Attesting to meaningful use (MU) Stages 1 and 2 is no small feat, but is vital nonetheless to a healthcare organization’s immediate and long-term success. The Health Information Technology for Economic and Clinical Health (HITECH) Act is rapidly transforming how people access their records and make decisions that directly affect their care, putting more control into the patients’ hands. As such, every healthcare provider faces different challenges in meeting meaningful use of an electronic health record (EHR), whether it’s attesting to Stage 1 or Stage 2.
To help with some of these concerns, Beacon Partners, a Weymouth, Mass.-based consulting firm, aims to keep providers up-to-date regarding best practices and the Centers for Medicare & Medicaid Services (CMS)’ certification and reporting requirements. Bruce Eckert, national practice director, strategic advisory group at Beacon, recently spoke with Healthcare Informatics about the challenges his clients face when it comes to MU, his overall thoughts on the program, strategies for providers, and trends he is seeing from the industry as a whole. Below are excerpts from that interview.
What are the biggest challenges your clients are having when it comes to attesting to MU?
Our clients run the gamut from very high-performing achievers to those who are behind in terms of adopting, so we are seeing a variety of things. But mostly, everyone who is struggling is having a difficult time understanding the nuances of the regulations, so we are doing a lot of work helping clients understand the trickier parts of that. An example of this is the changes to Stage 1 that are now in place for 2014. There is an assumption that not much is changing, and on the surface it looks that way, but embedded in the changes are a couple of significant items that deal with the patient engagement view/download/transmit requirement. Clients need to have the Direct program in place, and that right there is a project of some significance that is kind of hidden in the requirements.
Another challenge that we are dealing with quite regularly is computerized provider order entry (CPOE). What are the circumstances where the order that’s not entered by a physician can be counted as CPOE? There isn’t a cut-and-dried answer, because it all depends on a particular organization’s practices, policies, and state laws.
At the moment, we are also working with clients on various certification problems. The slowness of vendors getting the 2014 certification in place is causing more problems than many people expected, and there are a number of strategies to deal with that, ranging from hardship exemption applications to creative deployment of departmental systems to work around certification issues. We do make ourselves available to our clients on an as-needed basis to research questions for them and give them our direction and counsel on how they should approach.
Provider organizations have been pressing for more flexibility when it comes to MU. What are your thoughts on that?
For hospitals, we have advanced to the overall level of automation pretty significantly in the last few years. Ten years ago, a hospital doing CPOE was the rarity; now, the opposite is true. So there is a new standard, and with that come new expectations. A lot of that has to do with the MU program. My observation is that the physician market is a lot foggier—the incentive program does not have the same empowered influence and drive as we see on the hospital side. Many physicians have done well with it for sure, but the problems people are pointing out are primarily on the physician side.
And do you foresee a Stage 2 delay?
I don’t think there will be any delay in Stage 2; CMS has made that fairly clear. What we’re seeing is what Dr. Farzad Mostashari had predicted, which is flexibility in the hardship exemption requirements. So I think that’s how CMS is dealing with it—those who have a situation that challenges their ability to do MU will get some consideration.
Will the updated hardship exemptions make a significant difference for providers?
It can make a difference, but providers need to be realistic about what the opportunity is there. If it’s truly a certification problem due to the vendors’ release of their certified version making it virtually impossible to attest, you will get a break. We have filed some of these on behalf of our clients, and usually, either the EHR doesn’t have a certification yet, or the certified version hasn’t been released by the vendor yet (or it was released with such a short implementation timeframe left).
That being said, there is a little confusion out there in the user community. The hardship exemptions that were announced a month ago and due on March 31, 2014 apply to the 2015 payment year, meaning they apply to the 2013 attestation year. So there were not many cases where the exemptions came into play, and CMS will soon be publishing new hardship exemptions for the 2014 attestation year and 2016 payment year. But I think they have given every signal that they will be open to providers making their cases. For example, if my vendor is certified, and I received the certified version 30 days before the start of my reporting period, it would be very difficult to meet the requirement.
What are some of the things you see provider organizations doing wrong in the MU program?
I’ve seen a few things that providers have done in the past that were probably not the best ideas. One, for healthcare IT executives who are less accessible than others, there tends to be a failure of project management. We come across provider organizations that are working diligently on either Stage 1 or 2, but they don’t really have a project plan in place to guide them. There are enough dependencies and interactions where having a tight project plan you follow is extremely useful and will save time in the long run.
Another problem I see is a failure to work ahead and consider future stages. This especially came up in Stage 1, where there were various strategies in the environment to meet MU faster, with less effort. For example, there was the so-called emergency department (ED)-only option, though to be clear, you can’t just do MU in your ED and have it count. Because of the number of patients in the ED, many providers realize if they did a great job in ED, they would meet the overall requirements. While that is a valid strategy, it doesn’t take into account the long-term view and realize that future stages will require a lot more than that. And now, a lot of provider organizations I have talked to that are very focused on their 2014 certification are not thinking through or paying too much attention to the fact that October 1, 2014 starts the new reporting period for Stage 2.
So it’s also important to plan for Stage 3, too. In the drafts for Stage 3, there is a lot more emphasis on patient engagement and clinical decision support. Keeping those things in mind would be helpful now. There is plenty of concern out there now about the patient engagement requirement, and while I understand that, we need to recognize that it’s here to stay. As an industry, it’s time to accept that and focus on it.