Arriving at Meaningful Use Attestation: Getting there is Half the Fun

[Anita Karcz]

Know the Right Math... and Choose the Right Path

Enhanced patient care, streamlined CMS quality reporting, smoother processes, incentive payments…these are among the rewards awaiting you at the elusive end of the Meaningful Use rainbow. But to realize them, you need to plan with a more mundane destination in mind — successful attestation. Without accomplishing this, you won’t achieve any of the program’s higher level benefits.

Although CMS has created a serviceable roadmap, hospitals still have many decisions to make along their MU journey including negotiating hairpin turns in complex regulatory requirements. They also need to understand the complex calculations needed for CQM reporting.

The first step is getting familiar with the MU program overall and reading through the specific requirements on a very granular basis. Unfortunately, there are no shortcuts. Summaries and comments help, but they are no substitute for reading through hundreds of pages of ever-changing rules and regulations.

MU Math: When attestation involves a measure, hospitals must show that an appropriate proportion of cases in the population have met the MU Objectives. This involves creating a fraction with the overall qualifying patient population as the denominator and patients meeting the Objective as the numerator. That fraction then becomes a percentage that must reach the mandated threshold for successful attestation.

CMS gives hospitals a little room to play with by offering a choice between two different population groups. The Observation Services Method includes patients admitted directly to inpatient departments, presenting to the ED (emergency department) and subsequently admitted and treated in the ED with observation services. The All ED Method adds patients treated and discharged directly from the ED to the observation population.

You cannot switch between groups — the same population must be used across all core and menu data. Depending on the specific procedures implemented in your ED, the figures you report for a particular Objective can vary dramatically based on population choice. For example, if CPOE is implemented both in the ED and across the hospital, compliance rate may be high in the ED because of a limited number of physicians using CPOE. In that case, the All ED Method will boost this measure by the higher compliance rate from the ED blended with a lower rate throughout the rest of the hospital. However, by choosing this patient group, if at the same time ED doesn’t capture and document smoking status or height consistently, you may fall below the threshold on these measures where you would have passed with the Observation population.

Before you choose, carefully examine which data gathering procedures are conducted in the ED only as well as those conducted house-wide and project which population method will be best for you. This analysis is well worth the time and effort. While meeting all core objectives is mandatory, menu objectives offer some choice, and considering these in the context of the two possible Population Groups as well as your hospital’s strengths and weaknesses can put you well along the route to successful attestation.

Unfortunately, it doesn’t get easier from here. Keep in mind that each CQM objective involves an array of exclusions and inclusions for both numerators and denominators that can dramatically change your results. CMS is seeking to match the appropriate patient population accurately with care guidelines by adding greater clinical information about the patient and medical situation into the calculation. But the result is that data elements from various EHR modules need to be reconciled to calculate the appropriate data, often for both the numerator and denominator.
Another point of decision – how will care that crosses departmental boundaries be documented if the same action is being chronicled in multiple EHR fields? Specifically, which entry will be counted in the MU report? Analyze this carefully because the decision may have multiple unforeseen repercussions. And once the decision has been made to use one data element field over another – document the decision so that it is recorded and available for reference in the event of an audit.

Don’t overlook cases known as UTD's (unable to determines), which, because of insufficient information — just one small seemingly unimportant missing field – or an improper code, do not clearly fit in your numerator, denominator or population. You will need to develop a system to root out these data errors and to correct them for MU compliant calculations.

How did your hospital make decisions on Population Groups, or Menu Objectives? Have you confronted UTD problems? Share your experience here.

 Anita Karcz, MD is the Chief Medical Officer at IHM Services