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?
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