The meaningful use stage 2 schedule has given way to the demands of ICD-10, but yes Virgina, there will be no extension for coding upgrade deadlines.
Last week, the U.S. Department of Health and Human Services announced a clarification of deadlines for meaningful use incentive program participants. While some people might consider it a relaxing of deadlines or even an extension, no, it’s just a harmonization of calendar items — which should have been done long ago, i.e. during the planning stages of all this health IT rollout, perhaps?
The American Health Information Managers Association was kind to HHS, applauding the announcement and calling it an extension for physicians and hospitals that are planning to jump on the Centers for Medicare and Medicaid Services’ meaningful use bandwagon in 2012. They can use the Oct. 1, 2013 switchover date and the rest of the year for another major CMS health IT project, ICD-10 implementation. Unless, of course, they’re working on accountable care, yet another CMS program requiring a heavy dose of IT infrastructure to support data reporting and analytics.
Sounds benevolent on the surface.
Keep in mind this “calendar adjustment” only applies to meaningful use attestation. The U.S. health care system still is steaming toward that Oct. 1, 2013 deadline for ICD-10, and many of the sources we talk to say there will be no changing that deadline. Meaningful users — who are volunteers, as opposed to ICD-10 users, who are not — get the reprieve, especially those who signed up for the earliest rounds of incentive checks. Those earliest adopters get the most opportunity to work the kinks out of their care workflows as they implement all the stage 1 criteria and will likely be in the best position to roll with stage 2. Vendors, in theory, would also benefit, getting a little more breathing room for software dev, certification and customer implementation work in the field before their users are on the clock with the EHR incentive program.
My question is, why wasn’t this scenario imagined earlier, and addressed? This isn’t the first time we’ve seen disharmony among HHS’s various health IT programs. Health care CIOs talk a lot about “big bang” versus “slow rollout” of EHR systems, debating the merit of each approach. Some love to just toss every employee, in every department, into the pool at once and get it over with. Others feel that deliberately taking one’s time will uncover problems the rest of the staff won’t have to learn, because they can be addressed for a relatively small group and corrected before the majority get to experience them.
Both have their pros and cons.
What HHS is doing, however, combines the worst of big bang and slow rollout. A big bang is what we’ve got, with HIPAA 5010, ICD-10, EHR adoption, HIE construction, health reform/ACOs and all the other health IT initiatives happening right now. We’re also experiencing all the small corrections of the slow rollout, such as the deadline extensions, at the same time. Don’t the various leaders at HHS in charge of these programs — or their minions — talk to each other? Wasn’t this addressed in initial planning meetings when setting up this grand health IT plan? In the private sector, everyone’s Outlook and iCal and Google calendars talk to each other. Do they work differently in greater Washington, is there some firewall that prevents people from setting up calendars across departments at HHS?
Any hospital that gets certified by the Joint Commission likely has conducted tabletop disaster exercises to see how natural and manmade disasters will affect the facility’s ability to function. HHS brass should have conducted a similar tabletop exercise to see how all these deadlines — meaningful use, ICD-10, etc. — interact with each other, sequenced them properly, and hardwired them into proposed rules from ONC and CMS. Is that too much to ask?
Bottom line: They’re expecting an awful lot from providers, who are pulling the load in building our nation’s health IT infrastructure. The least they could have done is synched up their deadlines before the final rules were issued.
Granted, this whole health IT thing contains a lot of moving parts, and CMS has to follow Congressional edicts for some of these timetables. In fact, we contacted HHS and asked them how much of this calendar trainwreck was a result of mandated deadlines and not, in fact, a lack of planning. They didn’t respond. And so were left with wondering, was this whole health IT buildup (ICD-10, EHR adoption, ACOs, all of it) planned in a rush? Sure looks like it.