Final “Meaningful Use” Rules Seen

The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC) announced the final rules for meaningful use , incentives, standards and certification today. The requirements to qualify as a meaningful user of EHR technology, and therefore receive incentive payments as defined in the HITECH portion of the American Recovery and Reinvestment Act (ARRA), had been the subject of hot debate over the past year as providers wondered whether they could actually meet the terms set forth in the proposed rules seen earlier this year. The final rules do scale back the number of objectives that must be met somewhat, and provide more flexibility for providers to continue along individualized paths to meaningful use. Hospital systems that share a CMS Certification Number (CCN) will be disappointed to learn that the payments will still be made based on the single number, not as individual hospitals. This could mean millions to some systems, which are no doubt investigating how to separate their operations under multiple CCNs. The hospital-based physician definition was clarified to exclude physicians performing all work in an inpatient hospital setting or emergency room.

ONC is still the process of identifying organizations that will be certified testing and certifying bodies, but it projects that certified software will be available for purchase by this fall. Registration for the incentives begins in January, 2011, and be managed online by CMS. Attestations from providers seeking incentives will be made starting in April, 2011, with payments starting in May, 2011. Medicaid payments will occur on schedules dependent upon individual states and the status of their plan and progress made.

The final rules on meaningful use and the incentive program will be published in the US Federal Register July 28.

-Rod Piechowski

Copyright © 2010, Rod Piechowski, Inc., Consulting

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HIT Essentials for Hospital Boards (and Other Leadership), Part 2

Information technology should support the healthcare mission, not become the mission, so it is important, especially for the board, to not get dragged into the minutiae. Here are three more essential concepts about information technology in healthcare that should be integral to every hospital board’s leadership toolbox. Understanding these will help position a hospital for successful implementations, and to reap long-term benefits.

1) Converting to EHR systems is a baby-step. This is just an early phase in a much longer process of weaning the healthcare system away from paper and into a world in which the efficiencies of technology can truly enable a reformed healthcare system. Quality reporting, the reduction of administrative burden, the application of standards, more accurate billing, lower prices for coverage and services, computerized decision support, improved home care, and access to better care for all are just some of the goals that depend upon the thoughtful application of information technology. The day each hospital and every physician in the country starts using EHR systems will mark an early milestone in a transformative process that will continue for years. Remember, there is no going back…

2) Calculating Return on Investment (ROI) is hard. Implementing an EHR system is not the same as investing in a new drill press for a machine shop, where the price per widget can be calculated using known formulas and each widget sold contributes to net profit or loss. Furthermore, classic ROI calculations assume a monetary payback for a given investment within a specified number of years. The kind of savings EHR systems bring to a hospital may not be apparent for a while. They may involve improvements in safety and efficiency that are more difficult to measure, or that may pay off in intangible ways such as greater patient satisfaction. From a safety standpoint, the return must be measured in terms of “mistakes not made.” Just to complicate this a bit, consider the drive away from task-based pricing and it gets harder still.

3) Technology will enable individualized medicine. Thanks to what we will learn from research done on anonymized data from populations and their subsets, physicians will be able to target care plans specific to the way an individual reacts to certain classes of drugs or other treatments. Information about what works and what doesn’t work will be more readily available to physicians, providing huge value to both individuals and communities. Hospitals will have first access to this information, and the best ones will use it to assess their performance and perform research with an immediate benefit to both the business and the community. (Link to Part 3 here.)

-Rod Piechowski

Copyright © 2010, Rod Piechowski, Inc., Consulting

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HIT Essentials for Hospital Boards, Part 1

While the CEO, CIO, COO, and CMO take on the task of identifying which technologies are required to support a hospital’s mission, hospital boards have a responsibility to guide the organization, support its strategies, and ensure that the financial pieces are in place in order to remain a viable community asset. The timeframes for implementation allowed under HITECH and proposed rules don’t provide much time to take a “wait and see” approach. Here are three information technology essentials for the board to consider that will benefit the entire transformation to a digital healthcare world.

1) Information Technology is a tool, not an end unto itself. Merely implementing IT will not magically change your organization, improve quality and efficiency or reduce risk. The more a hospital can do to prepare for cultural change, the more prepared it will be to implement IT in a way that will support the mission and strategies. First, develop a strategy; then develop an IT system that supports that strategy. If you invert this process, there will be disappointment all around.

2) Paper is tangible, electronic records are not. People are used to holding paper in their hands, whether reading a book or a folder filled with medical records. Electronic records allow much greater capability to search and analyze data, but the way we interact with the information is different, and requires learning an entirely new process just to see it, save it and retrieve it. Anyone can learn to turn the pages of a book, but a computer adds a layer of obfuscation between the reader and the information. Paper medical records wait patiently for you to access them at your leisure. Electronic records require electricity, computer hardware, software, networks, and an IT department to maintain it all. Meanwhile, a book printed 400 years ago will never require a software upgrade in order to read it.

3) Information technology is a long-term commitment. Not many people have invested in personal computers and then given up on them in order to revert to typewriters and paper. The next version of hardware or software always promises faster speeds, improved performance, easier use, etc. The initial cost of a personal computer is minimal compared to the additional investment we must make in software (and upgrades), educational materials, and time spent learning how to use these tools efficiently. Further, the data collected, whether it is in the form of email, spreadsheets, reports, etc., is now in electronic format, and it would be completely impractical to convert all of it back to a paper-based system. The same holds true for HIT: There is no going back. (Link to Part 2 here.)

-Rod Piechowski

Copyright © 2010, Rod Piechowski, Inc., Consulting

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Summers in Suspension

Last year at this time we were waiting for the final meaningful use recommendations from the policy committee. Even then (a year in HIT time seems like 10) we felt the pressure of the looming deadlines for achieving meaningful use. This summer, we’re waiting to see what the final rules look like. Depending on your point of view, they were either scheduled or promised for release by late spring, 2010. Now spring has passed, and even the government websites are have added “early summer” to the possible delivery date. Even when we do have the final rules, every product still needs to be certified, or re-certified, and we still don’t know who will be doing the certification. But worrying about all of that can ruin your summer, so instead I’ve been thinking about the concept of trust, and how much of what we envision as a result of HIT involves trust.

For example:

  • Physicians and patients might ask: Does the software work as promised? Are there any hidden problems that could jeopardize safety?
  • The government might ask: Are the end users acting in good faith? Are they using the system? Using it as designed? Or are they implementing workarounds?
  • Everyone is asking: Will the meaningful use rules increase the chances that most providers can achieve them?
  • Providers wonder: Will the government pay the incentives or look for ways to save?
  • Everyone asks: Are the systems secure?
  • Patients in particular wonder: What will employers and payers do with the data they have?
  • There are others…

We must also trust ourselves to adapt. It’s interesting that for years, the healthcare community has been aware of the fact that it is way behind in the adoption of technology to improve safety and delivery. The number one issue in just about every poll ever taken on the issue declared that the cost of these systems was the limiting factor. After all, technology is expensive. Now, the government is putting some money into softening the blow of the cost; that’s good! But that positive move has been dampened by the apparent rush to move everyone along at the same speed.

In project management, it is often said that of the three interlocking components (cheap, fast and good), you can only have two. A single implementation at one hospital is a complex undertaking; now multiply that times 5,000 hospitals in the US, factor in the half-million or so physicians who may or may not participate, and then tie it all together with the promise of one interoperable, trustworthy system. Do we trust ourselves, as a sector, to make the right choice? Which will we give up: Cheap, Fast, or Good? While the US is making a net investment in EHRs of about $17 billion (the actual initial investment is $30+ billion), consider that there are individual hospitals that have already spent hundreds of millions of dollars to get where they are today.

It’s great that we’re finally moving forward. But by making “meaningful use” the centerpiece of getting the incentive payments, the focus shifts to the money and to individual provider survival, not to the patient or to an improved healthcare system and in turn, societal benefit. This disconnect puts the larger goals in peril and, if we really care about them, we can either “trust” that someone out there is working on them, or start talking about it now. Your comments are welcomed…

-Rod Piechowski

Copyright © 2010, Rod Piechowski, Inc., Consulting

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