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A Health IT Auditor on the Two Big Obstacles in MU Stage 2

March 9, 2015
by Gabriel Perna
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When it comes to meaningful use, it’s hard for healthcare organizations to determine if they are truly ready to attest.

That’s where people like Erik Dahl come into play. Dahl is an IT audit director at Chan Healthcare, a Clayton, Mo., a firm that specializes in healthcare organizational audits and is a subsidiary of Crowe Horwath LLP, a public accounting and consulting firm. Administrators hire his company to verify they’ve hit on all required meaningful use measures properly, before the government does the same thing.

For this reason, Dahl has unique insight as to the readiness of providers for meaningful use Stage 2. Dahl recently spoke with Healthcare Informatics Senior Editor Gabriel Perna on meaningful use Stage 2 readiness, the recent announcement from the Centers for Medicare and Medicaid Services (CMS) to extend the deadline for attestation, and other topics on the controversial program. Below are excerpts from their discussion.

Plain and simple, are healthcare provider organizations ready for meaningful use Stage 2 or not?

It’s kind of a mix. Some of our clients were able to comfortably attest to meaningful use Stage 2. Others did end up using the flexibility rule by attesting to Stage 1 in lieu of Stage 2, given the challenges and delays in having the certified products available and installed in enough time to actually get their workflows and clinical processes in place to meet the new Stage 2 measures.

Looking at the key challenges, many have been associated with two of the measures. The first has been the summary of care measures—providing the summary of care documents electronically. The other has been around implementation of patient portals, getting the patent engagement levels up to meet that five percent threshold. That takes some strategy and planning. It takes time to get those processes in place.

What was your reaction to the announcement from CMS recently about extending the deadline? Will this be a major help to eligible providers (EPs) or a minor one?

As far as extending the deadline for the attestation, I think it will help a little bit. It gives you a little bit more time to scrutinize your data and prepare for attestations. One of the key things that we’ll look for when we look at governance is the sustainment process. Have you truly organized your documentation? Have you maintained your documentation you’ve used to do attestations? All of these are important to be prepared for down-the-road, subsequent audits. That will give you a little bit more time. Now, a couple weeks obviously it doesn’t the change reporting period. If you weren’t a meaningful user, it won’t help you from that perspective. It will help you get prepared and organized and make sure you’re comfortable with data. The bigger thing we’re expecting to see the announcement that it will be 90-day reporting this year instead 365-day. That will be the bigger help.  

It seems as if CMS is finally listening to providers when it comes to adjusting the difficulties of Stage 2, are they making the right move? Are they caving?

I don’t see it as caving. I think they’re really trying to balance moving the healthcare industry forward through interoperability with also making it achievable. That has been a challenge to balance. It’s important to recognize that there are those challenges. They are kind of taking a step back and reevaluating the program to see how they can make it more effective, to support the provider communities in a way that makes it achievable. Obviously, interoperability has been one of the key challenges for Stage 2.

For those attesting to Stage 2, what should be their focus right now?

It depends on where they are in their cycle. If you are attesting to Stage 2, you should really be planning on attesting to a 365-reporting period. Hopefully, you have your 2014 code implemented. If the change does occur and that does revert to a 90-day reporting period, that might make it achievable for providers that have only recently implemented their 2014 code or maybe are implementing it now. An important piece to me is having those governance structures over your program, where you are monitoring progress on your compliance level for each of those requirements. I’d recommend that be some kind of monthly process. The key part is making sure your teams and responsibilities are tightly defined to make sure you are not slipping on any of those measures over the course of the 365-day period leading up to attestation. One of the key challenges if you’re not up to that five percent on patient engagement is coming up with strategies and plans for meeting that. Many providers are really beginning that process of communication at the point of administration, and not waiting until discharge, getting registered while they are still in the hospital.

Can you reach that five-percent threshold this late in the game?

If you are behind, I’d say you should continue to keep working towards that goal. If the change does occur from a 365-day reporting period down to a 90-day and you continue to work on it between now and then…you may find that change makes you be successful.

What are you predictions for Stage 3?