Eyes Wide Shut – Managing Multi-EMR Meaningful Use Stage 2 Is Hard

Most discussions on Meaningful Use (MU) seem to focus on a single healthcare provider organization (acute or ambulatory), with a single EMR, and a single Medical Record Number (MRN) pool generating unique patient identifiers. Even in that context, the complaints of the difficulties of successfully implementing the technology and obtaining the objectives are deafening. How daunting might those challenges seem, multiplied across a large integrated delivery network (IDN), attempting to make enterprise-wide technology and operational process decisions, in alignment with MU incentive objectives?

Imagine you are an IDN with 9 hospital facilities, sharing a single EMR. You also have 67 ambulatory practices, with 7 additional EMRs. You’ve made the progressive choice to implement a private health information exchange (HIE) to make clinical summary data available throughout the IDN, creating a patient-centric environment conducive to improved care coordination. To properly engage patients across the IDN and give them the best user experience possible, you’ve purchased an enterprise portal product that is not tethered to an EMR, and instead sources from the HIE. And because you’ve factored the MU incentive dollars into the budget which enabled these purchasing decisions, there is no choice but to achieve the core and select menu measures for 2014.

It is now October 2013. The first quarter you’ve chosen to gather Stage 2 attestation data starts on April 1, 2014. All your technology and process changes must be ready by the data capture start date, in order to have the best opportunity to achieve the objectives. Once data capture begins, you have 90 days to “check the box” for each MU measure.

Tech check: are all the EMRs in your IDN considered Certified Electronic Health Records Technology (CEHRT) for the 2014 measures?

Your acute EMR is currently 2 versions behind the newly-released MU 2014-certified version; it is scheduled to complete the upgrade in November 2013. Your highest-volume ambulatory EMR is also 2 versions behind the 2014-certified version, and it cannot be upgraded until March 2014 due to vendor resource constraints. Your cardiology EMR cannot be upgraded until June due to significant workflow differences between versions, impacting those providers still completing Stage 1 attestation. One of your EMRs cannot give you a certification date for its 2014 edition, and cannot provide an implementation date for the certified version. The enterprise portal product has been 2014-certified as a modular EMR, but the upgrade to the certified version is not available until February 2014.

Clearly, your timeline to successfully test and implement the multitude of EMR upgrades required prior to your attestation date is at risk.

Each EMR might be certified, but will it be able to meet the measures out of the box?

Once upgraded to the 2014 version, your acute EMR must generate Summary of Care C-CDA documents and transmit them to an external provider, via the Direct transfer protocol. Your ambulatory EMRs must generate Transition of Care C-CDA documents and use the same Direct protocol to transmit. But did you purchase the Direct module when you signed your EMR contract, or maintenance agreement?

Did you check to see whether the Direct module that has been certified with the EMR is also an accredited member of DirectTrust?

Did you know that some EMRs have Direct modules that can ONLY transmit data to DirectTrust-accredited modules?

You determine your acute EMR will only send to EMRs with DirectTrust-accredited modules, and that you only have a single ambulatory EMR meeting this criteria. That ambulatory EMR is not the primary target for post-acute care referral.

You have no control over the EMRs of providers outside the IDN, who represent more than 20% of your specialist referrals.

Your 10% electronic submission of Summary of Care C-CDA documents via Direct protocol measure is at risk.

Is your organization prepared to manage the changes required to support the 2014 measures?

This is a triple-legged stool consideration: people, process, and technology must all align for change to be effective. To identify the process changes required, and the people needed to support those processes, you must understand the technology that will be driving this change. Of all the EMRs in your organization, only 2 have provided product specifications, release notes, and user guides for their 2014-certified editions.

Requests for documentation about UI, data, or workflow changes in the 2014 versions are met with vague responses, “We will ask product management and get back to you on that.” Without information on the workflow changes, you cannot identify process changes. Without process change recognition, you cannot properly identify people required to execute the processes. You are left completely in the dark until such time as the vendors see fit to release not only the product, but the documentation supporting the product.

Clearly, your enterprise program for Meaningful Use Stage 2 health IT implementation and adoption is at risk.

What is the likelihood that your Meaningful Use Stage 2 attestation will be a successful endeavor for the enterprise?

As a program manager, I would put this effort in flaming red status, due to the multitude of risks and external dependencies over which the IDN organization has zero control. I’d apply that same stoplight scorecard rating to the MU Stage 2 initiative. There is simply too much risk and too many variables outside the provider’s control to execute this plan effectively, without incurring negative impacts to patient care.

The ONC never said Meaningful Use would be easy, but does it have to be this hard?