How to Fast-Track Your Meaningful Use Effort

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.

In addition, the program management team should collaborate as much as possible with: your EHR vendor; other hospitals and health systems, especially those who use the same EHR vendor; consultants; and health information technology (HIT) organizations like the American Medical Informatics Association (AMIA), CHIME, and HIMSS. This enables your team to benchmark what's possible and avoid reinventing the wheel.

Finally, complement the program management structure with a strong communication plan that engages the entire organization and helps people understand what the MU program is and how it's tied to your existing strategic mission, vision, and goals. If your employees have a clear sense of MU's strategic, financial-and, especially, clinical and patient safety value-they are more likely to engage in the activities needed to achieve the incentives. Seeing the link will help eliminate concerns that the MU program is only about the incentive money and is out of context of the organization's strategic plan.

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.

Once these basic building blocks are in place, you can turn your attention to two near-term challenges for Stage 1 attestation: first, gauging and closing the gap needed to attain the incentives and, second, simultaneously assessing how you will work with existing or prospective EHR vendors.

GAUGE AND CLOSE THE GAP

Perhaps one of the biggest mistakes organizations make is in 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. The result is that many organizations lack clarity on the measures and underestimate what they need to do moving ahead.

One way to fully understand the MU requirements is to look at each objective measure across four dimensions, and then look at the multiple data points within each dimension. The four dimensions are:

• Understand how to calculate “the numerator and denominator” for each objective. On its website, CMS explains this by dividing the calculation into two groups: “one where the denominator is based on unique patients seen or admitted during the EHR reporting period, regardless of whether their records are maintained using certified EHR technology; and one where the objective is not relevant to all patients either due to limitations (e.g., recording tobacco use for all patients 13 and older) or because the action related to the objective is not relevant (e.g., transmitting prescriptions electronically and for whom the denominator is based on actions related to patients whose records are maintained using certified EHR technology.)” Some objectives do not require a numerator and denominator, but are “Yes/No” or “perform one test” measures.

• Meet the objective using certified EHR software with a process acceptable to CMS. According to CMS, “In most cases, an eligible professional or eligible hospital is not limited to demonstrating meaningful use to the exact way in which the Complete EHR or EHR Module was tested and certified. As long as an eligible professional or eligible hospital uses the certified Complete EHR or certified EHR Module's capabilities and, where applicable, the associated standard(s) and implementation specifications that correlate with the respective meaningful use objective and measure, they can successfully demonstrate meaningful use even if their exact method differs from the way in which the Complete EHR or EHR Module was tested and certified.”

• Adhere to the data and technical standards defined for the objective. The ONC has issued reference grids that show each measure and objective and their corresponding data and technical standards. While you are not required to demonstrate adherence to the data and technical standards during Stage 1, they offer important guidance-and demonstration may be required for Stages 2 and 3. Therefore, it makes sense to do everything you can to adhere to these standards as soon as possible. CMS has issued one- to two-page specification sheets for each measure that are designed to assist you in demonstrating meaningful use successfully and to help you understand the specific requirements of each objective.

• Capture the data elements required to achieve the objective and report those elements from the EHR with your vendor-certified reporting logic. The goal is for data capture to occur in the EHR, in real-time, during the healthcare process.

Important Dates for Meaningful Use

November 30, 2011: Last day for eligible hospitals and critical access hospitals to register and attest to receive an Incentive Payment for federal fiscal year 2011.

December 31, 2011: Reporting year ends for eligible professionals. Expected timeframe for CMS to publish the Stage 2 NPRM for public comment.

February 29, 2012: Last day for eligible professionals to register and attest to receive an Incentive Payment for calendar year (CY) 2011.