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One Expert Looks at Attestation

April 19, 2011
by Mark Hagland
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One day after the federal Centers for Medicare and Medicaid Services (CMS) opened its website for attestation from hospital organizations and physicians who have fulfilled Stage 1 meaningful use requirements under the federal Health Information Technology for Economic and Clinical Health (HITECH) Act, a small number of healthcare CIOs have already electronically attested.

But is earlier automatically better? Not necessarily, says Mitch Morris, national leader, health IT, for the New York-based Deloitte Consulting. The Los Angeles-based Morris spoke with HCI Editor-in-Chief Mark Hagland regarding the potential pluses and minuses of early versus not-so-early attestation for Stage 1 of meaningful use. Below are excerpts from that interview.

What is your sense of how many organizations might attest within the first couple of weeks?
I think it will be somewhat limited. Those that have achieved Stage 1 as of today are still a minority of the total. And we’ve been counseling our clients that if you’re a hospital, you can begin to attest in 2011, 2012, or 2013, and you can wait to attest that long and still get the same amount of money. In contrast, eligible physicians must attest by 2012 to get the full amount.

Mitch Morris

But hospitals would obviously have to be working forward, regardless of whether they attest early or not, right?
Exactly. And here’s the deal: we don’t really know what’s in Stage 2. And the clock is ticking. And by 2013, you absolutely must attest to Stage 2, and since we don’t know what’s in Stage 2, there’s a risk in attesting to Stage 1 early. On the one hand, by delaying attestation, you wouldn’t be gaining the interest on the money you’d be getting otherwise. But by next year this time, we will have known well before then what’s in Stage 2. One thing we know about Stage 2 is that, while with Stage 1 there was a 90-day window of measurement, with Stage 2, there’s a one-year window of measurement. So here’s the bad scenario: you attest to Stage 1, but fall behind what will be required in Stage 2, since we don’t know exactly what’s in it right now. So there are some risks to beginning now, because once you start your timer, you can’t take a year off.

But some are saying that organizations should be moving ahead anyway based on what they preliminarily know about the Stage 2 requirements.
I absolutely agree, everyone should be moving forward and preparing as best they can for Stage 2. But what I’m saying is that they may not want to attest right now because of the risk, since they’ll still be attesting in Stage 2. Waiting a year, you lose the opportunity to immediately get the money; but you could potentially be better prepared for Stage 2. This assumes, though, that you’re working full-speed ahead the whole time; you’re not just sitting around.

But couldn’t the fact of holding back on attestation right now inadvertently send a signal within your organization that you’re not really serious about this as a CIO?
It could, but failing to achieve meaningful use in Stage 2 because you went ahead too quickly could be even worse. The point to the readers is that you have a choice. If your program is rock-solid and you know you’ve got it nailed, do it now. If you have concerns about clinical adoption, how to get the affiliated physicians on board, and whether or not you’re going to have a high enough level of CPOE adoption, then I would advise that you continue to go full-steam ahead, but you may want to wait to actually notify the federal government.

What are you seeing out in the industry right now, in terms of preparedness?
It’s all over the board; we’re seeing a lot of variability still. Pretty much every hospital has got a program going; but it’s amazing how some well-known hospital organizations are just now choosing a core clinical vendor, and still don’t have a contract yet. And some of them will be hard-pressed to meet meaningful use in time.

Will that be true of most all of those that haven’t already begun implementation?
I would say it will be a significant challenge if you’re just signing a contract today. I’m not saying it can’t be done; but it will be challenging. There are a number of organizations that had chosen a vendor years ago and for a variety of reasons, were not entirely successful with them. In some cases, it will be the real or perceived shortcomings of the software; but in other cases, it will be various organizational challenges. There are examples in our industry of somewhat-old, stodgy software doing well in organizations.

So the take-home lesson from that is, be very careful managing the clinical adoption timelines. And one thing that exists in pretty much in all non-profit organizations is the need to build a consensus around anything before moving forward. And you can’t do an implementation in 18-24 months, which is what we’re talking about here, unless you can be nimble enough to be successful. And we’re involved in a number of rapid implementations with clients right now.