Tuesday, July 6, 2010

A Do it Yourself Meaningful Use Update Letter

In January, I wrote a Do it Yourself presentation on meaningful use for folks to use with their Board and Senior leaders.

Now that its July, there is a different kind of Do it Yourself document - a letter to your Board and Senior leaders outlining your plan and timeframe for certification, measurement of meaningful use, and collection of your stimulus funds. We cannot be completely certain about every detail, so its important to state what you do not know. The reason to start this communication now is that CFOs may be including stimulus dollars in budgets, not realizing that the timeframe to achieve the stimulus is still unknown.

Here's what I used.

"Dear Senior Leaders:

I want to update you on the effort in Washington to accelerate adoption of electronic health records by providing stimulus dollars to eligible professionals and hospitals.

There are three important regulations associated with this effort - the rule on standards, the rule on meaningful use, and the rule on certification. Electronic Health Records must include data standards in order to exchange data. To improve quality, safety, and efficiency, electronic health records must be used in meaningful ways. Products and self built systems must be certified as having the capabilities to support meaningful use and the standards.

Where are we are on the journey?

On June 24, the final temporary certification rule was published in the Federal Register.

It outlines the process for organizations to become authorized testing and certification bodies, but it does not provide the certification criteria. Those will be part of the final meaningful use rule.

On July 1, organizations began applying to serve as testers and certifiers. The timeline for approval of these organizations is unclear but likely it will be fast.

The Certification Commission for Health Information Technology is likely to be the first organization authorized based on its extensive past experience. It is likely that several organizations will eventually be authorized. We'll have to choose one to certify our suite of software, since it is a combination of built and bought systems.

The final rule on meaningful use has not yet been published, although it is likely to be completed by the end of July.

As soon as it is is published, we'll do a gap and risk analysis of our inpatient and ambulatory systems, just as I did with the interim rule.

Many organizations found aspects of the interim rule challenging for FY11 implementation. Meaningful use is not a cakewalk, it is a stretch goal for just about every organization. You should not presume that clinicians and hospitals will be able to use existing software and processes to achieve meaningful use. There will need to be upgrades and workflow change.

I've been working very aggressively to prepare us as much as possible, but until the final rule is issued, we cannot know how close or far we are.

Once the final rule is issued and certification bodies are authorized, we will proceed with certifying our inpatient and outpatient systems. If the certification process identifies gaps in functionality, we will need to enhance those systems to fill the gaps.

Once the systems are certified, then we'll need a significant education program for our clinicians, followed by a 90 day test period during which we document the use of all systems by our clinicians to achieve the thresholds required to demonstrate meaningful use.

As to timeframe, I am guessing August before certification bodies are ready, September for certification of our applications/education of our clinicians, October through December to document meaningful use, followed by initial stimulus payments in January.

If there are gaps in EHR or Health Information Exchange functionality we need to remediate, it will be later.

I've asked ONC if organizations can use a 90 day demonstration window before their systems are certified (since no software in the country is yet certified - all previous certifications have been declared void). ONC responded that the final rule will provide this clarification.

Thus, the bottom-line is that no hospital in the US yet has any idea when they'll receive stimulus payments, making inclusion of such payments in the FY11 budget very problematic.

I'll keep you updated over the next weeks and months. If there are ways to accelerate stimulus dollar payments by adding additional temporary or permanent resources, I will let you know.


Feel free to use this as a template for your own letters.


A I said...

According to the ONC, There were 40 inquiries and 14 requests for applications for testing bodies that intend to be ONC-ATCBs. I have been able to find only two testing bodies, namely CCHIT and Drummond Group. I am also guessing that EHNAC may want to put its foot into the ring. Do you know of or have heard of other organizations that may want to be an ONC-ATCB?

Paul said...

Did you see the clarification / answer to this question:

Whether "organizations can use a 90 day demonstration window before their systems are certified (since no software in the country is yet certified - all previous certifications have been declared void). ONC responded that the final rule will provide this clarification."

I have the same question but have not been able to find it in the final rule just yet.