Framework for Empowering Pathology in the Electronic Health Record

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

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

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

Regulatory Framework: ARRA

Pathology’s Two Challenges

Challenge #1 Suboptimal management of laboratory information in EHRs CPOE design and configuration issues Potential patient safety issues Hidden costs

Suboptimal Lab Data Handling in EHR This EHR report is garbled, I need to call the lab We don’t control the EHR, you’ll have to call IT

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

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

Poor CPOE Symptoms Incorrect, incomplete, inappropriate test orders Inefficient lab/provider operations Billing & compliance problems Pitfalls – future orders, duplicate handling, canceled orders

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

Challenge #2 Pathologists are “non-hospital based” (per CMS definition) eligible providers (EPs) for MU incentives and penalties Challenged by MU requirements to: o Use certified EHRs o Report specified objectives o Report clinical quality measures (CQMs)

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

Regulatory Relief Possible CMS considering criteria for relief from penalties for eligible providers that: 1.Lack face-to-face/telemedicine interaction with patients 2.Lack follow-up with patients 3.Lack control over availability of certified EHRs at their practices

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

What CAP is Doing Advocating for regulatory relief Seeking passage of H.R Developing white paper on best practices for lab data/transmission

Partner with Stakeholders

What You Can Do at Home Advocate for patients’ laboratory information in EHR Develop some expertise: o Intradepartmental o Institutional Raise awareness and provide domain expertise at institutional level

What You Can Do Here When you visit your Senators/Congressmen…. Ask them to support H.R. 4066!

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