Posted by: Jenny Laurello
CFO, CMIO, EHR, EHR incentives, EHR incentives program, Joe DeLuca, Meaningful use, MU
Guest post by: Joseph DeLuca, Knowledge Architect, Fulcrum Methods
The first reporting year for the ARRA HITECH hospital EHR incentive program ended on Sept. 30, 2011 with the closing of Federal Fiscal Year 2011 (FFY11), and the first reporting year for eligible professionals will close on Dec. 31, 2011. Money is flowing to eligible hospitals and professionals who have qualified, EHRs are getting implemented and clinical behaviors are changing. So has program year one comes to an end, it offers a time to learn from those on the journey to meaningful user status. What have some of them, my clients, to offer as guidance?
First and foremost, “Nothing is easy…working through the PECOS registration processes as well as the Medicare and Medicaid incentive program registrations may not be a straight forward process, and will likely involve multiple administrative staff within a hospital or organized medical group. Start early, work with your physicians on funds flow, get registered and cleared through CMA and state systems or else you may be in for problems when it comes time to report and attest” was advice given from the CFO of a Texas based multi-hospital system with a controlled medical group.
Across all of the hospital and medical groups I am working with, the registration process seems to be both smooth and easy, or an administrative nightmare. One CFO at a hospital system wondered out loud how they were actually getting paid by Medicare. And all medical groups face at least a serious conversation — if not a governance challenge — when discussing the assignment of individual professional incentive dollars to the medical group for team benefits.
“It’s critical to engage the organization’s CFO at the earliest possible moment. In our organization, he is the one who will (and did) sign off as the attesting officer, and has the organization is ultimately aligning its resources around financial goals, it is imperative that he be the champion from an early stage,” noted the CMIO of a California hospital who attested as a meaningful user in FFY11.
The CFO fiduciary duty expands with meaningful use attestation. The CFO is the most likely attestation officer and will sign under threat of perjury that the organization is truthful in its attestation, will refund overpayment if received and will maintain documents required to support and approve attestation. And as the program is evolving, issues related to revenue accounting and recognition timing, as well as Medicare and Medicaid cost reporting implications for meaningful use incentive dollars will fall under the CFO mandate. Compliance officers are in place to assist, audit and assure the boards and CEO that rules are being followed, but the CFO appears to bear the weight of this responsibility.
One EMR project coordinator at a multi-hospital academic medical center stated that “Implementing an EMR is not enough. Meaningful use means many clinicians across your organization and health system must change the way they work, and operational leaders must be accountable for assuring the change is a priority. Make the investment in contracting with an objective, knowledge resource to evaluate your internal assessment, help your team understand the complexities of the HER incentive program and educate upward and outward. This is one of the best things we did.”
The depth of change required to meet the meaningful user measurement criteria is, by design, a challenge, although not undoable. Organizations that have implemented enterprise-wide Computerized Provider Order Entry or even just in key clinical departments such has the emergency department appear to have an edge in getting the cultural change process in place to achieve meaningful use. But seemingly simple workflows become very complicated. For example, to implement a middle of the night process for providing a patient with an electronic copy of a discharge record and care instructions requires an authorization and tracking process, software, training, a write enabled computer workstation, thumb drives (or other media if a personal health record is not used as the media) and a caregiver who has the time to complete this patient request. Missing one of these likely low volume events could put a reporting numerator and associated measurement percentage provided below the threshold, and put the work of the entire program in jeopardy. Stages 2 and 3 will add further requirements, many in non-traditional care areas, which will further expand the depth of change.
In my next posting, I will continue with perspectives from the field, and also discuss the perfect storm coming in health care IT around ICD-10, accountable care, meaningful use and provide thoughts on a holistic approach to survival and even thrive.
For more information, please visit www.fulcrummethods.com.