INDUSTRY-EXCLUSIVE REPORT: Looking at an Avalanche of Deadlines and Timelines in Healthcare

They’re around how to avoid penalties in 2015, and all the requirements you have to meet. The other is that  by October 2013 (for the year 2014), you have to have in place an information system certified for the 2014 requirements, the new requirements that have just been published in draft. And the certification requirements are not tied to stages; they’re tied to dates. So if you started in 2011, you’ll be at Stage 2 in 2013; if not, you’ll still be at Stage 1; but the system has to be certified against the new 2014 requirements, and that starts October 1, 2013.

It’s very hard to keep this straight in one’s mind, isn’t it?

Yes, it is. And remember that the year runs from January to January for doctors, but begins on October 1 of the prior year, for hospitals. So when they think about this idea that they have to have a system certified by 2014—it’s been in the law all along, but since the requirements are new—there are new requirements—and the systems will need to be certified, even if there are no changes in requirements. That says that pretty much every hospital in the country will have to undergo an upgrade of their system.

Remember, you have to be a meaningful user of a certified system. And the vendors have gotten their systems certified (or self-developed products) against Stage 1. But that whole concept of Stage 1 has gone away; now they’re referring to 2011. So if you have a 2011-certified system, that runs through 2013. But starting the next year, you have to have a 2014-certified system that meets all the new requirements and standards and has all the new capabilities. So that means that every hospital will have to have its system certified for those requirements by October 1, 2013, to be a meaningful user. Now, there are exemptions in the requirements. If it’s a future-stage requirement and you’re still in Stage 1, your system doesn’t have to be certified for that, but there are a lot of changes in the core requirements that mean that no matter what you buy has to have a 2014 certification.

The 2011 certification will be no good after 2013; and what’s more, the certification requirements are different enough that even if you’re still in Stage 1, you’ll have to make changes. That means that everybody’s going to have to have a newly upgraded system. And what’s unknown is how vendors will react; they may decide they’ll only update some of the current systems out in the field, to the new certification.

I looked at this initially and said, gee, those requirements aren’t all that different; and these are things that people know how to do, like e-prescribing in the hospital; and maybe the hospital systems don’t have it, but they could develop it. The thing is that I don’t think the amount of engineering and new product development is insurmountable; it’s the implementation part that will just be huge, because of the fact that every single hospital has to have this updated system, if they want to be a meaningful user. And by the way, you can’t have anything certified yet, because the requirements won’t be out until this summer.

Will vendors be challenged to move forward in time?

I think they’ll have problems getting all their customers to a 2014-certified system in time; I do think that will be a major challenge for people. So what if the requirements are out this summer, which they promised? That’s the summer of 2012. They need all these systems in place, in their client base, one year later, implemented. Because the hospitals have to be using them.

How big will that upgrading task be? It’s hard to envision what the sense of scale will be.

I don’t think the upgrading is massive. But small upgrades are a challenge when they’re brought across an entire mass of hospitals that have different tweaks and customizations, and may already be behind in terms of upgrades. And some people may be stuck, in that the system they’re using isn’t going to be upgraded by their vendor to the new 2014 specifications. What do they do? They can self-certify, or buy a new system.

So if you’re a hospital with an outdated version of your vendor’s EHR product, you could be faced with a situation where your vendor is going to abandon the version you  have, and you could be faced with a fully new implementation right now?

Yes. And you don’t want to tell people they’ll need a huge upgrade, too far in advance, because that would be difficult; but I just think that nobody thought about the trouble that would occur with the 2014 system requirements. And it’s not new news; it’s just that we weren’t really paying attention, and people didn’t really understand that the requirements would be changed. And they are going to be changed; for instance, you have to code your new problem list in SNOMED as opposed to in ICD-9. And that will be one of the 2014 requirements. And that affects everyone.

The irony is that the National Library of Medicine is working on a translation between SNOMED and ICD-10, which now won’t be implemented as early as had been expected. And they’ve greatly increased the amount of information that has to be transmitted and that has to be made available for sharing with patients.

So the amount of work that has to be accomplished in a short time is much more remarkable than people realized?