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Meaningful Use HIM = Quality Informatics


Meaningful Use + HIM = Quality Informatics Phyllis A. Patrick, MBA, FACHE, CHC, CISM Phyllis A. Patrick & Associates LLC May 9, 2014 Quality Informatics the study ... – PowerPoint PPT presentation

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Title: Meaningful Use HIM = Quality Informatics

Meaningful Use HIM Quality Informatics
  • Phyllis A. Patrick, MBA, FACHE, CHC, CISM
  • Phyllis A. Patrick Associates LLC
  • May 9, 2014

  • Overview of the Meaningful Use Program
  • Key Elements of an Effective MU Program
  • Role of HIM in Meaningful Use
  • The Ultimate Goal Quality Informatics
  • Q A/Discussion

Overview of the Meaningful Use Incentive Program
  • CMS and ONC Strategic Objectives
  • Certification Basics
  • Regulatory Requirements
  • Federal and State Programs
  • The 3 Stages of Meaningful Use
  • Risks and Challenges for Hospitals and Providers
  • Security Risk Analysis The Weak Link what
    is required?

The Vision for Health Reform
  • Health Care will be
  • Patient-centered
  • Evidence-based
  • Prevention-oriented
  • Efficient
  • Equitable
  • Not investments in technology, but efforts to
    improve health of Americans and performance of
    their health care system.

CMS Goals
  • Improve quality, safety, and efficiency of health
    care and reduce health disparities
  • Engage patients and families
  • Improve care coordination
  • Improve population and public health, and
  • Ensure adequate privacy and security protections
    for personal health information.

Defining Meaningful Use
  • An EHR user must meet the following
  • Use of certified EHR technology in a meaningful
    manner (e.g. e-prescribing)
  • Use of certified EHR technology for electronic
    exchange of health information to improve quality
    of healthcare, such as promoting care
  • Use of certified EHR technology to submit
    Clinical Quality Measures (CQH) and other
    measures in a form manner specified by the
    Secretary of HHS

Benefits of EHRs
  • Complete and accurate information
  • Providers will know more about their patients and
    their health history before they walk into the
    exam room.
  • Better access to information
  • Facilitates greater access to the information
    providers need to diagnose health problems
    earlier and improve health outcomes of their
  • Information can be shared more easily among
    doctors, hospitals, and across systems, leading
    to better care coordination.
  • Patient empowerment
  • Patients will play a more active role in their
    health and in the health of their families.
  • Patients can receive electronic copies of their
    medical records and share their health
    information securely over the Internet with their
    families and others.

Federal Health Information Technology Strategic
Plan 2014 2018
Beyond Meaningful Use of Data
  • Quality Reporting
  • Research Secondary use of EHR data
  • Comparative Effectiveness Research
  • Comparing treatment outcomes in two or more
    groups taking different drugs ? this could negate
    requirement for large clinical trial recruitment
  • Platform for clinical trial recruitment ? use of
    clinical decision support alerts may increase
  • Increase sample sizes ? improve reliability and
    integrity of data
  • Recording of adverse events ? early
    identification of side effects not identified
    during clinical trials (integrating adverse event
    reporting into EHR workflow)

Facilitating Factors
  • Standards ? Interoperability
  • When EHR vendors were initially approached
    with the opportunity to add a new service for
    the research community, most of them figured out
    fairly rapidly that this was not a wise business
    decision. At that time, they realized that they
    would have to extract data and map them to every
    requested format, which varied by research study
    sponsor or, the EHR system would need to be
    configured differently for each research study or
    research sponsornot very feasible. In addition,
    there was a perception that the entire EHR would
    have to be validated to meet Good Clinical
    Practices (GCPs) and other regulations required
    of biopharmaceutical development companies such
    as 21CFR Part 11 in the U.S.another relatively
    impossible option.
  • R. D. Kush, Interoperability Review EHRs
    for Clinical Research, American Medical
    Informatics Association, Winter 2011-2012, Vol.
    2 No. 2.

Certification of EHRs
  • ONC and CMS post most-up-to-date list of EHR
    products used for attestation to the CMS EHR
    Incentive Program at
  • Dataset (April 2011 to present, updated monthly)
    intended for use by hospitals, physicians,
    researchers and other interested parties to
    explore and apply data in the context of the
    growing trends in Health IT adoption
  • Capability to analyze at State levels and to view
    monthly trends.

Certification of EHRs The Basics
  • Focus certification on Meaningful Use.
  • Leverage the certification process to improve
    progress on privacy, security, and
  • Improve the objectivity and transparency of the
    certification process.
  • Expand certification to include a range of
    software sources, e.g., open source,
    self-developed, etc.
  • Develop a certification transition (short-term to
  • Privacy and Security Consistent themes
    throughout regulations and guidance.

Privacy and Security Protection
  • Federal Health Information Technology Privacy
    Committee (HITPC) and Privacy and Security Tiger
    Team developed Stage 2 and Stage 3
    recommendations for the health outcome priority
    ensure adequate privacy and security
    protections for personal health information.

Regulatory Requirements
  • ARRA
  • HIPAA and Omnibus
  • ACA
  • EHR Incentive Programs Final Rule
  • HIT Initial Set of Standards, Implementation
    Specifications and Certification Criteria for EHR
    Technology Interim Final and Final Rules
  • Establishment of Temporary Certification Program
    for HIT Final Rule
  • Establishment of Permanent Certification Program
    for HIT Final Rule
  • Breach Notification Rule
  • HIPAA Privacy and Security Rules
  • Modifications to the HIPAA Privacy, Security, and
    Enforcement Rules under the HITECH Act Proposed
  • HIPAA Privacy Rule Accounting of Disclosures
    under the HITECH Act Proposed Rule (in limbo!)

Roots in HITECH
  • The Health Information Technology for Economic
    and Clinical Health (HITECH) Act provides the
    Department of Health Human Services (HHS) with
    the authority to establish programs to improve
    health care quality, safety, and efficiency
    through the promotion of health IT, including
    electronic health records and private and secure
    electronic health information exchange.

4 Key Regulations
  • Regulations define meaningful use (2)
  • Incentive Program for Electronic Health Records
    (issued by CMS) define minimum requirements
    that providers must meet through their use of
    certified EHR technology in order to qualify for
    payments for stages 1 and 2 of meaningful use.
  • Regulations identify technical capabilities
    required for certified EHR technology (2)
  • Standards and Certification Criteria for
    Electronic Health Records (issued by ONC)
    identify standards and certification criteria for
    the certification of EHR technology, so eligible
    professionals and hospitals may be assured that
    the systems they adopt are capable of performing
    the required functions.

Regulations and Statutes
  • American Recovery Reinvestment Act (February
  • Medicare Medicaid Electronic Health Record
    (EHR) Incentive Program Notice of Proposed
    Rulemaking (NPRM) and Final Rule (July 28, 2012)
  • Stage 2 Meaningful Use Final Rule (August 23,
  • Security Risk Analysis 45 CFR 164.308(a)(1)
    (April, 2005)
  • Health Information Technology for Economic and
    Clinical Health (HITECH) Law Interim Final Rule
    (February, 2009)
  • Omnibus Rule (January, 2013, Effective September
    23, 2013)

Implications of the Final Rule (EHR
Incentive Program)
  • Harmonizes MU criteria across CMS programs as
    much as possible
  • Closely links with ONC Certification and
    Standards Final Rules
  • Builds on recommendations of HIT Policy Committee
    and Public Commenters
  • Coordinates with existing CMS Quality Initiatives
  • Provides a platform that allows for staged
    implementation of EHRs over time

Key Players
  • CMS - Centers for Medicare Medicaid Services
  • Established EHR Incentive Program (formal rule
  • Rule provides parameters and requirements for
    Medicare Medicaid EHR Incentive Programs
  • ONC - The Office of the National Coordinator for
  • Resource to support adoption of Health
    Information Technology (HIT) and promotion of
    nationwide Health Information Exchange (HIE) to
    improve health care
  • OCR - Office for Civil Rights
  • Responsible for HIPAA Enforcement (Privacy

Other Key Players
  • Quality Reporting Groups
  • The Joint Commission hospital quality measures
  • Hospital Inpatient Quality Reporting (HIQR)
  • Physician Quality Reporting System (PQRS)
  • CMS Shared Savings Program
  • National Council for Quality Assurance (NCQA)
  • Others?

Incentive Money for Meaningful Use
  • Medicare EHR Program
  • Participation started FY 2011
  • EPs may receive up to 44,000 over 5 years
  • Must begin by 2012 to get maximum funds
  • Incentives for hospitals began in 2011 w/ 2
    million base payment
  • Medicare EPs, hospitals and CAHs who do not show
    meaningful use have payment decrease beginning
  • Medicaid EHR Program
  • Voluntarily offered by individual states
  • Began 2011 States on board 2012
  • EPs may receive up to 63,750 over 6 years
  • Incentives for hospitals began 2011
  • No payment adjustment for providers who do not
    show meaningful use

Eligibility Medicare Medicaid
  • The EHR Incentive Programs are available for
    Medicare and Medicaid eligible professionals.
  • There are two (2) programs a Medicaid EHR
    Incentive Program and a Medicare EHR Incentive
  • Although the two programs are similar in many
    ways, there are also some differences between
  • Eligible professionals can only participate in
    one of the programs. If an eligible professional
    chooses to participate in the Medicaid EHR
    Incentive Program, then she or he can participate
    in only one states incentive program in any
    given year.

Meaningful Use Stages
Clinical Transformation
  • MU represents the means of clinical
    transformation managing information for better
    care, safer care, more effective and efficient
  • Stages 1 3 of MU progress from capture of
    health information and reporting of QCM and
    public health data (Stage 1) to information
    exchange and decision support (Stage 2) to
    systematic health care improvement (Stage 3).

Key Elements of an Effective MU Program
  • Governance
  • Interdisciplinary Process
  • Program Goals
  • Financial Reporting and Reconciliation
  • Outcomes Reporting Plan for Quality Reporting
  • Documentation
  • Security Risk Analysis/Risk Management

  • Monitoring, tracking, and managing compliance
    with the various and ever-changing requirements
    requires a concentrated focus and effort.
  • A successful meaningful use program requires
    three foundational work streams
  • incentive program compliance
  • organization performance, and
  • electronic health record (EHR) enhancement
  • The Meaningful Use Program requires comprehensive
    coordination and oversight to ensure current
    compliance and to establish capabilities for
    future health reform initiatives.
  • Charter Statement is important.

Interdisciplinary Process
  • Senior leader as sponsor and champion.
  • This is not an IT initiative.
  • Clinical leadership is key.
  • Areas involved should include medical, nursing,
    and clinical staff ancillary services
    quality/performance improvement risk management
    legal services information security and privacy
    finance health information management practice
    managers, information technology and other key

What are appropriate roles for HIM professionals?
Consider adopting the following .
  • Seek knowledge. People who are resilient are
    always curious, excited about life, and wanting
    to know more. They embrace the unknown and want
    to feel more knowledgeable about the world.
  • The more you know, the more equipped you are to
    deal with challenges and to be able to vision
  • Ask questions!

Program Goals
  • Flow from the Charter and Governance Structure
  • Relate to organizational Mission, Vision, Values
  • Foundation in strategic plan, IT plans, quality
  • Outcomes reporting and plans for measures
    reporting alignment
  • Ongoing auditing and monitoring
  • Coordinating/directing activities for internal
    compliance audits
  • Managing preparation and responses to external
    compliance audits
  • Align MU improvement initiatives with current and
    future organizational quality initiatives.

Financial Reporting and Reconciliation
  • EHR technology is not critical to the delivery of
    patient services.
  • Incentive payments are similar to revenues
    derived from sources other than providing
    healthcare services.
  • How can management determine whether there is
    reasonable assurance that meaningful use has been
    or will be achieved for a particular period?
  • Set aside for contingency/pay-back?
  • HFMA Issues Paper (2011)
  • Contingency Model
  • IAS Grant Accounting Model

Outcomes Reporting/ Clinical Quality Measures
  • CMS selected CQMs to align with DHHS National
    Quality Strategy priorities for health care
    quality improvement.
  • CMS Quality Domains
  • Patient and Family Engagement
  • Patient Safety
  • Care Coordination
  • Population and Public Health
  • Efficient Use of Healthcare Resources
  • Clinical Processes/Effectiveness

Quality Professionals Need to be Involved
  • Stage 2 goals focus on ensuring that the
    meaningful use of EHRs supports the priorities of
    the National Quality Strategy.
  • Use of Health IT for continuous quality
    improvement at point of care
  • Exchange of information in a structured format
  • Health Information Exchange requirements
  • E-prescribing becomes more demanding
  • Structured lab results need to be incorporated
  • Electronic transmission of patient care summaries
    to support transitions in care across
    unaffiliated providers settings and disparate EHR

OIG Interest in MU
  • Early Assessment Finds that CMS Faces
    Obstacles in Overseeing the Medicare EHR
    Incentive Program
  • HHS, OIG, November 2012.
  • Included review of self-reported MU use of
    certified EHR technology.

OIGs Comments
  • CMS faces obstacles to overseeing the
    Medicare EHR incentive program that leave the
    program vulnerable to paying incentives to
    professionals and hospitals that do not fully
    meet the meaningful use requirements. CMS has
    not implemented strong prepayment safeguards, and
    its ability to safeguard incentive payments
    post-payment is also limited. (2012 Report)

OIGs 2014 Report
  • CMS and its contractors had adopted few
    program integrity practices specific to EHRs.
    Specifically, few contractors were reviewing EHRs
    differently from paper medical records. In
    addition, not all contractors reported being able
    to determine whether a provider had copied
    language or over-documented in a medical record.
    Finally, CMS had provided limited guidance to
    Medicare contractors on EHR fraud

Vendor Technology Stability
  • Vendors under increasing pressure to deliver
    changes for Stages 2 and 3.
  • Providers need to stay in contact with vendors
    and understand their delivery timelines and
  • Due diligence and documentation re. vendor
    challenges and any failures to meet criteria.
  • Providers should not rely on vendors to perform
    risk analysis or substantiate that all criteria
    are met.
  • Management, clinicians, IT, and others need to be
    on same page.

Additional Resources Are Needed
  • MU is an ongoing, dynamic PROGRAM, not just a
    source of funds.
  • This is not another IT project.
  • Dont assume that technology can lead to FTE
  • Support for MU will require additional resources.
    Key issues will include
  • Vendor management
  • Implementation of software changes and system
  • Infrastructure changes
  • Interface development and maintenance
  • Need for sound change management procedures
  • Interface with HIEs and other provider

Security Risk Analysis and Risk
Mitigation Meeting Privacy Security
The Weak Link HIPAA RA/RM Requirements
  • conduct an accurate and thorough analysis of
    the potential risks and vulnerabilities to the
    confidentiality, integrity, and availability of
    ePHI. Once have you completed the risk analysis,
    you must take any additional reasonable and
    appropriate steps to reduce identified risks to
    reasonable and appropriate levels. (45 CFR

Security in Stage 2
  • Core Objective 15
  • Protect electronic health information created or
    maintained by the certified EHR technology
    through the implementation of appropriate
    technical capabilities.
  • Note the preamble specifically addresses
    encryption/security of data stored in Certified
    EHR Technology, and notes that a review of the
    assessment must be conducted each EHR reporting
  • Expectation is that security will evolve and
    change as needs change.
  • Expectation of robust security.

Stage 1 vs. Stage 2
  • Objective Protect electronic health information
    created or maintained by the certified EHR
    technology through the implementation of
    appropriate technical capabilities.
  • Security Risk Analysis must be conducted during
    each reporting period for Stage 1, Stage 2, and
    Stage 3.

Measure Stage 1 vs. Stage 2
  • Stage 2 Eligible professionals (and hospitals)
    need to meet the same security risk analysis
    requirements as Stage 1, but must also address
    the encryption/security of data at rest.

Ensure Security Risk Analysis was conducted..
  • Perform or review existing Security Risk Analysis
    of your certified EHR technology
  • Do you have copies of your vendors security
  • Has testing been thorough and documented any
    potential security issues have been fixed?
  • Have you/vendor made any security updates (e.g.,
    updated certified EHR software)?
  • Have you/vendor corrected any security
    deficiencies (workflow, storage, etc.)?

Additional Precautions
  • Dont attest for EHR Incentive Program until you
    have conducted the security risk analysis (or
    reassessment) and developed a risk mitigation
    plan to correct any deficiencies identified
    during the risk analysis. You must implement the
    plan, which can be phased, but needs to be clear
    and documented.
  • Document changes/corrections in the security
  • Update policies as appropriate to reflect changes
    and improvements.
  • Communicate policies and changes.

Keep in mind.
  • When a provider attests to meaningful use, it is
    a legal statement that the provider has met the
    specific standards, including protecting
    electronic health information.

False Claim
  • Engaging in a conspiracy to defraud by the
    improper submission of a false claim
  • FCA strengthened by
  • Fraud Enforcement and Recovery Act (2009) -
    redefined obligation to include retention of
    any overpayments
  • Patient Protection and Affordable Care Act (2010)
    - a person need not have actual knowledge
    or specific intent to commit a violation
    Providers will not be able to successfully argue
    that they did not know.

Recoupment of Funds
  • Failure to meet one (1) of the criteria can
    result in recoupment of all payments.
  • Some providers incentive funds been recouped and
    some have self-disclosed and paid monies back.
  • Be aware CMS has noted that several providers
    have been referred for possible fraud
    investigations, through direct reports to CMS.

Potential Bumps in the Road
  • The Attestation Process
  • If you attest prior to actually meeting the
    meaningful use security requirement, you could
    increase your business liability for federal law
    violations and making a false claim. From this
    perspective, consider implementing multiple
    security measures as feasible, prior to
    attesting. The priority would be mitigating
    high-impact and high-likelihood risks.
  • ONC Guide to Privacy and Security of Health

Final Statement in Attestation
  • I certify that the foregoing information is
    true, accurate and complete. I understand that
    the Medicare/Medicaid EHR incentive program
    payment I requested will be paid from Federal
    Funds, that by filing this claim for Federal
    Funds, and the use of any false claims,
    statements, or documents, or the concealment of a
    material fact used to obtain Medicare/Medicaid
    EHR incentive program payment, may be prosecuted
    under Federal or State criminal laws and may also
    be subject to civil penalties.

Between You and Your Contractor
  • If during attestation, you or your EHR
    contractor answered yes that you were in
    compliance with this MU criteria without first
    ensuring complete compliance with the Security
    Rule Risk Analysis requirements, not only is your
    incentive payment at risk, but you also may be
    subject to liability under the Federal False
    Claims Act.

The MU Audit Program
  • The Basics
  • Federal and State Programs
  • 2014 and Beyond What can we Expect?
  • 45 CFR Section 164.308(a)(1)(ii)

Meaningful Use Audit Process
  • Pre- and post-payment audits (January 2013 ?)
  • Edit checks in EHR systems
  • Documentation audits
  • Source documents required
  • Appeals process (888-734-6433)
  • Comprehensive audits
  • Payment recoupment

CMS Audit Activity To Date
  • Figliozzi Company
  • Desk audits
  • Post payment audits for EPs and EHs
  • Pre payment audits for EPs
  • Candidate for audit after meeting MU for full
  • Turnaround time for audit results can vary
  • Extent of audit activity at the time
  • Degree to which your documentation submission is

Audit Request from
Documentation for MU Audits
Supporting Documentation
  • Required for pre- and post-payment audits
  • Must support meaningful use and clinical quality
    measure data that is submitted
  • All source material (paper and electronic) must
    be saved for at least 6 years from attestation
  • If using hospital cost report data, follow data
    retention policies and process
  • Documentation must support payment calculations
  • Reports must come directly from the certified EHR
  • Dont rely on vendor for documentation!

Additional Supporting Documentation
  • Primary documentation should include
  • Numerators and denominators used for the measures
  • Time period the report covers
  • Evidence to support that the report was generated
    for the eligible hospital, eligible provider
    (NPI, CCN, provider name, practice name)
  • Documentation that demonstrates how data was
    accumulated and calculated.

Source Documents
  • Audit logs
  • Screen shots
  • Letters received from public health agencies
  • Summary of data that supports the information
    entered during attestation

Good Documentation Practices
  • Maintain all documentation for at least 6 years.
  • Review all supporting documentation for
    attestations, CQMs, payment verification, etc.
    BEFORE any audit request.
  • If contractor was used for Attestation process,
    review supporting documentation on a regular
    basis. Ask questions. Make sure you have all

Good Documentation Practices (Contd)
  • Verify that incentive payments were accurate
    (possible over-payments or under-payments).
  • Make sure you have proxy permission from your EPs
    to attest on their behalf.

Future Audit Processes
  • Figliozzi current contract for 3 years (2012
  • Will CMS use another contractor for next phase?
  • Next phase will be more robust and comprehensive.
  • May be process oriented, include analysis of
    quality reporting, testing of EHR systems, etc.
  • MU is a dynamic, ongoing program and process!

Role of HIM in the Meaningful Use Program
Participation is key!
  • Governance Steering Committee and
    decision-making processes
  • Documentation Policies and Practices
    implementation and advisory roles
  • Security Risk Analysis/Mitigation requirements
    advocate and participant roles
  • Menu Set Criteria/Measure Selection for hospital
    and eligible professionals
  • Tracking requirements and regulatory changes
  • Knowledge of data collection, data aggregation,
    data integrity issues
  • Interface with and train clinicians
  • Clinical Quality Measures participation in
    strategy and working with Quality
    Officer/Performance Improvement group ? reporting
    and advisory

EHR A Platform for Quality
  • EHR Functionality is the beginning, not the
  • The quality of data and what providers do with
    the EHR is important and has to be carefully
    planned and vetted.
  • EHRs can be used to improve care.
  • When will we get there?
  • How do we get there?
  • Understanding the BIG Picture is key!

Quality Informatics
  • the study of use of information in
    understanding and improving the quality and
    safety of health care. It seeks to measure the
    quality of health care.

The Classic Quality Measurement Model
Donabedian, A., The 7 Pillars of Quality
Crossing the Quality Chasm, Institute of Medicine
Clinical Quality Measure Alignment
Quality Programs How many?
  • Hospital Inpatient Quality Reporting HIQR)
  • The Joint Commission
  • Physician Quality Reporting System (PQRS)
  • CMS Shared Savings Program
  • National Council for Quality Assurance (NCQA)
  • Childrens Health Insurance Program
    Reauthorization Act

CMS Goals and Plans for Alignment
  • Hospitals may voluntarily submit clinical quality
    measure data electronically, beginning in 2014.
  • CMS Goal to simultaneously satisfy quality
    reporting requirements for both Medicare EHR
    incentive program (MU) and Hospital Inpatient
    Quality Reporting programs.
  • Hospitals benefit
  • Collaboration among multiple teams and
  • May reduce costs (reductions in chart abstraction
  • Reduced regulatory reporting burden

Reporting for Eligible Professionals
  • For EPs, we proposed a set of 12 clinical
    quality measures beginning in 2014 that align
    with existing quality programs such as measures
    used for the Physician Quality Reporting System
    (PQRS), CMS Shared Savings Program, and National
    Council for Quality Assurance (NCQA) for medical
    home accreditation, as well as those proposed
    under Childrens Health Insurance Program
    Reauthorization Act.
  • For eligible hospitals and CAHs, the set of 24
    CQMs we proposed beginning in 2014 would align
    with the Hospital Inpatient Quality Reporting
    (HIQR) and the Joint Commissions hospital
    quality measures.

Harmonization of Quality Reporting
  • CMS goal is to harmonize all quality reporting
    programs with EHR electronic reporting.
  • In 2014 simultaneous reporting is voluntary. At
    some point (TBD), CMS will make this mandatory.
  • How are hospitals and physicians preparing???

Decisions Hospitals Must Make
  • When to begin to align CQM and MU reporting, i.e.
    in 2014 or continue to report measures separately
  • Separate reporting requires submission of 57 CQMs
    for calendar year via chart abstraction and 16
    CQMs for selected reporting period via CMS
    attestation portal for MU
  • Alignment of reporting between the 2 programs
  • EHR incentive program requires reporting for 1
    quarter of patient-level data for 16 CQMs
    electronically and Inpatient Quality Reporting
    CQMs requires electronic reporting of 57
    inpatient measures via chart abstraction
  • FY 2014 IPPS Final Rule, pages 50811-50819

Quality Reporting is a Strategic Decision
  • What resources and capabilities does the hospital
    have to align and report measures simultaneously?
  • What is the organizations strategy on quality
    reporting? Are the different reporting
    requirements centralized and coordinated?
  • How does data align across departments? How is
    data integrity addressed with quality reporting
  • Is the EHR capable of creating and submitting
    reports for the various requirements?
  • What is the organizations plan for simultaneous
    reporting - need to balance competing priorities
    and resources?
  • How do quality reporting, EHR development, and
    clinical priorities fit with the organizations
    overall strategic plans and goals?

How Can HIM Participate?
Q and A/Discussion
Security Privacy Culture
  • Phyllis A. Patrick, MBA, FACHE, CHC
  • Phyllis A. Patrick Associates LLC
  • 914-696-3622