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• Framework for Empowering Pathology in the
  Electronic Health Record

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• Walter H. Henricks, MD, FCAP, The Cleveland
  Clinic Foundation
• Jodi G. Daniel, JD, MPH, Office of the National
  Coordinator for Health Information Technology

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• Walter H. Henricks, MD, FCAP
• Framework for Empowering Pathology in the EHR
• May 8, 2012

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Objectives

• Review HIT Regulatory Framework
• Discuss Two Regulatory Challenges Policy
  Solutions
• Note What CAP Can Do What You Can Do

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Regulatory Framework ARRA
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Pathologys Two Challenges
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Challenge 1

• Suboptimal management of laboratory information
  in EHRs
• CPOE design and configurationissues

• Potential patient safety issues
• Hidden costs

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Suboptimal Lab Data Handling in EHR
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Example Garbled PAP report in EHR

• Example of unpublicized nonstandard view of Pap
  smear result in EHR garbled text
• Not widely used was not known to lab at time of
  interface validation

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Lab Data Problem Symptoms

• Reference ranges, comments, footnotes
• Abnormal result flags, preliminary reporting and
  updates
• Improper handling of
• Corrected results
• Unsolicited results
• Reflex tests
• Performing lab name address

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Poor CPOE Symptoms

• Incorrect, incomplete, inappropriate test orders
• Inefficient lab/provider operations
• Billing compliance problems
• Pitfalls future orders, duplicate handling,
  canceled orders

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Policy Initiatives CAP

• Has submitted extensive comments on ONC Stage 2
  (2014) Standards Certification Proposed rule
• Need for FULL testing of pending laboratory
  reporting guide before implementation
• Need for laboratory data/vocabulary integrity as
  it moves throughout healthcare system
• Is working for pathologist role as laboratory
  data stewards in EHR environment
• Developing white paper
• Desires to partner with ONC and others on
  solutions
• e.g. domain expertise for standards and/or
  certification criteria

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Challenge 2

• Pathologists are non-hospital based (per CMS
  definition) eligible providers (EPs) for MU
  incentives and penalties
• Challenged by MU requirements to
• Use certified EHRs
• Report specified objectives
• Report clinical quality measures (CQMs)

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Incentive/Penalty Rule Challenges

• Certified EHRs Pathologists do not practice in
  EHRs
• Report certain objectives Objectives not
  applicable to pathology practice (written for
  office-based providers)
• CQMs Not applicable to pathology practice

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Regulatory Relief Possible

• CMS considering criteria for relief from
  penalties for eligible providers that
• Lack face-to-face/telemedicine interaction with
  patients
• Lack follow-up with patients
• Lack control over availability of certified EHRs
  at their practices

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Legislative Solution on the Table

• H.R. 4066, The Health Information Technology
  Reform Act introduced by Rep. Tom Price MD
  (R-GA-6)
• Removes pathologists from eligibility for MU
  incentives or payment adjustments
• Penalty relief would be permanent

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What CAP is Doing

• Advocating for regulatory relief
• Seeking passage of H.R. 4066
• Developing white paper on best practices for lab
  data/transmission

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Partner with Stakeholders
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What You Can Do at Home

• Advocate for patients laboratory information in
  EHR
• Develop some expertise
• Intradepartmental
• Institutional
• Raise awareness and provide domain expertise at
  institutional level

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What You Can Do Here

• When you visit your Senators/Congressmen.
• Ask them to support H.R. 4066!

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Summary

• ARRA hastening EHR adoption
• CAP working to advance HIT and protect
  pathologists
• You have a role in DC and at home
• Constructive dialogue with policymakers other
  stakeholders to continue

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