• Executives

Meaningful Use 6: What’s This Gonna Cost Us?

For most providers, the certification for meaningful use will cost whatever the software vendor decides to charge. This will be a major effort for most vendors; most will feel it’s only reasonable to spread the cost of certification among the customer base who will benefit from the effort. The ONC stated that the Medicare/Medicaid incentives were intended to pay for the software improvements.

It’s been years since CCHIT certification was created for the benefit of providers and patients, and most software vendors serving our Health & Human Services niche market still haven’t become certified. That’s because behavioral health standards development has lagged behind physical healthcare efforts. A couple of larger companies in our sector got tired of waiting (and could afford the effort), so they became certified for ambulatory environments, but most companies were reluctant to lay out over $25,000 in hard-earned cash for certification that wasn’t even required for our sector yet. And that didn’t include the additional programming effort that few companies have staff to perform, which could push the CCHIT certification into many more hundreds of thousands of dollars.

Now, with the advent of the Medicare/Medicaid incentives becoming a reality, software vendors are playing a waiting game and saving their pennies. The certification effort will be substantial, reducing support resources for most manufacturers. It’s going to be interesting to see who bothers with this and who doesn’t, simply because they can’t see the payoff.

Here is the short story of particulars about what certification for eligible professionals will cost a software vendor (outpatient environments): •With previous certification o One time cost: $50,000 – $150,000 •Without previous certification o One time cost: $1,200,000 – $3,600,000

Based on the costs for vendors who have not previously become certified, the estimated average upgrade cost is $2,400,000 per software vendor (except for the two who are already certified in some capacity).

Next time, I’ll wrap up this discussion topic with tips on how to get the ballpark estimate you need to budget and consequently determine whether you want to continue considering taking advantage of Medicare / Medicaid incentives.

• Executives

Meaningful Use 5: What has to be done?

After all the definitions, foundations, policies and standards embraced by the ONC are discussed, explained and re-discussed, the meat of the matter comes down to two concerns: – What do I have to do to receive Medicare / Medicaid incentives? – What’s it cost?

Here’s the big picture of what needs to be done, and in Meaningful Use 6 I’ll explain the elements of cost, and share some ideas of what it could cost your agency.

Elements of criteria for certification of the EHR are clearly explained in the tables of the Federal Registry document I’ve been analyzing in this series. My MU_Criteria document contains the tables with details your agency should be concerned with. A bundle of the requirements that must be met to collect the incentives are met by your vendor or even your home grown system just by being HIPAA compliant and compliant with the HITECH act requirements.

Table 2 A in the linked document concerns standardizing electronic data interchange and language used across different health care environments, and yes, there’s a plan to help us all speak the same language.

Table 2 B is all about data security and maintaining confidentiality. That’s as it should be. Electronic encryption and decryption has been around a long time. Not all software vendors are conversant in this technology, so be sure to ask your vendor what it will take to get you there (usually a major modification or product upgrade will be required)…it’s not likely you’ll want to tackle this yourself.

Here are some elements you will want to review with your IT department and software vendor very soon. These requirements are coming, and somehow need to be met. If your vendor won’t certify this sort of functionality, your agency will need to take responsibility for the one-time and ongoing costs in order to collect the incentives. Let me know if you need help determining the value of doing this yourself. – CPOE: Order entry and tracking is not just for medications: Lab results, radiology/imaging, provider referrals are required. Not all electronic prescribing tools do this. – Medication Library: Pop-ups abound! Make sure the specific rule-based “pop-up” alerts are to be included in your software for interactions, etc. Some software vendors will insist you do this yourself, using tools that come with your system…and that may require an upgrade the vendor may charge for if you’re not running on their latest and greatest version – This type of programming amounts to telling the programmers how to program, so there may be some resistance, but the ONC document is firm and clear, so be firm in your dealings with your vendor – Electronic Transmission of medication orders, presumably to the pharmacy; this may require a subscription and business arrangement with a company like Sure Scripts – Electronic submission of reports to CMS or your state Medicaid agency…most vendors will not want to take this cost on for themselves – Decision Support: Make sure your agency’s top 5 rules in this regard are included in the software…there may be different procedures in following of the decision tree for your various programs, so be sure to have plans for all programs – Patient Portal: Ooooooh! A number of hospital systems and insurance companies already have this technology. It’s pretty new to our sector; The technology may or may not be included by your vendor already; if not, there may be a way to connect to Google Health or Microsoft Health Vault…Creativity may win the day on this issue

That’s not the whole story, but I hope it gives you enough to think about for the time being. Next installment: How much does this certification cost, and who pays for it?

• Executives

Meaningful Use 4: The EHR Is In Constant Change

I worked for Jim Gargiulo, Executive VP at Netsmart Techonologies for a number of years, and he would become frustrated when we discussed the EHR in static terms. “It’s a journey!,” He’d exclaim. The Office of the National Coordinator is taking this evolving view for the EHR.

The ONC promises that the requirements of certification will need to be updated as times, treatment methods and tools evolve, and change seems to be the only real constant in this universe.

The ONC says that some policies and standards will come into play, then later be phased out or replaced. In order to accommodate this way of doing business, the software industry has included tools to modify your EHR to suit a changing environment. The tools are sometimes inadequate. Some companies don’t want to give up control of your EHR. Usually tools would work fine to whip up a screen and include a report to reflect new policies & standards, as long as you have somebody on staff who has the wherewithal to use them. When they’re inadequate, you pay money for a programmer to help, and her baby needs shoes, Billy needs braces, and Sally’s going to college next year.

Wake up, my friends. Provider agencies need somebody working for them who can do a few things: • Design forms and reports (and if tools enable it, Electronic Data Interchange files) • Include workflow processes at all levels of the agency in updates • Implement using a rapid cycle change methodology or something like it • Incrementally update and implement the design when changes come • Roll out changes EFFECTIVELY to staff requiring them, and be savvy in convincing the staff to look forward to changes

If you need help with this, click on “About Terry McLeod” above…my contact information is at the bottom of that page.

Installment 5 of this series will discuss more about certification options and your decision to maintain an enterprise system or opt for a modular approach.

• Executives

Meaningful Use 3: Stages & Time Lines

There are three stages in proving Meaningful Use of your EHR to the Office of the National Coordinator and CMS in order to receive Medicare and Medicaid incentives amounting to around $100,000 per provider over a five year period. Stage 1: In my MU 1 post, I shared this needs to be addressed in 2011. That means getting ready this year, and the year’s 25% gone, and depending on where you are in your evolution to the EHR and how your vendor responds, it could be a big job.

Next year your EHR will need to be not only collecting the demographics and services rendered that are usually in place for billing purposes, but also tracking and electronically communicating patient clinical matters (like assessments, treatment plans, notes and medications). Moreover, you will need to be using your EHR for clinical decision support.

Stage 2: In 2013 the EHR will need to expand into areas like order entry for medication and other practitioners orders. This is a big concern; a number of software vendors in our sector are just getting around to developing these modules, and they can be clunky for the users in their first iterations. The system will need to provide electronic transmissions of data like using approved formats for labs, pharmacy and other ancillary services used in patient care.

Stage 3: On a national scale, elements of healthcare come into the spotlight on a regular basis. Beginning in 2015, these concerns will need to be tracked. The EHR will also need to expand to include quality improvement (and proof thereof), and provide patient access like the portals you see in Microsoft Health Vault and Google Health. Software vendors have been developing these tools for patient use for a while, and that development has already expanded into our sector.

It’s only rocket science, and we’ve done that.

Contact me if you need help.

• Executives

Meaningful Use 2: Raising Questions of Cost

The last rumor I heard was that it will cost $1 million $2 million to certify an EHR, and Certification of the EHR is a major part of what meaningful use is all about at the nuts and bolts level.

Small providers can have a problem justifying the expense of assuring their EHR is certified, especially if the increased payment for services (mentioned in volume 1 of this series) is not sufficient to show true value. Without value, the certified EHR falls by the wayside.

One objective in my work is to help folks arrive at the best EHR option for their agency, whether purchasing a new one or optimizing their current product. So, you’ll see a recurring theme in this series of seeking EHR options with that in mind. Foremost in my mind right now is discovering affordable certification alternatives.

The certification of the EHR in order to receive Meaningful Use incentives is built on previous action, like HIPAA for security and code sets, electronic prescribing standards set forth in NCCD Script 8.1, and the HITECH certification provided by the Office of the National Coordinator (ONC). In and of themselves, these elements are not enough to prove Meaningful Use.

Initially, the HIT Policy Committee was charged with eight areas of responsibility in building the standards, implementation specifications and certification requirements. Elements that jumped out at me included

• Protection of privacy • Nationwide IT infrastructure • EHR for all patients by 2014 • Tracking health info disclosures • Coordination of health care • Transmission encryption for health data • Specific race / ethnicity / gender demographics • Special needs technology

These elements are further defined in a couple sources I’ll cover in future installments. The concepts are not new, it’s just crunch time to use this technologe on a widespread basis.

The time element is critical. It’s March, and Stage 1 needs to be in place by 2011. If your agency hasn’t implemented your EHR sufficiently to capture clinical data (assessments, treatment plans and progress notes), perhaps it’s time to try something new. Contact me if you need help.

• Executives

Meaningful Use 1: “Cliff Notes”

The reorganization of funding for our broken health care system has taken some interesting turns. ”Interesting” meaning “costly”. Incentives offered for meaningful use of the electronic medical record could make the difference between survival and failure for a number of Health & Human Service provider agencies. More interesting news: the Meaningful Use incentives plummet in value after 2011, as the efficiencies, quality enhancement and patient safety measures start to pay off.

It’s tough to get ahead these days.

The Meaningful Use world is rife with acronyms: CMS, ONC, HIT, HITECH, PHSA and EHR to bring up a few. The EP is the Eligible Professional, and as I currently understand, the EPs who write prescriptions can be a godsend by making licensed Community Mental Health Centers eligible to participate in receiving Medicaid and Medicare funding that could amount to millions of dollars a year, depending on the size of the organization (CMHC inclusion is being drafted as you read this, and isn’t included at this time). Each EP could mean $100,000 or so in incentives through the five year program. There are rules and stipulations creating stumbling blocks, but this is the short story.

Meaningful Use incentive details are still being settled, moving at the speed of government and likely won’t give providers any breathing room to organize the agency and take advantage of the incentives once the dust settles on the rulemaking level. The aspect of Meaningful Use incentives that is certain is that provider agencies should be moving fast. • Get ready to institute the Meaningful Use criteria in 2011 and be collecting data for the whole year: 2010 could be a busy year • Get ready in 2012 to use the data you’ve collected to improve quality because in 2013 you’ll need to prove you’re making a difference in the care provided, and need to share electronic patient health data with others providing shared care responsibility for patients • In 2015, Stage three begins. Get ready to prove the improvements all this has meant.

As I uncover more details about how Meaningful Use incentives work, I’ll let you know. One thing’s for sure, it’s a lot of work, and you may need help. That’s why I’m here.

• Executives

Where’s the Bill?

In the recent post “Wellness and Capitol Hill”, I agreed that the health reform bill was actually a health insurance reform bill. The Legal Action Center’s blog, Policies and Politics commented on the bill in the post “Details on Expanded Health Coverage as Obama Signs Bill”. In the interest of updating my opinion, I discovered two elements of the bill not about insurance coverage that deserved my immediate attention: • SUD/MH workforce in health workforce development initiatives. The final bill includes the capacity of the MH and “behavioral health” workforce as high-priority topics in the bill’s National Workforce Strategy section. • SUD prevention, treatment, and MH service providers to be eligible for community health team grants aimed at supporting medical homes. The final bill lists SUD and MH service providers among entities eligible for community health team grants.

So, curious guy that I am, I searched the web for the bill. It’s hard to find. So hard, I couldn’t find it this morning. This brings out the persistent guy in me, so I’m asking experts, searching government web sites, and asking readers to send me a link to the bill.

Where is it?