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Building an IT business plan with health care policy in mind

A regional HIMSS director weighs in on the HITECH Act and other federal proposals that will affect providers' meaningful use compliance efforts and the build-out of their IT infrastructure.

In building an IT business plan, it's important for CIOs and physicians alike to keep an eye on numerous evolving targets, among them the Health Information Technology for Economic and Clinical Health (HITECH) Act, health care reform, federal funding opportunities and meaningful use rules.

Scott MacLean, CIO at Newton-Wellesley Hospital, an affiliate of Partners HealthCare System Inc., addressed these targets and how they apply to a provider's compliance policies and overall IT business plan at the recent New England HIMSS 5th Annual Public Policy Forum in Norwood, Mass.

"Our legislators in the executive branch have been busy," said MacLean, who is a board member of the Healthcare Information Management Systems Society (HIMSS). "There's a lot going on, [but] this is really a fabulous time to be in health IT. It's our time."

MacLean encouraged health care IT managers to think about their facilities' workflows and the ways the following health care policy and regulatory issues might affect their ongoing implementation of electronic health record (EHR) systems and supporting infrastructure:

• Providers, according to meaningful use rules, must give patients either a Continuity of Care Record or a Continuity of Care Document (CCD) after a visit. These standards are evolving, MacLean said, adding that he sees them merging into one CCD standard.

• The Drug Enforcement Agency, which regulates the flow of controlled substances, released a final rule on how e-prescribing controlled substances will affect compliance with DEA regulations. The rule, released on the same day that MacLean spoke, is open to public comment until June 1.

• As of the end of March, the release of the final version of meaningful use rules is targeted for late May or early June. Why pay close attention? The final version could look different from the current proposed version, thanks to myriad comments received by the Office of the National Coordinator (ONC) for Health Information Technology -- including 60 pages' worth from HIMSS alone.

• Right now, the two-tiered, temporary versus permanent structure of EHR certification is still under construction. What do we know at this point? The process will have two stages: testing first, then certification. With only a few months between the final rule's approval and the deadlines for incentives, a provider keeping abreast of this process and applying it to an overall IT business plan could buy welcome time needed to get into compliance, MacLean noted.

• The FDA also is considering the safety of EHR implementations. Dr. Jeffrey Shuren, director of the agency's Center for Devices and Radiological Health, recently testified before ONC's Health IT Policy Committee about how errors have caused injuries and deaths. The FDA is asking "serious questions" about reporting and tracking the safety issues bred by EHR systems, MacLean said, because such systems will gain prominence as the health care sector builds its IT infrastructure.

The legislation and executive orders are in place to be able to make health information technology something that will help change health care and make peoples' lives better.

Scott MacLean, CIO, Newton-Wellesley Hospital

Reporting and tracking could include: requiring EHR vendors to register with the FDA and report adverse events voluntarily; registration with mandatory reporting or even a formal testing and reporting process; or formally regulating EHR systems as a medical device. This could influence a provider's EHR purchasing or its process for deciding about upgrades, or even complicate the meaningful use certification process, MacLean said. Both events will adversely affect a provider's IT business plan.

• Finally, health care reform could significantly affect provider billing and payment systems, reporting patient data for quality-improvement purposes and documenting care improvements in order to reap potential financial incentives through Medicare and Medicaid programs that share savings with providers.

MacLean closed by exhorting audience members to keep their eye not only on the regulatory and financial aspects of the current health IT advancements, but also on the ultimate prize -- improving patient health.

"We have an opportunity to do something great in our generation," MacLean said. "This is an amazing effort. The legislation and executive orders are in place to be able to make health information technology something that will help change health care and make peoples' lives better."

Let us know what you think about the story; email Don Fluckinger, Features Writer.

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