Now that CIOs have had a little time to study the details of the meaningful use final rule for electronic health record (EHR) incentives, their reaction remains largely positive.
One CIO who works with small critical access hospitals (CAHs) says the final rule demonstrates that the Office of the National Coordinator (ONC) for Health IT listened to rural voices.
In a note to members, Louis Wenzlow, CIO of the Rural Wisconsin Health Cooperative Information Technology Network in Sauk City, stressed that CAHs are now eligible for Medicaid incentives if they meet the 10 percent Medicaid utilization threshold. (The proposed rule excluded CAHs from participating in the Medicaid program.) They will receive incentives based on the Acute Care Hospital formula, which is a lump-sum payment that could come close to $1 million or more over a several-year period, he noted.
Wenzlow also wrote that changes to computerized physician order entry (CPOE) requirements should aid small hospitals. “Orders entered by ‘licensed professionals’ (even if they are not the ordering physician) will count toward the 30 percent,” he wrote. “This is huge, as it will allow registered nurses and pharmacists to enter physicians orders to meet the requirement,” he wrote. “Only medication orders will be counted. Emergency room orders will also now be counted.”
Wenzlow estimates that the changes between the proposed and final rule raise the percentage of rural hospitals that are likely to attain incentives from 30 percent to about 60 percent.
Mary Carroll Ford, vice president and CIO of 851-bed Lakeland (Florida) Regional Medical Center, agrees with Wenzlow that the shape of the final rule suggests ONC paid close attention to the comments it received. She also says one major impact is that the final rule suddenly makes the meaningful use movement real to others in her organization and will provide impetus to get moving on projects.
Ford thinks the menu approach is smart because it accommodates organizational or regional strengths and weaknesses. “I will sit down soon with our clinical advisory committee to determine the five optional objectives we will work on first.”
The CPOE requirement will be more manageable, she says, because it involves just medication orders, not all orders.
“The physicians can just do one order for each patient to get used to the work flow,” Ford adds. “That is a much more reasonable way to roll it out.”
Lynne Dunbrack, program director for provider/health payer research at Framingham, Mass.-based IDC Health Insights, echoes the mostly positive comments we have been hearing from other analysts, but she does express some concerns. For instance, if an organization hasn’t already started on CPOE, the 30 percent threshold is going to be difficult to implement in the next year or two because of both cultural and technological issues, she says.
Looking at the menu of optional objectives, Dunbrack believes CIOs will defer those things that do not fit their current workflows well. For instance, sending reminders to patients may be difficult if they don’t already have a secure communication channel with patients. The hand-off of summary records at transitions of care may also be a work-flow weak point that has technological, cultural and even legal issues to be worked through, she says.
Another concern involves certification. Vendors will now be scrambling to get certified, Dunbrack noted. What if an organization is using a clinical information system that is one release back from the vendor’s certified one? It might take them a year or more to migrate to the certified version, and therefore be eligible for incentive payments. “I think the image of all these providers and critical access hospitals suddenly receiving checks in the mail is probably overly optimistic,” she says.