Happy New Year?
As I begin the 2014 Meaningful Use measures readiness assessment and vendor cat-herding exercises, I’m reflecting on this portion of CMS’s Director of E-Health Standards and Services, Robert Tagalicod and the ONC’s Acting National Coordinator Jacob Reider’s statement regarding the Meaningful Use timeline modification: “The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2.” (Previously published on EMRandHIPAA.com.)
I call BS.
If the “goal” is a “successful implementation”, then CMS failed miserably by not addressing the START of the quarterly attestation period for Stage 2, which is still required in 2014. CMS and the ONC need more time to successfully implement the measures, and they are bureaucratic agencies that don’t directly deal with patient medical care. Why wasn’t the additional time required to truly succeed at this monumental task extended to the healthcare provider organizations? Because the agencies want to save face, and avoid litigation from early adopters who may be already beginning their 2014 attestation period amidst heroic back-breaking efforts?
Here’s a reality check for what a large IDN might be going through in early January, in preparation for the start of the 2014 quarterly attestation period. Assume this particular IDN’s hospitals’ fiscal year runs October-September, so you MUST begin your attestation period on July 1. You have 6 months.
As of December 31, 2013, only 4 of the 8 EMRs in your environment completed their 2014 CEHRT certification.
Each of those 4 EMRs has a different schedule to implement the upgrade to the certified edition, with staggered delivery dates from March to July. The hospital EMR is not scheduled to receive its certified-edition upgrade until April. You pray that THIS implementation is the exception to your extensive experience with EMR vendor target timelines extending 6-8 weeks beyond initial dates.
The EMR upgrades do not include the Direct module configuration, and the vendor’s Direct module resources are not available until 6-9 weeks after the baseline upgrade implementation – if they have knowledgeable resources, at all. Your hospital EMR vendor can’t articulate the technical infrastructure required to implement and support its own Direct module. Several vendors indicate that the Direct module configuration will have to be negotiated with a third-party. Your clinicians don’t know what Direct is. Your IT staff doesn’t know how to register with a HISP. Your EMR vendor doesn’t support a central Direct address directory or a lookup function, so you contemplate typing classes for your HIM and clinical staff.
The number of active patient problems requiring manual SNOMED remediation exceeds 60,000 records in your hospital EMR. You form a clinical committee to address, but they’re estimating it will take 6 months of review to complete. You’re contemplating de-activating all problems older than a certain date, which would whittle down the number and shorten the timeframe to complete – but would eliminate chronic conditions.
There are still nagging questions regarding CMS interpretation of the measures, so you ask for clarification, and you wait. And wait. And wait. The answers impact the business rules required for attestation reporting, and you know you need any help you can get in whittling down the denominator values. Do deceased patients count in the view/download/transmit denominator? If records access is prohibited by state/federal law, does that encounter count in the view/download/transmit denominator?
Consultant costs skyrocket as you struggle to find qualified SME resources to blaze a trail for your internal staff. Their 60-to-90-day assessments inevitably end with recommendations for “proof of concept” and “pilot” approaches to each of the 2014 measures, which don’t take into account the reality of the EMR upgrade timelines and the looming attestation start date. Following their recommendations would delay your attestation start by 9-12 months. So, your internal staff trudges forward without expert leadership, and you throw the latest PowerPoint deck from “Health IT Professionals-R-Us” on the pile.
Who needs testing, when you can go live with unproven technology the day it’s available in order to meet an arbitrary deadline? Healthcare.gov did it – look what a success that turned out to be!
But wait, this is real clinical data, generated by real-world clinical workflows, being used to treat real patients, by real healthcare providers. By refusing to address the start of the 2014 attestation period, CMS and the ONC are effectively using these patients and providers as lab rats.
I did not give permission to be part of this experiment.