Meaningful Use: What to do if you’re behind in your preparations
If you thought it might be further delayed, you were wrong
There were a lot of hospitals and healthcare providers who believed that Meaningful Use would go the way of ICD-10 coding: It would be delayed and delayed and altered and delayed again. So instead of jumping on any bandwagon, they opted to wait. Now, however, some of those facilities are finding themselves very behind in their preparations, and now Stage 2 is bearing down on them. There is at the outside less than a year to get prepped for Stage 2 implementation, when organizations have to not just collect specific data electronically, but begin to share that data on exchanges and begin to use the data to help make real-time clinical decisions.
Marcy Cheadle, RN, director of advanced clinical applications at Spokane, WA-based Inland Northwest Health Services (INHS), says she has helped more than 20 hospitals achieve Stage 1, but be pretty far down the path for Stage 2. Another four are attesting for Stage 1. They range from critical access hospitals with just 25 beds to facilities with more than 700 beds.
INHS is a non-profit organization that runs a rehab hospital, a critical air ambulance service, a tele-health network, and a technology division. Its 200 tech experts often run the IT systems in hospitals and health systems throughout the inland Northwest region, as well as in other areas of the country. Among the INHS facilities are more than a dozen on the Most Wired list by Hospitals and Health Systems magazine, and 14 received stimulus funding for their electronic health record programs.
“Organizations that were forward-looking have already attested for Stage 1,” she says. “I really think that where hospitals should be is ready for Stage 2 now, but I think there were a lot of people who just wished this would all go away.” Part of the reason is the financial burden involved for those who were going to have to change vendors, revamp IT systems, and get everyone in the organization on board the Meaningful Use train.
“The government is now aligned to reform the payment structure for healthcare, and that is driving this shift,” Cheadle says. “Those who chose to ignore this are running behind now. What I would have hoped would be a majority of hospitals starting this in 2011 wasn’t a majority. There have been increases every year, but I think there is a real sense of panic setting in for those who haven’t gotten ready yet.”
INHS was “aggressive” in getting its facilities ready. For example, of the 14 facilities that received stimulus funding last year, all held Meaningful Use kickoff meetings that involved technical staff, providers, and physician champions. There were weekly meetings held to provide information and make sure everyone knew where they were on the journey and what was coming next. The hospitals all had daily dashboards to spur a sense of competition. (An example can be seen here: https://irm.inhs.info/uploadedFiles/Meaningful_Use/dashboard%20screen%20shot.pdf.)
Cheadle says there are many people wondering what they should do now to get back on track and be sure they meet the requirements set out by the Centers for Medicare & Medicaid Services (CMS) for Meaningful Use. “Hospitals didn’t engage with regional extension centers and now they are losing funding. They are largely on their own if they didn’t get on board before.”
So what can you do at this late date? There is no way to reach Stage 2 readiness by the June 30 start date you’d need for a 90-day period of data collection. Building what you need by then would leave inadequate time to ensure a stable system, she says. But you can get ready for next year.
The first thing Cheadle says you should do is to educate yourself on Meaningful Use. (For a list of resources, see box page 51.) And not just on the basic requirements, but on the vision it represents. “To get the best bang for the buck, it’s not just about meeting the criteria today, but about how you can use today’s criteria to build for tomorrow’s needs, and for what will happen next year and the next decade.” Anticipate that what you read about now will just be the beginning, and CMS will increase requirements over time.
You also need to understand the definitions and terms that the government uses. “There are specific definitions you need,” Cheadle says. “You can’t interpret their terms or use some other word. You need to understand their nomenclature and use it.” Just a couple days of reading will bring you the level of understanding you need, she says.
Once you understand the vision, do a current state analysis of where you are compared to what Meaningful Use requires. Note where your gaps are and then create a project schedule. Cheadle says a simple chart is all you need. The columns across should have the following headings:
- Date met
- Stage 1
- Measure (% or other)
- Department (check box)
- Unique Patient (check box)
Fill in the chart with the 14 core objective and 5 menu objective measures you choose to attest to Stage 1. For Stage 2, there are additional core objectives. (See the entire list at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_MeaningfulUseSpecSheet_TableContents_EligibleHospitals_CAHs.pdf.) You can add in spaces for those additional measures in your Stage 1 template to be ready for the next step.
Cheadle says you can probably do your gap analysis within a week. (A sample is available at https://irm.inhs.info/uploadedFiles/Meaningful_Use/final%20gap%20analysis_ABC.pdf.)
“There aren’t a lot of easy checklists to do this,” she notes. “I think the easiest thing to do is to sit down and just write down how you are planning on meeting each objective, what is in place today, what do you need to do to meet it, and whether this is an opportunity or a weakness.” Strike off the list any element you are already doing that needs no further work. You want a final to-do list that includes only what you must get done, and likewise have a nice list of things that you have already completed, whether they are on a certified vendor platform or not. If you are already collecting some of the data, you need to know it. “It can be overwhelming to focus just on where you have to get. It can be hard to take the first step. Seeing what you are already good on can ease your mind.”
Then create a schedule. Start at your required end date. If you are trying to meet the requirements for Stage 2, you have to be done by May 31 at the latest so you can have a good month to stabilize your program before your 90 days of data collection begin, no later than July 1. Work backward from that end date to determine what you have to do by when. Keep your resources in mind. If you have limited pharmacy resources, don’t do all your pharmacy-related projects at the same time.
But you don’t have to do the projects one at a time — they can overlap as long as you have the proper resources, she notes. However, if it isn’t realistic to be ready for this year, then take a step back and work toward being ready in 2014. This doesn’t mean you can relax — if you aren’t ready, Cheadle says you obviously have work to do. And remember in 2014, if you are just starting Stage 1, you have to use a federally recognized quarter for your data collection — not whatever three-month period you choose. The very last quarter to collect data will be the April-June quarter of 2014, so there is still less than a year to be ready for that data collection. If you are not ready by then and wait for the following quarter, you will pay a penalty.
Also note that some of the Stage 1 rules have changed since the first group of hospitals attested in 2011. If you did some work back then and put it on hold, go read the new requirements, she says.
In the coming year, make sure that you are communicating with your vendors and determine if you will need any hardware, software, or system upgrades to achieve Stage 2 status. Also be thinking about Stage 3, Cheadle warns. “That was a mistake people made. For rapid attestation of Stage 1, they did just the minimum amount they needed to check the box off. That doesn’t align a program to leverage what you did to help achieve the next stage. A lot of those organizations are having to go back and start all over. That’s time and money wasted. And who has extra time and money?”
Think about what the government is requiring and how it will impact workflow — the nurse at the bedside, the physician on rounds, the housekeeping and food service staff. “Step back and take a look at everything,” she says. “Don’t just implement something without determining how what you are doing can have a positive effect on outcomes.”
Further Resources for Meaningful Use Stage 2
• CMS has a toolkit for Stage 2 readiness available online at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_Toolkit_EHR_0313.pdf#page=24.
• The National eHealth Collaborative has resources, including a webinar, available at http://www.nationalehealth.org/event/getting-meaningful-use.
• INHS has a list of helpful links at https://irm.inhs.info/Sub.aspx?id=1886.
• President’s Council of Advisors on Science and Technology report from December 2010 provides a sense of vision on HIT: http://www.whitehouse.gov/sites/default/files/microsites/ostp/pcast-health-it-report.pdf.
Bringing docs on board for Meaningful Use
Explain how data can help improve care
One of the earliest adopters of health technology was the small 55-bed Parkview Adventist Medical Center in Brunswick, ME. They went live with an electronic health record way back in 2005. “The chief financial officer never met a module he didn’t like,” says Larry Losey, MD, the chief medical information officer at the facility. “He wanted everything in our Meditech system, and so Meaningful Use was a validation for us of everything we had already done.” While the systems were ready, the hospital still had to do work to get the numbers to what CMS wanted, but that was more about shifting physician’s clinical behavior, not about tweaking systems.
The hospital is already getting ready for Stage 3, and he has some good advice for getting physicians on board with the earlier stages. Losey says physicians at his facility mostly worried about the value of discrete data. How can what a computer captures really be of more use and import than what doctors know and see, and then write longhand into a paper chart? He says you have to push hard, and explain how data will be a tool that will help them to provide better and more consistent patient care. A computer won’t take over medicine, but the data from large numbers of people will certainly tell physicians more about what works with specific kinds of patients.
Letting them know the financial hit they and the hospital will take without the discrete data generated by Meaningful Use may also get them on board, he says. “We need this for our quality metrics. CMS can’t tell if a CHF patient had an echo without that checked box. That’s today’s world.”
Losey recommends that physicians be included in and engaged with all meetings related to technology and Meaningful Use issues. Even if they don’t come, the meetings related to it should be open to all physicians — actually to everyone, he says.
“If they want to learn more about how to use our systems, they should come to the meetings and spend time with the IT people,” says Losey. And the IT people should never be viewed or referred to as something apart from the rest of the hospital. “They are part of the team.” A vital part who can be great at giving physicians help that will make them more efficient — think about the guru who can do what you do in half the keystrokes because she knows shortcuts, or the IT guy who can show your hunt-and-peck-typing doctor how to use speech recognition software — and even turn some of the biggest naysayers into champions.
Meaningful Use can’t be seen as an IT project that a specific department runs. It’s a new way of life that IT will help physicians and others learn to manage. “Computers are more than a place to keep records. They are there to store data and help us make sense of it,” Losey says. “They are a tool to remind us that if you change this person’s medication, her heart might stop, or that person needs a flu vaccine, and he needs a colonoscopy.”
Physicians are often hard to bring on board, but Losey says that when you talk about IT as a tool to help them practice medicine, they come around. “I can click override if I disagree with something the computer says, but in general, the systems we have created remember much more than I can and do a better job at pulling information and data from various sources than I ever could.”
Lastly, Losey says you should get involved with your vendor user groups. He says the group he uses has been a great resource for him, linking to other like hospitals that may have the same issues his experiences. “Identify peers and have a collegial relationship.”
For more information on this topic, contact:
• Mary Cheadle, RN, Director of Advanced Clinical Applications, INHS, Spokane, WA. Telephone: (509) 232-8100.
• Larry Losey, MD, Chief Medical Information Officer, Parkview Adventist Medical Center, Brunswick, ME. Telephone: (207) 373-2000.