"Organizations that are more mature on their EHRs, or have been using health IT for longer, may actually be more challenged in this measure than people who just went up on an EHR," Kreofsky says.
She illustrates the point by explaining that seven or eight years ago, when those providers implemented their EHRs, some standards now baked into Meaningful Use Stage 2 did not exist. "LOINC was something you kind of talked about, but nobody was using very robustly, and then all of a sudden you're in a place where you have to implement it, and you've got 12 years of lab data that's not LOINC-coded and you've got all these downstream interfaces, and you need LOINC for your lab results, which is one component of that summary of care record, so it has this cascading effect," she says.
LOINC is but one example. There are others. "It's the little things that quickly become big things," Kreofsky says.
Some providers built what, at the time, was innovative portal technology. But in doing so, they deployed part of their EHR vendor's patient engagement portal, overlaid with data pulled from another source, overlaid with another user interface, and a different login procedure than the vendor's own, Kreofsky says.
"I'm not saying they're going to have to step back or rethink their plans, but they may have to," she says. "They may suddenly discover that they need to rework something that, while it's not broken, is not in compliance."