Cathy Thomas Hess, BSN, RN, CWOCN, is President and Director of Clinical Operations, Wound Care Strategies Inc (WCS), Harrisburg, Pennsylvania. WCS focuses on clinical operational, regulatory, and compliance/auditing aspects of skin and wound care in all healthcare settings. Please address correspondence to Cathy Thomas Hess, BSN, RN, CWOCN, 4080 Deer Run Court, Suite 1114, Harrisburg, PA 17112; e-mail: firstname.lastname@example.org
In my previous column titled "Checklists for Compliance," I discussed how Dr Atul Gwande demonstrated that development of well-designed checklists can improve outcomes. I further discussed that there are many checklists that could be created as written guides to assist your team in meeting key steps for compliance. These key steps begin to detail the workflow necessary to create structure for defined goals.
Let's think about a common goal that all healthcare professionals need to be meeting in the future, namely, incorporating the use of electronic medical records (EMRs).
The HITECH provision of the American Recovery and Reinvestment Act of 2009 provides billions of dollars in incentives for the adoption and use of Health Information Technology by Medicare and Medicaid providers over the next 10 years. For these eligible providers (EPs) and hospitals to receive the financial incentives set forth, they must achieve "meaningful use" of an EMR. The meaningful use requirements are grouped into 3 stages:
* Stage 1 focuses on capturing data
* Stage 2 focuses on reporting health information and tracking of defined clinical data sets
* Stage 3 focuses on improving performance and health outcomes.
This information is available at http://healthit.hhs.gov/portal/server.pt.
It is critical that healthcare providers now begin to develop the tools necessary to meet the regulatory criteria for their EMR. They also must understand the essential information and the measure of use necessary to demonstrate in Stage 1 to receive the incentive payments. For Stage 1, which begins in 2011, the Centers for Medicare & Medicaid Services (CMS) propose 25 objectives/measures for EPs and 23 objectives/measures for eligible hospitals that must be met to be deemed a meaningful electronic health record (EHR) user.
Perhaps a quick checklist would be helpful to assist in beginning to understand the criteria necessary to incorporate into the Stage 1 criteria. From this checklist, it becomes your responsibility to further understand the EP's and hospital's responsibility to be in compliance with these measures. The requirements for your checklist include
* use of computerized provider order entry for all orders
* implementation of drug-drug, drug-allergy, drug-formulary checks
* maintaining an up-to-date problem list of current and active diagnoses based on the International Classification of Diseases, Ninth Revision, Clinical Modification or Systematized Nomenclature of Medicine Clinical Terms
* generating and transmitting permissible prescriptions electronically
* maintaining active medication list
* maintaining active medication allergy list
* recording demographics including preferred language, insurance type, gender, race, and ethnicity
* recording advanced directives
* recording vital signs including height, weight, and blood pressure and calculating and displaying body mass index
* recording smoking status
* incorporating laboratory test results into EHR as structured data
* generating a list of patients with specific conditions to use for quality improvement, reduction of disparities, and outreach
* reporting quality measures to the CMS and states
* sending reminders to patients for preventive and follow-up care
* implementing clinical decision support rules related to clinical priority and track compliance
* checking insurance eligibility
* submitting claims electronically
* providing patient with his/her health information upon request, including laboratory results, problem list, medication lists, or allergies
* providing access to clinical summaries
* performing medication reconciliation
* providing summary records at transition of care
* submitting electronic data to immunization registries when required
* submitting reportable laboratory results
* submitting electronic syndromic surveillance data
* complying with Health Insurance Portability and Accountability Act privacy and security rules.
For a full explanation of the necessary criteria and its components, see http://edocket.access.gpo.gov/2010/E9-31216.htm specifically Table 1: Certification Criteria beginning on page 2025.
Keeping your finger on the pulse of clinical and regulatory changes for documentation requirements can be a daunting task. However, this is one task that everyone needs to stay abreast for the benefit of their (wound care) business. Designing a checklist to maintain compliance for this task may be one way to structure the oversight needed to meet expectations.