Leaders from healthcare organizations and associations, lawyers, consultants, IT vendors, and a host of other experts are slogging their way through all 800-plus pages of the Centers for Medicare & Medicaid Services final rule for the meaningful use of electronic health records. They have plenty of opinions about what's right and what's wrong with the rules. And that's fine. But it's also a good idea to think about something more important than what could have or should have been: What happens next?
The long-awaited final rules spell out exactly what hospitals and physicians must do to qualify for their share of a pool of roughly $27 billion in bonus Medicare payments over the next ten years for using electronic health records (EHRs). Eligible professionals can get up to $44,000 under Medicare and $63,750 under Medicaid, and hospitals may receive millions of dollars for implementation and meaningful use of certified EHRs under both Medicare and Medicaid.
Providers and vendors have been playing guessing games on what the final rules would look like and placing bets on when, exactly, the final rule would be announced. Some have predicted it will be an unfunded mandate. Others were skeptical it would ever come to fruition at all.
"There should no longer be any doubt that this program is real," says Charles W. Jarvis, vice president healthcare services and government relations for NextGen Healthcare. "Hospitals should be able to march ahead and make some final decisions."
Leigh Burchell, director of government and industry relations for Allscripts, agrees. "People who were in a wait and see or even wait and understand mode are now trying to understand, because it's real," she says.
A number of organizations have objections about the final rule—ranging from security and privacy concerns—to worries that smaller or individual hospitals in multi-campus settings will face barriers to achieving widespread IT adoption.
"We continue to be concerned that, given limited vendor capacity and workforce shortages, many hospitals will not have timely access to certified products, since no certified EHR systems are available today," said Rich Umbdenstock, president and CEO of The American Hospital Association (AHA).
AHA also frets about the timeline for Computerized Provider Order Entry (CPOE), says the certification process penalizes early adopters by requiring them to upgrade or replace already functional systems, and adds that the rules limit how quickly hospitals can adopt a certified EHR that can benefit patient care.
"The challenge now is to extend its use and integrate it into the routine care processes in all hospitals, big and small, in both rural and urban areas," Umbdenstock said.
(See Winners and Losers in HHS Final Meaningful Use Rule and HHS Meaningful Use Final Rule Draws Guarded Initial Praise for more on the initial reaction to the rule.)
But concerns, quibbles, and complaints aside, it's time for healthcare organizations to get moving.
Get out the roadmap
Whether they've been sitting on the fence waiting for the final rules to come out or planning for their eventual release, providers will begin taking more concrete action, such as hiring IT staff and investing in hardware and software, says Mitch Morris, MD, national leader, health information technology for Deloitte Consulting.
"As health care IT leaders move forward with their plans they will want to develop a clear roadmap," Morris says, adding healthcare leaders should consider the following questions:
"A meaningful use roadmap should include not only goals and expected outcomes, but also timelines, staffing requirements, and a projection of expected capital and operating costs. Factor in the risks involved and the needed controls," Morris says.
Mark Segal, vice president of government and industry affairs for GE Healthcare IT says healthcare leaders should also scrutinize potential vendors' roadmaps, as well-and where they are in relation to the meaningful use timeline—which is broken into three stages over the next few years—stage two starts in 2013, CMS has not yet set a date for stage three.
"It's not just where we are for stage one, it's pretty clear that you've got an accelerating trajectory," Segal says, noting that while CMS softened some stage one requirements, they didn't eliminate them. Rather, they've been deferred to stage two. "It really is going to be important that people look at stage two," he says. And "2013 is around the corner."
The meaningful use rule is a turning point for the industry, says Glen Tullman, Allscripts CEO. "The time for waiting is past and we're seeing people already acting in a very dramatic way," he says.
So what's his advice to healthcare providers? "The advice is get going. You don't want to be the one that, by the time you decide, no money is available," he says.
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