Can You Prove It?

Marc Holland

Now that ARRA meaningful use guidelines have been announced, hospitals are going to face a real challenge: proving it. Though providers may meet the governmental requirements for meaningful use, demonstrating they do may be another story - especially when they are already swimming in data and proof often comes from a variety of different systems.

Many agree that reporting strategies will need to be put in place, but in the first year, CIOs have a small window of breathing room. That's because in order to qualify for the ARRA incentive dollars, will be enough according to Centers for Medicare and Medicaid Services (CMS, Baltimore). “Attestation is nothing different for hospitals, and getting reimbursed from the federal government is nothing new,” says Celwyn Evans, senior partner at Greencastle Associates Consulting, Malvern, Pa., citing Medicare care delivery as an example. “This is just like submitting a bill and saying, ‘We've done this.’”

The fact that hospitals can just declare they've attained meaningful use without actually having to submit data electronically until 2012 doesn't let CIOs off the hook, however. “No CIO or CMIO is going to say they have 10 percent CPOE without having data, and no one is going to sign off unless they have a high degree of accuracy and precision,” adds Evans.

After 2011, of course, healthcare providers will need to submit reporting data to CMS electronically. The problem is that few have even begun to think that far down the line because so many are waiting for the final rules to be set. That's not such a good plan. Though the guidelines will probably shift a little to the left or right, most agree that they will not change dramatically. And that's why smart CIOs are already thinking about reporting.

A key problem, according to Marc Holland, CEO of New City, N.Y.-based System Research Services, is that not all of the data elements required to compute and report the quality measures proposed under meaningful use are routinely captured by clinical systems. Today, for reporting Core Measures, parallel or post-discharge chart abstracting processes are used. Such processes are neither consistent nor compliant with meaningful use requirements - and therefore would not qualify the organization for HITECH incentive payments.

Celwyn Evans

Standardization of data, especially when a hospital is using technology from a host of sources, is a stumbling block to reports as well. EHR certification, say most, is the way to ensure not only functionality, but interoperability - and is also the reason why many organizations are waiting for EHR vendors to be certified in hopes that will solve the standardization part of the reporting dilemma

One who is waiting is Peter Dempsey, M.D., CMIO for both the Lahey Clinic, a 500-physician multi-specialty practice and Lahey Medical Center, a 317-bed bed hospital, both in Burlington, Vt. Dempsey is using Chicago-based Allscripts in the clinic and is the process of implementing Atlanta-based Eclipsys in the hospital - and certification is a big part of his ARRA strategy.

“The message from both vendors is, ‘We can help you.’” says Dempsey. He expects both vendors to be able to address his reporting requirements with their next releases in April, which they assure will be CCHIT-compliant. “They both have already promised hot fixes in the summer to deal with the final iterations of the rule,” he adds. “We're happy with that.”

There remains, however, a cloud on Dempsey's horizon, one shared by many others: coming up just short in the meaningful use requirements. “My biggest fear is that we'll hit 22 of 23 requirements and didn't generate one report that will disqualify us.”

Attaining all the CMS requirements, even with a certified system, will still require a lot of upfront work on the part of the CIO. ‘There is no silver bullet where you are going to hit the button and generate reports,’ says Evans. “If there are any analytical tools for reporting, you are still going to have to build interfaces to extract the data.” Furthermore, even advanced organizations that dump all their data into a data warehouse will face the same issue. He says that CIOs will still need to extract that information and get it into whatever is writing the report.

Takeaways

In order to qualify for meaningful use in 2011, hospitals will only need to use attestation.
Hospitals will have to submit data to CMS electronically in 2012.
Not all the data elements needed to prove meaningful use are routinely captured.
Standardization is a stumbling block to reporting.
For medium to large hospitals using a vendor to set up the reporting is an option.

Extracting That's exactly why I used it-it's a transition. (and validating) that information is part of the five-step meaningful use assessment recommended by Greencastle:

Determine if the technology exists, and determine if it is located in the appropriate site in the hospital.
If the functionality exists, is it turned on?
Is the task built into in the workflow to capture the data?
Can the data be extracted from the system?
Finally, validate the data's accuracy and the data integrity.

This doesn't happen automatically, Evans notes. “You can create templates on the front end to make sure that the data is being captured,” he says. “But remember this data often exists in disparate places, especially if the hospital is best of breed.”

Building workflows to capture data and building the interfaces to extract but it's a technical expression and there is no other word for that. Extracting data is extracting data., you can't say remove or anythingit are additional burdens for CIOs, who already have full plates. For medium to large hospitals, leveraging a consultant's expertise may be wise, considering that it is a one-time event. At Lahey, Dempsey says it is still early in the game for him to consider using outside help. “That's not part of the plan yet, especially since the first year is just attestation,” he says. “In the second year when we have to submit things electronically, it's going to be a little more difficult.”

Whether CIOs opt for consultancies or not, Evans says proving MU it will still be a great deal of work for organizations. The good news, he adds, is that the government will be the one paying for your trouble.