As you may know by now, a long-awaited Notice of Proposed Rule Making was issued on December 30^th by CMS to outline the criteria for providers to show “meaningful use” of electronic health records. It is perhaps the most important news from the government for our industry since ARRA was signed into law last February. We produced several resources to help providers navigate the criteria and work towards qualifying for ARRA stimulus payments: 

• Getting to “Meaningful Use” - an online guide that walks providers through six critical steps toward becoming meaningful users of EHRs, including tips and advice on: researching EHRs; what to look for in product demos; planning a timeline for selection and implementation of the EHR; and preparing their staff for change.
• NextGen Community Forum - a public discussion board for providers to post comments and questions about meaningful use criteria. NextGen Healthcare will incorporate the feedback in its official response to CMS.
• Economic Stimulus and Healthcare Reform Update – a bi-monthly webinar series where you can learn how to maximize your stimulus incentives.
• Inside Health Reform - a stimulus portal with case studies, videos, white papers, and an EHR revenue improvement calculator.
• Grants Resources Center - valuable information about Beacon Communities, SHARP and other funding being made available as part of ARRA, and how NextGen can support your application submission.

I hope you find these resources helpful. We’ll keep them updated with fresh, actionable content that will help you get to meaningful use.

Last week we saw the release of $851 million in grant funds to the nation’s community health centers. Selected centers may choose to allocate some of their grant funding towards either the adoption or expansion of health IT solutions. This being the first of the major grants distributions from the American Recovery & Reinvestment Act (ARRA), it can also be viewed as a reminder to all general practice physicians that the time for them to be eligible to receive qualified funding is nearing.

In the most recent NextGen HIT Stimulus Update video I stated that physicians should be making their HIT purchasing decisions now. Physicians should not be lead astray by possible confusion around meaningful use, but rather take the information they do have and make the best-informed decision they can for their practice. The CHC grant release announcement is proof that this is the case Why would the government release such a large portion of money for HIT investment if it was not comfortable that there was sufficient information on meaningful use for providers to select the right IT solutions- remember CHC’s have to comply with meaningful use as well.

Whether a CHC or an independent medical provider, begin your selection process now- 2011 is only 18 months away.

I am very happy to report that today, as was thought, the Office of the National Coordinator released some additional recommendations to help define “meaningful use” for physicians. Clarification around this term is key for physicians who have been on the fence of the health IT purchase.

The meaningful use preamble and matrix are available on the NextGen Stimulus page. You can view the documents at:
Meaningful_Use_Matrix_6-16-09.pdf
Meaningful_Use_Preamble_6-16-09.pdf

What are your thoughts on this first glimpse into meaningful use criteria?

The Federal Government is close to weighing in on the definition of meaningful Use. We expect news on specific criteria imminently, maybe as early as tomorrow.

Still, even as we inch closer to receiving clarity, physicians should not let any confusion around this term keep them on the sidelines of the HIT decision making process. Physician practices and hospitals can be using what they know today to determine which HIT solution is best for them.

Some specific questions I’d recommend you’d ask the various HIT providers whose product you may be include:

·      Is their product certified under the current CCHIT program and, if so, in what year?

·      Is their solution capable of electronic prescribing?

·      What type of support will your practice receive as you go through the cultural change of switching from a paper to an electronic-based system?

Each of these key considerations will not only be important as you look to complete a smooth transition, but are also factors in the level of incentive funds you receive back from the Federal government for the HIT purchase, implementation and quality reporting.

You can also see more by viewing a recent video that looks to provide information and guidance for physicians as they start the HIT buying process. http://digg.com/d1tdg5

Coming off of the HIMSS Annual conference where the big talk was on the American Recovery and Reinvestment Act (ARRA), the major discussion now must center around what the government will be determining as a certified HIT solution for the medical providers to be able to show meaningful use. There are many opinions circulating around these two concepts. I will offer my opinions here.

The only logical program for the government to pursue - given the timeframe in the law to have a set of standards in place by 12/31- is to start with the CCHIT process as of CCHIT 2008. However this is not enough because the interoperability criteria and the data reporting components of meaningful use must be built from there. So, beyond CCHIT 08 we must move quickly.

Any HIT solution that is not starting from this set of criteria today, will not be supporting the government’s position to address meaningful use in a complete way. To help focus this dialogue, the Electronic Health Record Association (EHRA) is working on a position paper to begin the discussion. I encourage all to review this document, once it becomes available and offer comment.

One might say that I am completely biased –coming from an HIT provider that is a member of the EHRA and is already CCHIT 08 certified. I would suggest that if we are truly embarking on an automation plan as designed in the ARRA, and we want to keep patient care foremost in our mind, there is no other course of action.

However, to be fair, I would invite the reading public to offer alternatives – either on this blog or on others- so that the patient consumer can be assured that the taxpayer money in the ARRA is being put to the best use. Patient care needs to be first, the ability of the clinician to use automation properly for enhanced patient care needs to be considered second and then the perspectives of the HIT providers can be discussed third.

I have been reading with great interest the reports and responses to Wal-mart's recent announcement regarding their plan to begin offering EHR’s to the physician community. This action by a retail giant is another example of the fact that automation of our health records is gaining more and more credibility by the American public. I will leave the editorial comments about their plans, product and distribution channels to others who probably would be perceived as having a more objective view of this, but rather will confine my comments to issues about this effort that I have not seen addressed yet: cost of program implementation, interoperability plans, and the newest term to reach our HIT discussion rooms - meaningful use.

1. TOTAL COST

   I find the discussions about the "price" of an EMR product are missing the majority of the cost issue. Most industry consultant experts tell us that in a successful EHR installation, the cost of the actual software turns out to be less than 50% of the cost of the project. What is often missed in initial cost discussions is the training dollars and often they are never fully calculated until the project plan is complete. The reason for this is that physician adoption of automation is as much about how the physician adapts to his new- found tools as the quality of the tools. If you learn to drive safely, you can handle a $20,000 car that can get you from New York to Washington D.C. If you drive poorly, you can wreck your $100,000 Bentley before you get out of your driveway!! Look at 10 successful EMR installations and you will see training and implementation costs at least equal to the cost of product. A quality product comes with a quality program - nothing less.

2. INTEROPERABILITY

   No one EMR product is going to be in every physician office, just like no one car is going to be driven by every American driver. So, I fully agree with the authors of our recent national EMR legislation that certified products must be able to "talk" to one another in standardized ways. This capability is almost never addressed in preliminary discussions about EHR product cost - largely because this cost is usually not fully comprehended until the entire landscape of automation – in and outside of the physician office it is determined. However, what can be determined up front is that the basic product has the capability in it from the start, to be interoperable. This will only happen if the product can show – by performance – that it is currently sharing information in real time with other products. So part of the initial purchase investigation must be- "show me where your solutions are actually sharing data in real time with other solutions in the marketplace".

3. MEANINGFUL USE

   I left this issue for last because it is by far the toughest issue to deal with, because frankly it is as much about product as it is about behavior. I have seen high performance physician groups using high quality product struggle for months with collecting and sharing data- one of the keys to meaningful use of an EHR- not because of poor product or lack of training but rather lack of the discipline to adopt practices that consistently and uniformly collect and report data. Why is this so? In my opinion, it is because the physician organization has not grappled with the cultural issue that most physician practices today are not imbued with the philosophy that they need to collect, study and uniformly report data on how they practice medicine. I believe that the biggest reason by physicians may have trouble qualifying for the new Medicare and Medicaid incentives for EHR use is not going to be because of lack of product purchase, it is going to be because of lack of ability and discipline to collect and report data (and then modify behavior as a result of the results this data collection).

So, when examining whether Wal-mart’s strategy is sound or their plans are complete, I welcome a discussion around the three points above beyond the bargain basement price or mass distribution techniques being addressed. This is my viewpoint- what’s yours?

Many physicians have all voiced the same question with regard to Health IT and the national stimulus package:

“Considering that financial incentives in the new American Recovery and Reinvestment Act (ARRA) will not start until 2011, why do I "have" to select my EHR as early as this year or even by mid-2010?”

An important point to remember in considering when to begin your selection process: it can take up to 18 months from analysis to mastering the ability to collect and report the RIGHT information to the federal government.

If you accept this argument, then the next question that surfaces is:

“How am I going to pay for this system if I don't even start to receive money from the government until January of 2011? Furthermore, the how can I plan around a payment schedule has not been determined yet?”

Physicians need to know that there are resources and funding opportunities out there to help.  Those that they can look to and that I’d recommend include:

·      Once live on a system, physicians can begin to quality immediately for the 2% e-prescribing and 2% PQRI bonuses that will be paid in 2010

·      There are revenue cycle management programs that can potentially help the physician build revenue today to pay for this system.

·      The ARRA provides significant money in grants for programs that can provide some “seed” money to help the doctor get started.  Physicians can explore these options through the NextGen Grants and Funding Resource Center, their local hospital or through various reputable grants writers working in the industry today

It’s a brand new world of health care, and with health care reform legislation now looming, the physician needs to get engaged today to get the maximum benefit.

With the advent of significant funding for health information technology in physician offices, there is a real opportunity for physicians to begin to broadly experience the value of gathering medical information from multiple physicians regarding the care of an individual patient. Not only will this information be in “real time,” but this dialogue will give physicians treating the same patient the opportunity to consider the comments of other doctors shortly after care is rendered. I am interested to see how physicians will embrace this newfound opportunity to share secure patient information almost instantaneously.