Why? There are lingering issues that are causing many who thought they were ready to attest to meaningful use to pause. The most serious concerns involve certification, the quality metrics and timing of the stages of meaningful use.
Almost 10 years ago, I led our organization away from best-of-breed systems to use an integrated electronic health-record system from one vendor. Thankfully, that decision got us around the certification roadblock. But for many of my colleagues who use products from more than one vendor, the path to having a certified EHR has become muddied.
We now know that you must possess all the modules that a vendor used to achieve its certification even if you are not using them to demonstrate meaningful use. This is further complicated by the fact that many major vendors certified their products only as complete EHRs, and their modules do not inherit the certification when those modules are used separately. Some vendors are going back to the certification bodies and seeking modular certifications for some combinations of their products. In the meantime, purchasing overlapping products or going through the arduous process of self-certification remain the only path to compliance for providers.
After making an upgrade this spring, my team began exercising the quality metric reports and we hit the wall. With confidence I, like many, had looked at the quality metrics and said, "No problem, we already report many of these metrics to the CMS through various quality programs." But what we found was that the required data was stored in the wrong fields or that it was not properly mapped to required codes or—worse yet—it was being manually abstracted from physician notes in the medical record. I am hearing that my colleagues from all over the country are having the same experience. The complexity of creating the quality metrics has become "the issue" for many who thought they were ready.
Because of these revelations, along with the CMS attestation screen asking one to attest that the "information is accurate and complete," I asked the CMS for guidance. With no physician documentation and only certain percentages of nursing documentation required in Stage 1, complete accuracy of data derived solely from the EHR would be impossible. We did get some good news recently in CMS' FAQ (PDF) Answer ID10589, which says that the quality metric results are not being assessed at this time and that there is no need to manually enter abstracted data into the system. This put us back on the path to try to create the quality metrics with the data we had in our EHR.
Lastly, there has been a lot of advice issued about the timing of attestation and attempting to coordinate attestation to the stages of meaningful use. Many providers are undecided about whether to rush to attest in 2011, even if they are almost ready. The concern is that providers attesting in 2011, who will be in Stage 1 in 2011 and 2012, must start a full year of compliance with Stage 2 on Oct. 1, 2012. This would be an impossible feat in light of the fact that the Stage 2 requirements will not be finalized until the summer of 2012.
Why, then, do I press forward? I have been in conversations in which the Office of the National Coordinator for Information Technology and the CMS have acknowledged that we have a "train wreck of timing" on our hands. I believe there will be some remediation to this situation. The policy committee has been tasked with studying this and has been making recommendations. The options so far seem to be starting Stage 2 in 2013, another 90-day ramp-up period or requiring increased levels of compliance to Stage 1criteria on Oct. 1, 2012.
If you are pondering an intentional delay in attestation, please consider the following:
- Starting in 2012 or later compresses your time frames to move from Stage 2 to Stage 3.
- Everyone must be at Stage 3 in 2015, regardless of their start date.
- Some 70% of your Medicare incentive funds come during the first two payment years, and those two years will be in Stage 1 only if you start in 2011 or 2012.
The CMS and ONC have been proactive in seeking input—they really do want all of us to succeed in achieving meaningful use and obtaining our incentive payments. As chair of the CHIME Policy Steering Committee and in collaboration with other associations, I will continue to educate and seek remediation from ONC and the CMS on these issues and obstacles.
Senior vice president and chief information officerMethodist Health SystemDallas