Admittedly this is an unfair question in the moment because there isn’t an answer yet! We have, however, seen CMS’s initial definition of meaningful use for hospitals and to describe it as invasive is not an exaggeration. At a recent meeting of hospital CIOs a key point was driven home; the doctors must have “hands on keyboards”, not simply dictate or provides notes to others for entry into an EHR system. This mandate suggests not only the capturing of information as a requirement, but also changes to the workflows surrounding the data capture. The hospital CIOs agreed that implementing the technology in their companies was much easier than ensuring the clinical staff adopted the technology and adjusted their workflows accordingly. In other words, implementing an EHR solution is a business challenge which includes a technology component, not an IT project.
The post-acute healthcare sector expects to receive more clarity on meaningful use, and potential funding, late spring/early summer. In the meantime, LTPAC has recommended that meaningful use for hospitals and doctors include the requirement to exchange health information with all providers, including those in post-acute healthcare. It is a reasonable assumption, if not a foregone conclusion, that this multi-directional sharing of information will be a requirement for all post-acute healthcare providers. In addition, LTPAC’s comments on the initial CMS definition of meaningful use suggest a significant effort lies ahead for the post-acute healthcare sector to be compliant and interoperable.
So, what does this mean to post-acute healthcare providers? Here are a few questions to consider:
- Does your business strategy include implementing an EHR solution?
- Has the solution been selected? Has it been piloted? Does your vendor’s roadmap include CCHIT certification?
- Does your multi-year budget account for the investment in infrastructure, software, integration, and training?
- How will your EHR solution be interoperable with disparate hospital systems, doctors, and other post-acute healthcare providers?
- What information do you expect to receive from other providers?
- What information do you expect to contribute to other providers?
- Will you build individual interfaces to each provider with whom you will exchange information?
- Do you expect your application vendor to provide this capability? If so, who will fund the cost?
- Will you allow other providers to access your application? If so, how will you handle security authorization and access?
- Will you use one or more exchange gateways to allow for information exchange and access? If so, which ones and how will they interface with your EHR solution?
- In all of this, how will you ensure your information is HIPAA compliant?
- And, if you can’t answer these questions, what are you going to do in order to be able to answer them?
This is a subset of the questions each post-acute healthcare provider must be contemplating and ultimately address. While some of these questions may seem beyond your ability to answer until CMS finalizes the definition of meaningful use for post-acute healthcare, others can be answered now. One thing is for sure, you will be required to have your own EHR house in order. What is critical in the moment is that your organization has a firm grasp on the issues surrounding your interoperable EHR, a shared vision of priorities around EHR, and a multi-year implementation and investment strategy that can be executed and monitored.
To paraphrase a popular commercial from a few years ago, “it’s not your father’s post-acute healthcare.” What are you doing to get ready?
All the best,
Loren Claypool, Managing Director