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Meaningful Use Definition: Calendar Years or Adoption Years?

June 16, 2009
by David Raths
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The June 16 meeting of the Office of the National Coordinator’s HIT Policy Committee illustrated there’s still a lot of work to do in determining how aggressive to be in terms of setting timelines and expectations.
A work group presented its initial recommendations on the definition of meaningful use. The presentations, by Paul Tang, M.D., chief medical information officer at the Palo Alto Medical Foundation, and Farzad Mostashari, M.D., of the New York City Health Department, described a phased-in continuum that basically focuses first on data capture and sharing in 2011; then moves to advanced clinical processing by 2013; and finally to measuring progress toward achieving specific goals around improved health outcomes by 2015. One of the key goals they described is beginning to move from quality measures based on claims data to clinical measures enabled by health IT.
I found one question during the comment period following the presentation most interesting because it seemed so basic and yet no one had a clear answer. Neil Calman, M.D., of the Institute for Family Health, asked about the two calendars at work here: The first is the increasing sophistication of what ONCHIT may expect in 2011, 2013, and 2015, and the second is the calendar that each healthcare provider organization finds itself on as it implements a system.
The longer an organization wait to begin this process, the bar just gets higher and higher in terms of what they must achieve in the very first year. In other words, if a hospital system begins implementing a new EHR system in 2013, it may view that year’s meaningful-use requirements as unrealistic and/or unachievable. “You can’t open up a patient portal the first day you implement an EHR,” Calman said. “Things require sequencing.”
Tony Trenkle, director of CMS' Office of e-Health Standards and Services, noted that the law requires that everyone meet the same definition of meaningful use at the same time. Whether it is your first year of implementation or your third, the definition has to be the same, and there can’t be different tiers of meaningful use. That’s the way the law is written, he said.
The panel then spent a few moments mulling over the implications of talking to providers about calendar year vs. adoption year expectations, and how to deal with providers who jump on the adoption curve with a certified EHR later rather than sooner. Mostashari admitted they may not have an answer for that yet.
The HIT Policy Committee “tabled” the work group’s recommendations, which means its members will go back to the drawing board with feedback from today’s comments and make another presentation next month.



SaaS could end up being a popular option for many healthcare organizations with respect to the expectation that the definition of meaningful use will become more stringent over time. However, another option healthcare organizations should investigate is a subscription pricing offering in which they aren't purchasing the system outright rather they pay a fee to use it. This allows them to structure their contracts with language that requires the vendor to supply a system that always meets the current meaningful use requirements, knowing that those requirements will become more stringent over time. A subscription model also doesn't necessitate that the system be hosted with an outside vendor, which provides options to organizations that perceive more risk to full outsourced systems that leave it up to the customer to develop a suitable disaster recovery solution.

Thanks for this post David. In my opinion, the focus from today through 2013 should be solely on adoption to get all healthcare providers in the game, THEN start requiring people to extract quality measures. I think Neil Calman made a great point, but the law doesn't seem written to deal with reality.

Good point, Marc. And a few vendors and consultants I have spoken with recently, including Siemens, say that they are putting lots of effort into SaaS offerings. Are there complications, though, in integrating other hospital software, medical devices, etc., with an outsourced EHR application? And are there things about leasing that makes hospital CIOs nervous?

As I've said in earlier blogs...
Show me one healthcare federal regulation that was implemented on it's original time schedule, just one.
Think HIPAA, DRGs, Tefra, etc...

Which is why I don't buy the YOU MUST DO IT NOW approach.

I say do it right...even if it takes a little longer.
Trust me ... dates will be pushed out, I'd bet my bippy on it!

In the One-on-One with MemorialCare Medical Centers CIO Scott Joslyn he has an almost parenthetical side thought: "A way to avoid a lot of capital expense can be software as a service, it's less up front".

Having just read David's post, this side thought lept out at me and may well be one of the most important sentences of the next 4 years. Any healthcare organization which delays implementation by another 6-12 months from now will almost certainly have no other choice than to implement with an SaaS vendor given the law as it is currently written.