Like you, we’ve read article upon article of coverage on meaningful use stage 2, and checked out the rules themselves. From our media perch, we’ve also had the benefit of seeing and hearing CMS and ONC officials address stakeholders online and in conference calls. And interviewing some of them ourselves.
As such, we have a few opinions – and take them for what they are, opinions formed a few days after the feds issued the rules, subject to change on a whim – on what a few of the challenges stage 2 will drop into the health care CIO’s lap.
As a tribute to all the kids going back to school, a time that causes relief and celebration among parents nationwide, we’ll present them as sixth-grade math story problems:
- A physician attests to meaningful use stage 2, which includes the CMS-required equivalent of swearing over a stack of Bibles that, yes, enough patients requested electronic copies of their health information to qualify for EHR Incentive Program funds, and furthermore, that more than half the patients were offered access. A meaningful use auditor shows up at his door three weeks later. How does he prove it?
- An EHR vendor goes out of business, a situation that thanks to relief clauses written into stage 2 buys a meaningful user (either an eligible hospital or provider) time to get back into compliance and thus eligible for remaining incentives. How does the CIO find the budget to purchase the next system and migrate patient data into it? Extra credit for inventing a method that does it so quickly and efficiently that said health care provider isn’t forced to temporarily go back on paper.
- Physicians have to prove they sent at least one summary of care document to a recipient with a different EHR (or successfully testing with CMS test EHR). Write the script to enable a solo doc to approach a local hospital or physician group CIO/compliance officer to accomplish the former; assume it’s in a competitive region where every patient and payer dollar counts.
- There are 24 hours in a day. Find the time and expertise to build the software and hardware infrastructure to support a physician group’s quality reporting, accountable care organization requirements, ICD-10 implementation, various Affordable Care Act compliance initiatives, security technology for HIPAA compliance, and meaningful use attestation done by the end of 2014. Oh, and there’s a new batch reporting feature for stage 2 attestation, which needs to be figured out for your group. Go.
- A provider’s half-built HIE seems to be run by underpaid, half-engaged workers who are counting down the days until grant funding runs out and also appear to be hogging half their organization’s Internet bandwidth shooting out resume PDFs and playing fantasy football. Explain how using Direct fulfills objectives such as “successful ongoing transmission of immunization data.”