Meaningful Use Experts

After my last post, a meaningful use checklist, I couldn’t help but start thinking about how many people are going to soon be looking for a meaningful use checklist.

Certainly many practices are going to be interested in finding a meaningful use expert to help make sure that they get the EMR stimulus money. I’m guessing many EMR vendors are going to want to find a meaningful use expert that will help them navigate the hundreds of pages of regulations and wave of other meaningful use information which isn’t in the regulation cause let’s be honest. Despite a HUGE regulation, there are a still a ton of practical meaningful use details that you’re going to need to know to appropriately navigate the meaningful use world. The government doesn’t just hand out money (usually). You have to play the game.

The challenge is that who is a meaningful use expert. Just over a year ago, no one even used the term meaningful use. Over the past year we’ve learned a lot about meaningful use and each day we learn more, but it’s all one huge learning process for everyone.

Plus, it’s not like there’s some meaningful use expert certification. ONC and CMS have done some meaningful use conference calls and other training. I expect they’ll do more and more of these. Will those and other resources on the various HHS websites get us to the point that someone can say they’re a meaningful use expert? It seems like they’re going to have to do it, no?

Of course, we have the RECs also. No doubt, they should have the information you need to show meaningful use. Their meaningful use experts are free too. Not too bad. Are RECs getting extra meaningful use training that really will make them experts on meaningful use?

I’m interested to know how practices are planning to approach meaningful use. Will they be finding meaningful use consultants? Will they be using the RECs? Will they be navigating the meaningful use waters alone and build the expertise in house? Will they be relying on their EMR vendor to provide them the meaningful use expertise?

I guess it’s just hard for me to call anyone an “expert” on meaningful use. I think I’m pretty knowledgeable on meaningful use, but I’d definitely shy away from using that “E” word. Maybe other people see it differently than I do.

About the author

John Lynn

John Lynn is the Founder of HealthcareScene.com, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference, EXPO.health, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.

17 Comments

  • I hadn’t considered this point, but I’d agree: calling anyone an expert on a subject that’s only just left the womb (so to speak) is dubious. The webinars and public calls will no doubt help, but I think many providers are going to want a clear, concise report or checklist on how to get this thing done. That’s work that would be great for the RECs to handle, and I’ve no doubt BobbyG may have more to say on that front.

    Personally, I’d say the best way to have an expert declared is to get some real world examples to hold up of hospitals or practices that have achieved meaningful use and received their checks. That sort of street cred will get a lot of people’s attention.

  • Michelle,
    I agree. At least once you’ve proven that you’ve done it you could consider calling yourself an expert. So, we won’t have any meaningful use experts until at least April;-)

  • I personally don’t see how anyone can be a meaningful use expert at this point, or in the time that is alotted to meet it. Still, I doubt it will stop people from claiming to be, and those people probably will know the ins and outs pretty well. Still, that experience that you typically expect with an expert will be impossible to get.

  • As an EHR vendor, this has been a difficult conversation to have with prospects as well as customers due to the ever changing landscape. We have found that the best way to have this conversation is to keep our customers and prospects informed. In addition to eblasting out to our customers the CMS webinars – as well as doing our own – we are awaiting the final certification technical requirements (and cert bodies) to craft a MU training and implementation program for our customers so that as they look down the MU Checklist, they know how to apply that rule to our system and visa versa.

    There are already consultants/agencies, etc. that claim to be experts in MU, but for a buyer, I do think it’s critical that they choose a vendor that can relate MU to their product in a meaningful (no pun intended) way. While it’s important to work with an independent resource (or be your own!) to understand MU, make sure the vendor is an expert in their product as it relates to MU b/c it’s that vendor that will ultimately be your resource when you are trying to achieve MU.

  • Jessie,
    I agree with you that many providers will be VERY happy with the support their EMR vendor provides to them in their journey to show meaningful use. In fact, I think it makes complete sense to be able to get that service from your EMR vendor.

    The problem is with what I call the “jabba the hutt” EMR vendors that are so big that they basically can’t support small practices like this. They’re going to wish they had a different EMR vendor.

  • Copy that, EHR Scope. I would add that “experience is that which you get just AFTER you really needed it.”

    At my REC I lead a Meaningful Use “Brown Bag Lunch” Study Group comprised of our entire REC Technical Assistance Team (any that can make it from week to week). It convenes every Friday from 11 a.m. to 12:30 pm in one of our teleconference rooms (we are bi-state, NV and UT). We have been doing this since the IFR. One thing we have done was to have everyone submit 10 or more random initial questions asking about everything related in any way to MU, e.g., like the kinds of things they’d been asked about out in the field and for which they’d perhaps had to hedge their answers.

    I then de-duped and assembled these in an Excel sheet, with an accompanying “Comments” column, and circulated it back to the team, asking that they bring it to Brown Bag for note-taking.

    These are all smart, experienced, accomplished people, mostly Master’s up to PhD and MD level, and it’s interesting the difficulty WE have discerning accurate answers you’d expect from “experts.”

    Now, some of the criteria are straightforward, i.e., “bright line standards” not requiring much, if any interpretation, whereas others are much fuzzier, and open to divergence of conclusions or outright befuddlement (“…that one’s a CMS Project Officer question…”).

    Part of the problem is the FR itself, 864 pages of catatonia-inducing detail lacking an index or even a table of contents with page numbers, or chapter headings, in the same way that the IFR was published. You run across internally inconsistent stuff from time to time. A liability of drawn-out drafting by committee, I suppose.

    When I first saw the IFR, I thought “who the [bleep] wrote this? Marcel Proust and e e cummings?”

    Rule of federal bureaucracy: “Never say in 86.4 pages what you can say in 864.”

    In addition to my extensively sticky-noted 2″ binder, I always keep the PDF copy open on my laptop during Brown Bag for quick keyword searching.

    I can’t speak for the other RECs, I can only speak for my own.

    BTW, CSC has a nice “Meaningful Use Community” website. Join it.

    https://community.csc.com/community/meaningful_use

    Here’s just one example of the difficulty you run across. Yesterday we were on a CMS conference call MU incentives presentation in which they said that states’ participation on the Medicaid side was “voluntary.”

    We all went “WHAT?! How did we miss that?”

    Sure enough: on the CMS website you see “The Medicaid EHR incentive program is voluntarily offered and administered by States and territories. States can start offering their program to eligible professionals (EPs) as early as 2011”

    “voluntarily”, “can start”

    Not “shall” or “must”.

    Now, we knew from the IRF that (paraphrasing here) “there is no statutory basis for the manner via which states disburse incentive payments” but it somehow escaped us that states could simply opt out entirely.

    I went back to the ARRA legislation itself (on the assumption that the FR cannot, beyond operational implementation mechanics, mandate additional requirements not in the legislation). Beginning on page 375 you see “Subtitle B—Medicaid Incentives SEC. 4201. MEDICAID PROVIDER HIT ADOPTION AND OPERATION PAYMENTS; IMPLEMENTATION FUNDING.”

    You get to page 380 and then only see stuff about the administrative and reporting “requirements” for states getting the “FFP” money (Federal Financial Participation).

    And that’s it.

    I searched ARRA from beginning to end and found NO explicit wording that states’ Medicaid participation is “voluntary.” You just have to infer it from the Section 4201 language.

    What is one potential adverse upshot? Your REC could be signing up a boatload of providers coming in on the Medicaid side, and if your state opts out, well you now have what’s known as “Reputation Risk” writ large (not to mention a torpedo below the waterline in your Ops plan and its milestone payments assumptions).

    Why would a state opt out? Because they are only federally funded for 90% of their “reasonable” administrative expenses for the EHR incentive program. They have to find the other 10%. My state (NV) is currently wrestling with a three BILLION dollar budget gap. Similar relative woes exist elsewhere in statehouses (can you say KAHL-EE-FOR-NEEYA?).

    You better know where your state stands before recruiting Medicaid providers if you’re a REC or a consultant or VAR, etc.

  • I expect that small / medium practices will rely on VENDOR advice in this area. Especially those vendors that “guarantee MU achievement” in their marketing materials.

    Has anyone yet seen a standard form which can be used for EPs to “assign” their incentive money to their employer organization?

  • John,

    I feel as though HITECH has really leveled the landscape for EHR vendors – and whereas the jabbas of the world used to be able to rely on their name and CCHIT Cert. to convey conviction/confidence in their product, we are working with a much more savvy marketplace where gov’t criteria are published and “checklists” are available. If these guys don’t provide a MU training/implementation service and aid to customers and prospects, I’d be shocked if their business models don’t fall flat…but that’s where the politics of this industry come into play. Consultants/Firms already have their “preferred” vendors that they recommend…now are they recommending based on the fit with the customer OR because they know what kind of implementation consulting commission they’ll get after the fact? It’s an interesting world out there – a lot of different organizations have a stake – I hope that the jabbas will step up to the plate for the practice’s sake.

    On a side note, KLAS came out with their interim report in June that (among other products) rates ambulatory EMR vendors based on the consumer’s opinion. This is definitely a good place to start when evaluating vendors for physicians.

  • Jessie,
    I agree that there has been some leveling of the playing field. I’m still interested to see how the REC portion of it plays out and if that makes the playing field unfair. Not all RECs are vendor agnostic like BobbyG’s.

    The only caveat I’d add to what you said is that many specialty practices are going to see the meaningful use guidelines and laugh. They’ll then ignore the guidelines and move forward with an EHR based on other criteria. Meaningful Use was definitely focused at primary care.

  • BobbyG,
    Thanks for the details on Medicaid stimulus money being voluntary and states can opt out. Unfortunately, there are hundreds of little details like this that are going to come out as the crap hits the fan (so to speak). It’s going to be a little bit ugly when they do I think.

    The brown bag lunch meetings sound interesting. Maybe I’ll have to sneak into your office sometime and listen in;-) We are pretty much neighbors after all (I think).

  • Yea, I caught the “voluntary” state participation in the webinars with CMS & ONC. However, they mentioned that they couldn’t imagine that there would be ANY state that would not wish to participate. Here’s the logic:
    1. The incentive $ = money into the state economy
    2. #1 is true whether the EP keeps or assigns the $ to their employer (except maybe in the cases of large multi-state provider orgs)
    3. All states’ economies are in need of stimulus
    4. CMS pays the states’ administrative costs of administering the Medicaid incentive $
    5. States almost never turn down federal money, especially lately

    So, I’d be very surprised if we hear of even a single state that says, “nah, we don’t want to participate”

    BTW – I sat thru a nice 4-hour Centricity demo today 🙂

  • BTW – Did you also know that a state can mandate up to 4 of the 5 “menu” clinical quality measure items? True. However, they have to explain to CMS why they need to mandate an item, i.e. how it fits with projects the state is engaged in. CMS must approve their request, but if they do, some of the “menu” items can be dictated instead of “selected”.

  • @Wes –

    “4. CMS pays the states’ administrative costs of administering the Medicaid incentive $”
    ___

    Yes, but only 90% of “reasonable expenses.” The states have to fund the remaining 10%. And, headline here yesterday was that of our Governor saying he may refuse the latest $162 million federal emergency appropriation, $79 million of which is designated for NV Medicaid. He says “too many strings” (I know, he’s playing politics).

    I hope you’re right that all states will fall in line, but I want confirmation of that here in NV.

  • John,

    Agree completely that MU seems to focus mostly on PC and do believe that there are several specialties that will forego MU criteria as a means by which to evaluate vendors. Certainly each practice is its own business and will consider a number of factors around their own unique needs to ultimately decide what solutions would best fit their practice.

  • “I sat thru a nice 4-hour Centricity demo today :)”

    You brave soul. I think it says something that their demo is 4 hours. Practice Fusion use to have a marketing campaign called “Live in Five” which had you up and using their software in 5 minutes.

    Of course, that always felt like marketing hype, but there is really something interesting to say about being able to get your hands on the software and use it yourself instead of seeing the masterfully crafted 4 hour demo.

  • Just to be fair to the vendor, the 4-hr Centricity demo was 2 separate 2-hr sessions (PM vs. EHR) which had mostly different audiences – and also Q and A time. Audience was about 80 people and it did not seem long..went quickly.

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