As the industry lurches toward automation spurred on by the HITECH Act, reading the tea leaves on meaningful use is becoming all important. And while the HIT Policy Committee has issued a fairly extensive matrix on the subject, many of the apparently clear details dissolve into fuzziness upon closer examination. To tackle these issues, and provide a snapshot of where the industry stands, HIMSS Analytics has released a report on the subject. Recently, HCI Editor-in-Chief Anthony Guerra had a chance to talk with the author, EVP Mike Davis, about healthcare’s all-consuming quest to collect the stimulus funds.
(Part I, Part II)
GUERRA: In your report, you wrote there’s a need for templates that allow nurses to create additional data elements. You used the term template capabilities. Can you explain that a little bit?
DAVIS: Let’s say that right now nurses are not capturing the A1C hemoglobin status in the progress note, they need to be able to go into that software environment and add that as a field they can check off or put a value into, as part of their documentation template. That’s just an architecture capability which the majority of vendors have today.
GUERRA: You wrote that systems must have the ability to transmit results to requesting parties. It’s going to be important there is an audit trail for those releases of information, correct?
DAVIS: Every system that I know of has an audit trail. The issue is many of them are not usable. You basically have to write very sophisticated queries to find out what you’re looking for. I think, over the last probably two or three years, the vendors have started to look at the audit trails and they’re trying to make that much more user-friendly than they currently are, but you’re exactly right. There’s going to be a lot of design work, you have to go into the audit functions of these environments to track all this, and they also need to create the requests so people can look at them very quickly and ascertain if they are valid or if people are trying to basically hack into their environments. So there are all kinds of things that this gets into, not just the security for patient information but general security of the environment overall.
GUERRA: I’ve always thought it’s problematic that CMS has not laid out the mechanisms by which hospitals and physicians will have to prove they’ve achieved whatever meaningful use is define to be. We don’t know the mechanisms, we don’t know if it’s going to be a simple attestation or if it’s going to be some sort of electronic extraction from the systems they’re supposed to be using.
DAVIS: That’s a very good point. Two things there, it may be those regional entities (RECs) that they’re setting up will go ahead and actually do the validation. It may be that they require the hospitals to actually report this data or prove that they report this data by submission of required reports to CMS, like the quality reporting programs which exist today. But I think for 2011, you make a good point. I really haven’t thought about that too much. My mindset has always been that this would be something they’re going to have to prove through electronic submissions.
GUERRA: If it is electronic, and we don’t know how they’re going to want that data extracted, all of a sudden you could be in for a real data conversion problem or even a manual process.
DAVIS: Well you could. One of the examples provided to us was that the ability to exchange information in 2011 is going to be as simple as putting a PDF report into an email and sending it. So like I said, I think for 2011 they’re going to not be nearly as restrictive as they’re going to be in 2013 and 2015. They’re making up several different methodologies to do this. It may be that some of these have to be electronically reported, some of them are going to be done through attestations.
GUERRA: There’s no way CMS can build the infrastructure to go out and check every hospital and every practice. It’s going to have to be done with attestations, and audits where there are red flags.
DAVIS: Yes. I think the government has been pretty smart about using existing capabilities in the industry. This could become part of the JCAHO evaluation. I think the other thing you look at is as people go through their accreditation processes this can be a part of that.
GUERRA: When we get beyond transactions to hardcore data management issues, that’s when your sophistication level as an IT director or CIO has to be top notch, because many people can put in a transactional system but few really understand data capture and manipulation.
DAVIS: Right. You’re preaching to the choir. That’s how we’ve tried to identify the Stage 6 or 7 hospitals so that other hospitals in the industry can contact them for help.
The nice thing about Stage 6 is those are all sizes and types of hospitals. When we initially started this, we started to do the evaluation to research and release the model. The money, at that point in time, was only in the academic medical centers, but that’s not true anymore. So I think that’s helped the industry understand that there are hospitals out there, different sizes, different types, that are starting to push the envelope and are becoming pretty advanced in this environment.
But again, I think you’re exactly right, and I think that’s why you’re going to see a lot of solutions offered and adopted because that way you can start to implement systems. In some cases, they implement systems that have templates already set up to meet these requirements for capturing data and reporting data.
If you look at the vendor environment out there right now, they’re really focused on saying, “Okay, how do I set up these systems? How does this now impact my implementation protocols and those types of things?”
You’re starting to see vendors make some guarantees. So you want to make sure that you set up your solutions to address all these issues, so all of your documentation should be able to capture this data. You should have solutions out there that can actually take this data and create reports from it or create the actual structured transactions, if you’re required to do that. And so I know the vendors are looking at that very closely right now, because they understand that, for them to be successful, they’ve got to deliver the solutions that meet these requirements.