What would you say are some of the good and bad points in the proposed Meaningful Use criteria?
Well, let’s start with the good. What’s good about this whole HITECH legislation, I think, is that HIEs, or Health Information Exchanges, are going to be planned out at the state or regional level in a little more solid form than they have in the past. I think that’s good. Prior to that, we had HIEs being formed in regions, in cities, and sometimes even multiple HIEs being developed inside a single metropolitan area. Now with the grants, the states will be putting some thought and planning into what their state’s health exchanges will look like. It will bring some order to things.
Now what’s going to be difficult about the regulations that came out, I think there are a few main points there. First is the all-or-nothing approach that was laid out by the Meaningful Use regulations. Both AHA and CHIME have commented pretty strongly on that; that we think it should be more of a building block approach, rather than all-or-nothing. Meaning that if you can achieve so many, and that number could be debatable, of the objectives laid out, then you could be deemed to have achieved Meaningful Use, rather than having to do every single objective and every single quality measure. We’re very hopeful that will be given serious consideration by CMS. We hope.
What changes do you think will be incorporated from all the thousands of comments made?
I think we’ve already seen something occurring. The issue about eligible providers. In many cases, outpatient clinics of hospitals were excluded under the current definition. My understanding is that there’s been legislation that has passed both House and Senate now that fix that problem and should make physicians who practice in outpatient clinics of hospitals eligible for the stimulus funding. So, we’re already seeing that change.
I think we will also see some changes in the quality reporting requirements. Asking providers to be able to install and use systems that electronically calculate all of the quality assurance measures is asking too much. The CMS has been asked to hold off on that requirement until they’re ready to accept it and process it in that fashion. I’m hopeful that we’ll see some relief on that front. I think those are the biggies.
Then the third item that I think everyone’s concerned about is the basic timing compression that’s going on here due to the delay in spelling out the certification process. Since providers must use certified records, that’s kind of your entry point to even be considered for stimulus funding. We’re going to need to have our system certified, potentially, as early as October 2010 for hospitals, January 2011 for providers — eligible professionals, physicians. Yet the certification rules and process will not be finalized until perhaps as late as June of this year.
That’s going to make it very difficult for hospitals and physicians to potentially have to upgrade their systems if their vendor’s requiring that to comply, or to get the certifications from their vendors. This also puts, I think, a lot of pressure on our vendors as well; having to go back and get their products re-certified, if you will, through a process that’s going to be different than the previously required CCHIT certification process. This presents some real challenges in timing.
What are your impressions about the proposed rule for creating the certification bodies through the EHR certification and testing?
I’m working with the CHIME Policy Steering Committee. I’m actually the Chair of the CHIME Policy Steering Committee, as well as serving on the American Hospital Association IT Advisory Committee. In both cases, these committees are concerned with any provision in the certification process that would drive more providers — hospitals or physicians — to have to go and obtain certification for their portfolio of systems on their own, rather than being able to rely on vendor certification.
In particular, there’s language in the NPRM on what constitutes a self-developed system. We are going to be commenting on that and asking that that be more precisely defined, such that a provider’s minor modification or enhancements to a certified system doesn’t throw them into the category of self-developed.
The fact that they’re opening it up to other entities — is that a step in the right direction?
It’s hard to say. There have been criticisms of CCHIT and there’s also been kudos to CCHIT. It’s difficult to say whether, in the long run, introducing more competition into that certification process is a good thing or a bad thing. They are adding, though, more rigor in the permanent certification process that’s being proposed; which is that you go through certification, then you have to go through testing and the introduction of a concept of a certification body needing to do some field surveillance to make sure that the product is actually being used in the field as it was intended. These three components together could make the certification process quite complex in the future.
Given all these questions that are still out there, do you think vendors and providers will be ready?
I would be very surprised to see any provider, hospital or physician, qualifying much sooner than perhaps this time next year. I’d be very surprised.
I hear many of my colleagues say that they will not qualify for Stage One stimulus funds until 2012 or 2013. Kind of towards the tail end of when Stage One is still in effect. I think that’s going to be pretty common.
What seem to be the biggest hang-ups?
I think it just depends on where the provider or the hospital is at right now with their IT implementation plan. Many people are just starting an implementation of a larger integrated solution. Some people have some pieces firmly in place. Like ourselves, we have many pieces of an integrated electronic record system in place, but we have implemented the modules in a different order than the Meaningful Use criteria are dictating.
We’re having to change our strategic IT plan to go, for instance, and elevate CPOE to be something that has to be done within a year; and perhaps, drop some of the other plans we already had to expand nursing or OR documentation into other areas of our operations. We’ve had to switch our priorities because of this. Any time you switch priorities, it takes some time to start up and get that project going. I think that’s what people are challenged by.
Will you be ready in time?
I really believe that in our organization, we will be able to achieve Stage One. Now whether its next year at this time, or whether it’s a little bit later, is not totally clear to me at this point. But I do believe we will obtain it within the next two years.
How do you see healthcare reform and the ARRA legislation? Are they competing with one another, or do they actually complement one another?
We were just talking about that exact topic this morning in a meeting. I think we have three different initiatives out there right now that are on a collision course. Those initiatives are this rush to adopt electronic health records by 2015, the ICD-10 conversion that’s to occur in 2013, and then the IT implications of healthcare reform. Specifically, in regards to the new reimbursement models, such as bundling episodes of care and accountable care organizations. You have all three of those pretty much converging at the same time, and they all have IT implications.
I do believe that some of the things that are being done in the HITECH Act to bring about standardized adoption of electronic health records could help with the new reimbursement model. However, there’s so much more needed to do that than what’s in the HITECH Act. So while they are complementary to some degree, trying to do them all at the same time has me very concerned, especially given that we have heard statistics of a shortage of over 50,000 people across the industry via the healthcare IT industry.
It makes you wonder — where are we going to get the human resources? If money were no object, where would you even get the human resources to do all the work? Plus, we also know that introducing too much change into your HIT applications and infrastructure can cause instability in their operation. That’s concerning — introducing too much change at once, not to mention all the process flow and workflow redesign that need to occur for healthcare IT to be used effectively.
What, in general, do you think Meditech hospitals are going to have to do to get ready for Meaningful Use?
I think, again, it depends on where they are in their software upgrade cycle. For us and for many others that were staying current with the MEDITECH products — I am on the most current release level, which is 5.6 — that will be able to deliver the Meaningful Use criteria from Meditech.
For other hospitals that have not upgraded recently, I think it’s going to be more difficult. It’s not just the Meditech hospitals. Really, you look at any vendor. The queues for people wanting upgrades are very long. We’re hearing 12-18 months just to get a project started. This isn’t just with Meditech. This is with any vendor, because they’re being overwhelmed by upgrade requests.
I think that in the long run, Meditech hospitals will be in good shape; that Meditech is going to see us through these Meaningful Use requirements. But it’s not going to be easy, especially when it comes to the quality metric reporting. This isn’t a technology issue, this is, in some cases, a workflow process issue back at your organization. You can have all the fields in the software that you need to populate to produce a metric, but how are you going to ensure that those data points are collected? How are you going to instill that discipline in your workforce?
What were some of the conclusions that you drew from the HIMSS conference?
As many have probably observed, the conference was largely about Meaningful Use. Some conclusions that I drew personally, was that data analytics are going to be incredibly important over the next 3-4 years.
On top of all these other things we have to do to meet Meaningful Use internally, we are going to have to start, if one hasn’t already, to dive deeply into your clinical data to understand and engage in the creation of dashboards and alerts and other things to keep your progress towards achieving your quality metrics at the forefront of everyone’s attention in your organization. That is going to require, I think, some very sophisticated data analytic tools.
That was probably my big takeaway besides Meaningful Use, Meaningful Use, Meaningful Use.
What are your biggest challenges and most important strategies at this moment?
For Methodist, we decided three things that we’re very actively pursuing. One, no surprise after what I just said, is really looking at our quality data analytics. Two is ramping up to do CPOE with our hospitalist group as our pilot. Of course, that is to meet Meaningful Use. Then the third really important strategy for Methodist is to reach out to our physicians and help them achieve Meaningful Use by offering a hosted electronic record solution to them. We have ramped up in a very big way to be able to offer that to our physicians. We are hosting NextGen for our affiliated physicians in the community and are gearing up to have 100 or more on within a year. We’re growing very rapidly.
I would say those are our three main strategic IT initiatives. Throw on top of that that we are building new hospitals and we are completely integrating one that we acquired last year and converting them to our HIT structure.
I don’t think that’s that unusual. I think a lot of us have all the other challenges. A lot of people have all the challenges we’ve already been talking about, but on top of that, I think many larger organizations across the country are being approached, as Methodist was, by standalone hospitals that are looking and saying, “I can’t navigate through all the complexity that’s coming at me. I need to partner with somebody that can quickly bring me solutions.” I don’t think I’m unique in having that challenge on top of all the other ones.