While there is no shortcut to meaningful use, getting the fundamentals right is essential to smoothing the way to qualifying for incentives.
Though the Stage 1 attestation process for meaningful use (MU) incentives opened in April 2011, the number of hospitals that will attest in the early stages is likely to be underwhelming, according to at least two recent surveys. One, from the Ann Arbor, Mich.-based College of Health Information Management Executives (CHIME), found that fewer than one-third of responding healthcare CIOs expect to qualify by Sept. 30, 2011. A second, from the Chicago-based Healthcare Information and Management Systems Society (HIMSS), found that only 44 percent of hospitals thought they would be ready to qualify by May 2012.
That's disappointing, but not surprising. Understanding and meeting the MU requirements demands a significant effort. To qualify for incentives in Stage 1, “eligible hospitals” must meet 14 core measures, and then demonstrate they've also met five of the remaining 10 menu set measures. “Eligible professionals” (clinicians) must meet 15 core measures and five of 10 menu set measures. Ongoing clarifications from the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) have added to the challenge. One clarification, for example, requires that organizations “possess” the software for all of the menu items, even though they are only expected to “demonstrate” five of the 10 menu set measures.
MU ‘To Do’ List
Depending on where you are in your EHR implementation journey, this can be a several-month multidisciplinary effort that includes:
understanding the regulations and tracking the constant clarifications on an ongoing basis;
completing a “current state” analysis;
comparing “current state” to the desired “future state” as defined by the regulations and your own strategic goals;
completing a detailed data element mapping analysis to thoroughly identify the data requirements needed in the clinical workflow process (readers should make note of the intensity of data requirements within the clinical quality measures);
creating a plan to address the gap, including a detailed timeline, detailed technology requirements and specific clinical workflow changes;
executing the plan;
testing and validating that you've met the measure objectives (healthcare organizations can receive some guidance on this from a MU attestation calculator that CMS has published);
determining your 90-day measurement period for year one;
documenting your numerators and denominators for each measure requiring them;
identifying who from the organization will attest and when; and
completing the attestation online.
Despite such demands, we believe the number of organizations attesting is far lower than it should be. Having an electronic health record (EHR) in place that meets MU standards is quickly becoming a must-have for any clinical operation, so why not attain incentives to offset the costs? It can be done in a reasonable time period if hospitals and physician groups take some thoughtful initial steps.
ONE OF THE BIGGEST MISTAKES ORGANIZATIONS MAKE IS NOT FULLY UNDERSTANDING THE MU REQUIREMENTS, INCLUDING NOT TRACKING ALL THE UPDATES, CLARIFICATIONS, AND IMPLEMENTATION GUIDANCE THAT THE CMS AND ONC HAVE PUBLISHED ON THEIR WEBSITES.
CREATE A STRONG FOUNDATION
If you haven't done so already, an important first step is to model your financial opportunity in the MU EHR Incentive Program, based on your volume of Medicare and Medicaid patients. A simple approach is to use the instructions on the CMS Tip Sheets for Medicare and Medicaid to calculate your potential return. A clear, realistic picture can help you: first, understand the value proposition for your organization's MU project; second, engage in a more precise budgeting process; and third, confidently balance MU with other competing priorities.
That balance is critical. Like most hospitals and health systems, you're probably already contending with multiple strategic considerations that range from deciding whether to apply for the CMS Medicare Shared Savings Program to incorporating ICD-10 coding and weighing merger and acquisition opportunities. Those competing priorities could cause you to allocate inadequate resources for your MU project; the resulting hasty implementation might make short-term financial sense, but may not address key patient safety issues and could put your future EHR incentives (Stages 2 and 3) at risk.
In contrast, designating MU as a strategic project and placing it in the context of overall strategic planning can help ensure there are enough resources to plan, design, implement, and foster clinical adoption of a system that meets both the MU measures and your organization's needs.
An important next step is to create a dedicated program management structure with clearly defined roles and responsibilities-some exclusively for MU, others integrated into existing clinical structure-and to begin creating the project plan. One effective component of the plan is to engage your government affairs and compliance departments to take leadership roles in understanding the regulations, delivering the needed MU documentation, and tracking the updated guidance from ONC and CMS using the published FAQs.