Guest post by Tom S. Lee, Ph.D., CEO & Founder, SA Ignite.
If the few years since the onset of meaningful use haven’t been proof enough, the speed and unpredictability of regulatory change in the last five months has cemented our field’s status as truly not-for-the-feint-of-heart.
Yesteryear’s glacial rate of change in healthcare IT regulation is nowhere to be seen. May 2014 brought both a CMS reset of the ICD-10 transition deadline to October 1, 2015, and a proposed meaningful use rule to enable the use of 2011 edition certified EHR technology (CEHRT) to meet compliance in 2014. The summer then ended with the August 29th finalization of the 2014 meaningful use final rule, the ensuing disappointment that the mandated start of Stage 2 was not delayed and then the swift Congressional response in the form of the September 15th proposed Flex-IT Act to introduce quarterly meaningful use reporting for 2015; enough to spin heads more than once around.
What’s happened in the field since the publication of the final rule among provider organizations bring the phrase “threading the needle” to mind. To further illustrate, we have culled some sample issues from our client base of more than 8,000 providers, across more than 15 EHR brands, and representing numerous combinations of meaningful use stage, payment year and program. These issues, none of which yet have universal and clean solutions, span three areas for provider organizations as seen in the field: 1) properly adhering to the requirements of the final rule, 2) working within the constraints of what EHR vendors can deliver per the final rule’s timeline, and 3) redirecting or pausing organizational momentum for change on short notice.
Regarding the first consideration, note that the final rule requires that an organization attest that it is “not able to fully implement” 2014 Edition technology because of “delays in 2014 Edition CEHRT availability.” Although the rule outlines what does not meet this eligibility test, provider organizations have a persistent question about what documentation and conditions are sufficient to satisfy the test.