An overwhelming majority of CIOs are both pleased with how public comments impacted the final Meaningful Use regulation and optimistic about their ability to meet it, according to the July healthsystemCIO.com SnapSurvey; however a majority of those same CIOs thought it far less likely that the “average” hospital will make the grade.
And the apparent bullishness — at least at their own institutions — further dissipates when analyzing the comments CIOs left after confirming they would meet the measure. That copy (see text below) is peppered with phrases like “we should qualify … we hope to meet the measures … we are fairly certain of reaching the goals.”
In an attempt to identify the reasons for any concern, CIOs volunteered the specific core measure that most distressed them, with “Report clinical quality measures to CMS or states. For 2011, provide aggregate numerator and denominator through attestation; for 2012, electronically submit measures,” taking the top spot at 24 percent.
Finally, CIOs were asked how not knowing what will be required in Stages 2 or 3 of the program impacted their work. Almost 60 percent admitted it made their job “a little difficult,” with just over 26 percent feeling it “is a ridiculous way to run this program.”
(SnapSurveys are answered by the healthsystemCIO.com Advisory Panel. To see a full-size version of all charts, click here. To go directly to a full-size version of any individual chart, click on that chart)
1.Grade the final Meaningful Use regulation in terms of the average hospital’s ability to achieve it:
A/B
- More will make it than not.
- The average hospital will have a greater chance of meeting the new requirements, as the basic mandatory items have decreased and the number of utilization measurements have been relaxed.
- Overall, the requirements are less demanding and more flexible.
C
- Many are still far behind the curve. When challenged as to a commitment on adoption by this time next year, even David Blumenthal hesitated on giving a percentage.
- It is getting closer, but having the requirements “watered down” may not help that much. The big issue will be the ability of hospitals that haven’t implemented the functionality or tools to be able to implement them in time to “use them meaningfully.” If the functionality isn’t there to use, having “watered down” requirements won’t help.
- 15 clinical quality measures will be hard to codify in an EHR.
- I believe that the Stage 1 criteria is appropriate, but not a slam dunk for the average hospital. It should make facilities strive to be more wired in a planned sense.
- Since the “average hospital” has potentially not even started implementing the required systems and process changes, I rate this a “C.” If you have already started down the path, then it’s probably a “B” or higher.
- Although much more flexible, it will still take some significant dollars and effort to attain stage 1 criteria. In light of the other strategic initiatives, most organizations will not have the money and attention for the effort.
- I’m very glad that they took the opportunity to listen and modify the final rules. It does lower the bar somewhat, but it is not something that facilities can just step over.
- It’s still not a slam dunk for stage 1, since deadlines have not been touched.
- I like that there is more flexibility with the menu items.
D/F
- I will be in a rural hospital and it will be next to impossible to meet the final rule in the timeframe provided. Meditech will not even have 6.0 certified for some months to come and their implementation schedule is way overbooked as is.
- While the “All or Nothing” clause has been dropped, the Feds just could not help themselves and added more.
- I don’t have a lot of confidence that either the IT organizations or the clinical users can manage the level of change that will be required to meet the full intent of the MU regs.
- Only a minority of hospitals will achieve Stage 1 in 2011-2012. It appears that CMS/ONC is now resigned to this eventuality.
- Anything is achievable, but the current MU rule places too much emphasis on measurement instead of principles first. As they say, some things that can be measured, shouldn’t be measured and some things that should be measured, can’t be. The MU rules are going to require as much, if not more, effort to measure as is required to implement the functionality.
2. Did the comment period function as it was intended (please write in the most significant change you saw in the final regulations)?
Sweet Flexibility!
- Yes. No longer the “all or nothing approach.”
- Change from all or nothing.
- Concept of core and menu.
- They did ease up on the type and number of requirements, with the most significant change being the ability to pick and choose from a number of “optional” requirements.
- Not making it necessary to meet all requirements as originally proposed, but meeting the core and then filling in the others as time goes on is a great compromise.
- The menu set was a reasonable attempt to satisfy concerns that the “all-or-none” approach of the NPRM was too inflexible.
- Flexibility from an “all or nothing” approach was a significant and welcomed change.
- Relaxation on the “all or none” component.
- Moving some of the requirements to a “menu” and allowing facilities to pick from the list.
- Menu option on 5 items.
- Core versus menu set makes MU more achievable.
- Whether you agree or disagree, it did show that ONC and CMS listened to the majority. The most significant change was limiting mandatory criteria to 15 categories.
- Choice of measures.
- It could have been much worse, to be certain. If the Feds changed nothing, then it would have been a disaster, per se. All or nothing, as noted, was the biggest positive move.
CPOE Changes
- It is absolutely clear that the ONC heard our concerns. Specifically the reduction in CPOE criteria, as well as the menu of options, were very much appropriate.
- Most significant change was changing CPOE requirement from all orders to medications.
- CPOE changes.
- Method to calculate CPOE makes more sense.
3. Will you qualify for all available Stage 1 monies at some point during the eligibility window?
Yes
- We will qualify for all possible funding designated for our hospital and the eligible providers that we employ.
- Yes, but not until 2013.
- We planned to qualify in 2011 with previous criteria. New criteria makes it easier for 1st year.
- Yes. We’re targeting 2012.
Maybe
- I should qualify. We are on track to qualify for all available Stage 1 monies and hope to qualify for all of the remaining stages too.
- We’re fairly certain we have all the functionality in place. We’re well beyond the CPOE requirements and are now working on tweaking the Problem List documentation.
- Perhaps if we choose to chase it we could make it. On the other hand there are many other options we can use our resources for that might be more critical and important to our Board and CEO.
- We should qualify in FY 20111.
- We hope to qualify for Stage 1 in the first reporting period (2011). Wish us luck!
- We feel fairly confident, as long as the vendor certification process does not take too long!
- My former organization should meet the criteria easily, as they are doing all that work already. The only missing portion is the certification of the vendor product and the effort the new release will take.
- Knock on wood, throw salt over my left shoulder, kiss the Blarney stone, rub a troll’s belly, staying away from black cats in my path. Then we should hit it.
- We think we will, but it’s still iffy.
- We have work to do, but expect to complete it.
4. Which of the following core set measures will be the most difficult to achieve? Please explain why.
Report clinical quality measures to CMS or states For 2011, provide aggregate numerator and denominator through attestation; for 2012, electronically submit measures
- Technically, the reporting of quality metrics from a certified EHR will not be difficult to accomplish. Organizations, however, will struggle with their comfort level in reporting the metrics to CMS, as is, from the electronic specifications. In other words, do they really believe this a structural measure or are these actually performance measures?
- Reporting clinical quality measures will be most difficult for organizations that do not capture discrete data for documentation. Privacy and Security will also be difficult since most organizations have been focused on EHR while the security and privacy regs have been strengthened.
On request, provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies, and for hospitals, discharge summary and procedures) — More than 50% of requesting p
- Will have to implement a patient portal.
- We need to implement a COMPLETE electronic medical record.
- I believe that transmission of data to patients is the biggest challenge.
Computer provider order entry (CPOE) for medication orders — More than 30% of patients with at least one medication in their medication list have at least one medication ordered through CPOE
- CPOE will be the most difficult because of the dependency on community physicians to cooperate.
- CPOE will be the most costly, but it was on the list anyway. There are some items that we don’t currently chart (i.e., cause of death, etc.) so we will need to view the related processes.
Implement capability to electronically exchange key clinical information among providers and patient-authorized entities — Perform at least one test of EHR’s capacity to electronically exchange information
- Requires collaboration on the parts of many, and too many organizations are trying to fill this gap with their own self-centered interests in mind — including the insurance companies who know they will miss out in 2014 when employers start to dump their employees into the state exchanges.
- Although CPOE is a significant challenge in that it requires changes in clinical workflow, I do think that exchanging data with outside entities will in the longer run be the greatest challenge. Current commercial clinical systems’ architectures focus on workflow within an organization, not across organizations. It is not clear that this is a surmountable challenge in the short run.
5. Not knowing what will be in Stages 2 or 3:
Is Not Good
- Budgeting and planning by crystal ball is not optimal.
- The timing of Stage 3 requirements will be the most difficult.
- This is not good, especially when the timing between stages creates a squeeze play to keep incentive monies.
- I’m concerned that we will need to do this same exercise two more times, and I really don’t know if I have the time to do it. Not really knowing what the real future state “should” look like creates an opportunity for us to not make the best long-term decisions; which could add cost to the process.
Is No Big Deal
- Given the uncertainties that were apparent prior to Stage 1, having them continue to future stages should not be a surprise to anyone. This is clearly uncharted territory. I would be more concerned if Stage 2 and 3 specifics were released BEFORE we learned anything from a Stage 1 experience.
- I think we all have an idea that the next stages will just expand on the requirements of Stage 1.
- We have a comprehensive Information Management Plan, however it would be beneficial to have all of the requirements for Stages 2 and 3 specifically addressed in the plan to assure success.
- While problematic for vendors and providers, it’s understandable that CMS needs to wait until the MU program is underway before defining the later stages. Unfortunately, given the limited number that will achieve Stage 1 in 2011 (when CMS is developing the Stage 2 criteria), they will have incomplete data to work from.
- We now can at least anticipate what Stage 2 will require as a minimum. CIOs deal with uncertainty every day.
- I actually like the idea of an undefined future. It keeps people creative.
- I cannot worry about a future that is not clear. We will take it as it comes… but the upside is that we are in healthcare IT and we have jobs for the foreseeable future. I keep telling my staff that you could not be at a better industry cross road. We think in terms of 5 and 10 year horizons for our long term view, including my career path. With any luck, I should be able to have a very meaningful career until I hang it up (as will every other CIO out there who gets it).
- It’s okay — they will be better defined once the DHHS determines how feasible it is for EPs and hospitals to meet stage 1.
Bonnie Siegel says
Anthony – Enjoyed reading the Snap Survey on MU, great content on this timely and important topic impacting CIOs and health systems, interesting comments!