Successful
CMS/Figliozzi Audits:
• FFY 2013 2/2 = 100%
• FFY 2014 7/7 = 100%
State Medicaid Pre-
payment Audits: FFY
2013 1/1 = 100%
State Medicaid On
Site Financial Audits
– 1 pending
OIG Audits of State
Medicaid EHR
program – 7 pending
CHAN Internal Audits
– documented action
plans

33. 33
Audit Defense Template Guide
Detailed audit defense checklist
documents:
• Audit documentation
requirements
• Supplied by (department)
• Completion status
• Owner (individual’s name)
• Owner facility, department and
title
• Document name
• Document Specifics and
Comments
• Document location (electronic
and paper-based)

34. CMS/Figliozzi Audits Against FFY 2013
Milestone Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 Site 7
Initial
notification
May 20 May 20 May 20 May 20 May 20 May 20 Jun 30
Due date Jun 17 Jun 17 Jun 17 Jun 17 Jun 17 Jun 17 Jul 14
Response date Jun 13 Jun 13 Jun 11 Jun 16 Jun 13 Jun 13 Jul 3
Follow-up
Request
Aug 8 N/A Aug 8 N/A Aug 8 Aug 8 Jul 8
Follow-up Due
Date
Aug 22 N/A Aug 22 N/A Aug 22 Aug 22 Jul 22
Follow-up
Response
Aug 13 N/A Aug 13 N/A Aug 13 Aug 13 Jul 9
Final
determination
Sep 2 Aug 25 Sep 2 Sep 8 Sep 2 Sep 8 Jul 28
Outcome PASS PASS PASS PASS PASS PASS PASS
34

35. Figliozzi Scope of Request – Five Topics in Three Parts
35
• Proof of use of a Certified EHR system
• Documentation to support the method chosen to
report ED admissions
Part I – General
Information:
• Supporting documentation for core measures used in
the completion of the Attestation Module
• Provide proof that a security risk analysis of the
Certified EHR Technology was performed prior to the
end of the reporting period
Part II – Core Set
Objectives/Measures:
• Supporting documentation for menu measures used in
the completion of the Attestation Module; supporting
documentation for non-measurable menu items
claimed
Part III – Menu Set
Objectives/Measures:

36. 2015 Office of the Inspector General (OIG) Audits
Summary
Milestone Site 1 Site 2 Site 3 Site 4 Site 5 Site 6
Initial notification Apr 15* Apr 17 Apr 17 Apr 15 Apr 17 Apr 15*
Due date Apr 28 Apr 30 Apr 30 Apr 28 Apr 20 Apr 28
Response date May 6 Apr 28 Apr 29 Apr 27 Apr 28 May 7
Notification
letter sent to:
Administration
Manager Senior
Executive Assistant
Chief
Financial
Officer
Vice President
of Finance and
CFO
Regulatory
Compliance
Manager
Facility
Compliance
Professional
Director of Quality
Years Audited 2013-14 2012-14 2011 & 13 2012-13 2011-13 2011-14
At Stake $4.75M $5.66M $3.213M $3.304M $3.785M $5.249M
2nd Request Jun 12 Jun 17 Jun 15 N/A Jun 11 N/A
2nd Request Due Jul 6 Jul 6 Jul 6 N/A Jul 6 N/A
2nd Submission Jul 1 Jun 26 Jun 24 N/A Jun 23 N/A
Final
determination
TBD TBD TBD TBD TBD TBD
Outcome PENDING PENDING PENDING PENDING PENDING PENDING
36
* Initial notification went undetected until after the response due date. OIG
was contacted and a new 10 business day response period was granted.

37. 37
See Appendix for detailed questions.
OIG Audits of State Medicaid EHR Incentives
Scope of Initial Request
State Medicaid
Enrollment
Medicaid Patient
Volume
Medicaid EHR Hospital
Payment Calculation
Certified EHR
22 Questions in Four
Sections, Covering…

38. 38
OIG Audits of State Medicaid EHR Incentives
Submitted Documents
Cover Letter
Questionnaire and
Document Request with
Embedded Responses or
Reference to
Attachments
Patient Volume
Information
Cost Report Documents Calculation Tools
Vendor Verification
Letter(s)
CMS Certification ID;
Certified Product List
Screen Shots of Access
to EHR

39. Meaningful Use Rules Update
Modified Stage 2 2015-17
Stage 3 2017-18ff

40. New Rules –
Released Oct 6; Published Oct 16, 2015
40
Electronic Health Record Incentive
Program -- Stage 3 and
Modifications to Meaningful Use in
2015 through 2017
Released Oct 6
https://federalregister.gov/a/2015-
25595
PI version = 752 pages
2015 Edition Health Information
Technology Certification Criteria,
2015 Edition Base Electronic Health
Record Definition, and ONC Health
IT Certification Program
Modifications
Released Oct 6
https://federalregister.gov/a/2015-
25597
PI version = 560 pages

41. Stage Of Meaningful Use Criteria By First Payment Year
41
• The focus of the first three
stages remains as follows:
stage 1, capture data in
structured formats; stage 2,
improve clinical processes;
stage 3, drive patent
population health outcomes
• First year measurement
requirement (regardless of
year) remains 90 continuous
days of meaningful use in
that payment year.
• All subsequent years, the
measurement requirement
is for the entire year. For
2015, the measurement
period is 90 days within the
15 months ending Dec 31,
2015. Stage 3 period in
2017 is 90 days.
Source: 2015-25595-PI.pdf, pp. 60-61
1st Yr MU 2015 2016 2017 2018 2019ff
2011 M M M or   
2012 M M M or   
2013 M M M or   
2014 M M M or   
2015 M M M or   
2016 N/A M M or   
2017 N/A N/A M or   
2018 N/A N/A N/A  
2019ff N/A N/A N/A N/A 
M = Modified Stage 2
 = Stage 3

42. 1. Protect Patient Health Information
• Conduct/review Security Risk Analysis (SRA);
correct deficiencies
2. Electronic Prescribing (eRx)
• >60% Eligible Professionals; >25% Eligible
Hospitals
• Permissible prescriptions only
• Drug formulary checks
3. Clinical Decision Support (CDS)
• 5 CDS interventions
• Drug-drug/allergy checks
4. Computerized Provider Order Entry (CPOE)
• >60% medication orders
• >60% laboratory orders
• >60% diagnostic imaging orders
5. Patient Electronic Access to Health Info
• >80% can access to View, Download or
Transmit (VDT) w/in 24 hours via portal or
Application Programming Interface (API)
• >35% identify patient education and
electronic access to education materials
6. Coordination of Care through Patient
Engagement *
• >5% 2017 >10% 2018ff VDT (portal or API)
• >5% 2017 >25% 2018ff exchange secure
messages
• >5% patient-generated health data from non-
Inpatient or Emergency setting
7. Health Information Exchange (HIE) *
• >50% create and send Summary of Care (SOC)
electronically
• >40% SOC incorporation from other EHR
• >80% clinical information reconciliation
(meds, allergies, problems)
8. Public Health and Clinical Data Registry
Reporting **
• “Active engagement” with three options:
registration, testing & validation, production
• Six data types: immunizations, syndromic
surveillance, electronic case reporting, public
health registry, clinical data registry,
electronic reportable laboratory results
Final EP and EH Objectives and Measures for Stage 3 MU
2017 and Following
* Must report data on all three measures but only meet thresholds for two of three measures.
** Must choose four of six data types to report on for EH; three of six for EP
42

43. 43
Key Takeaways - Critical Success Factors
Governance and program
organization are critical to
success
Executive and clinical
sponsorship are essential
for decision making,
resource allocation and
barrier elimination
Identify and involve all
stakeholders
Use program and project
management
methodology
Share and leverage
leading practices between
sites
Monitor performance on
key measures
continuously
Focus on documentation
anticipating audits
Communicate,
communicate,
communicate!

44. 44
Name Email
Sandy Summers Sandy.Summers@DignityHealth.org
Contact Information