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Meaningful use tying together ICD-10 compliance, HIPAA omnibus

Meaningful use leads many providers' health IT initiatives because it pulls in ICD-10 compliance, HIPAA omnibus plans.

This is the first part of a Q&A with Shane Pilcher, vice president of Stoltenberg Consulting. Here he discusses why next year is a critical time for meaningful use and why it's helpful for hospitals to consult with outside parties when attempting an ICD-10 implementation.

Shane PilcherShane Pilcher

Why are the next 12 months so critically important for meaningful use adherence, as opposed to the last 18 months or the upcoming stage 3?

Shane Pilcher: There are a few reasons why. One, if deadlines aren't met by 2014, then penalties start in 2016. So for those who have not started down their meaningful use pathway, it's making it even more critical that they get started sooner than later so they can hit their final deadline before 2014 [and] can attest without having to fear any penalties coming into place. Also in October of this year, you have to start using 2014 certified systems. So that adds to the complexity of those who haven't even gone down their meaningful use pathways. They have to make sure their vendors have a 2014-certified system and that they have time to implement and attest, or submit their meaningful use numbers.

The sequester is also affecting some of that, too. The CMS [Centers of Medicare and Medicaid Services] gave a notification that any reporting period that ends by April 1 of this year could be subject to a 2% decrease in incentive payments. So for those who have started -- or those who have not started -- April 1 was a potential impact for them, as well.

Your survey indicated that the same percentage of respondents would consult an outside expert for guidance with ICD-10 implementation as meaningful use. What's your advice to ensure both large scale projects move forward effectively, simultaneously?

Pilcher: I agree. Meaningful use has dominated the conversation, but ICD-10 has always been out there looming on the horizon. When the government delayed ICD-10 implementation, it gave hospitals a little bit of breathing room that they needed as they had to focus on meaningful use. It's kind of like the squeaky wheel gets the grease. Meaningful use had deadlines that occurred sooner so that got most of the attention.

However ICD-10 has to be in by Oct. 1, 2014, which -- and it's kind of eerie -- is also the date that you have to have attested for meaningful use to avoid penalties. So for those organizations that have not gone down that road, they have to implement both at the same time. And each one in its own right is very complex. When you start putting those together, it increases the complexity exponentially.

So my advice is to anyone that is doing both projects, especially if they're doing them simultaneously, is getting outside, knowledgeable, experienced resources involved in that process as early as possible to help guide them through that, because they don’t have time to muddle their way through it and figure it out on their own. The timeline is getting so condensed now; you need to do it right the first time. Having that outside knowledge can be critical to that.

Have you found that rural providers are coming to you with their hair on fire saying, "Please help us!" Or are most people getting on that bandwagon in 2013 and realizing that next year is the looming deadline?

If you're implementing an EHR, you have to take the time prior to implementation to analyze your processes ... because technology will not fix a flawed process.
Shane Pilcher vice president, Stoltenberg Consulting

Pilcher: From a rural perspective, not only is their hair on fire, but everything else. Rural hospitals have more of a challenge than some of your larger organizations. They rarely have the resources on staff; their IT shops and internal resources are very limited; and their financial resources are even more limited. Having that internal knowledge is almost guaranteed to be nonexistent. So having someone that can come in and lead them through it is even more critical for them. But it's not just leading them through it, it's making sure you have that transfer of knowledge during the process so their staff can maintain and move forward after you've helped them implement and cross that hurdle. That's one critical piece -- that knowledge transfer.

How does meaningful use enhance processes, as the press release for your survey claims?

Pilcher: We might need to clarify a little bit more about enhancing processes. It all depends on how you define enhancing a process, and what process we're talking about. What I have always advised my clients on is, if you're implementing an EHR, you have to take the time prior to implementation to analyze your processes, to re-evaluate the processes and streamline them and make them more efficient; because technology will not fix a flawed process. If you implement technology around a flawed process, it tends to exacerbate those flaws. So you have to identify processes that are flawed, re-evaluate and then redefine them. Then, when you implement technology around those, it actually compliments those processes so they work together.

From an EHR perspective, the way it will help in processes is giving access to information, which is a critical piece to providing healthcare. Hospitals have to align their business processes with their mission -- delivering healthcare -- and technology helps to do that. Giving clinicians access to that information immediately, allowing us to drive notifications during the patient care delivery to increase patient safety -- all those processes are significantly enhanced by technology. But the underlying process has to be efficient and effective for that to happen.

Is there any measurable return on investment on meaningful use, do you think, beyond getting incentive checks? What are the top benefits you're hearing from clients?

Pilcher: I think there are two types of ROI: hard and soft. When you're talking about meaningful use, you have to look at those to be able to truly assess your returns. With hard ROIs, you're pretty much stuck to the incentive checks -- how much money you're able to bring in from your efforts. Most of the time it's going to be less than what you invested into the process. Very few hard ROIs are out there except for the incentive checks that come in.

The soft ones, however, are increasing patient safety and decreasing errors in patient care. Initially, documenting care is not really improved by technology, but down the road, it is. Once the information is into the system, it's available for you later on. You're able to identify decreases in time that it takes to provide the care and document it, which is a return; it just doesn't have a specific dollar amount tied to it.

Today, being able to assess any decrease in time is another soft ROI. Allowing more than one caregiver to have access to the information at one time is also a soft ROI. Using a paper document, when I was taking care of a patient I'd go to look for their record and if someone else had it I'd have to wait until they were done to get the record and document what I'd done or assess lab results. Digitizing it and having an EHR that multiple caregivers can have access to at the same time significantly decreases the amount of time it take to document your care. I think those soft ROIs are just as important as the hard ones.

Continue to the second part of this Q&A.

Shane Pilcher is vice president of Stoltenberg Consulting, which provides support for senior healthcare leaders. Let us know what you think about the story; email or contact @SearchHealthIT on Twitter.

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