We have an economic stimulus package now and we’re all trying to figure out what’s in there and what it means. You can debate the pros and cons of the new legislation as it relates to job creation, but it’s certainly a lot of money and it’s certainly going to have a dramatic impact on healthcare IT (HIT) for the next several years.
Steve Leiber, President and CEO of HIMSS presented what we know thus far about HIT funding in the American Recovery and Reinvestment Act (ARRA) at the Iowa HIMSS Annual Advocacy Day on Monday.
The largest component of the roughly $20 billion that relates to HIT relates to incentive programs for organizations adopting EHR solutions. Incentives start in 2011 and go through 2015. After 2015, they begin cutting base reimbursement rates. Each year, the incentive payments will decline, so physicians and hospitals who fail to qualify in 2011 will miss out on the largest reimbursement year.
So, what’s required to qualify? “Meaningful use” of a “certified” EHR.
Meaningful use – this is good. It will be a few years before the money starts flowing and HIT spending would screech to a halt in the interim if this were a money first, implement second approach. Most of the money will only be available for entities that have bought, installed and are using these technologies and to those early movers that have been ahead of the game. Again, this is a good precedent as it helps to remove the inclination that organizations should wait until someone is willing to supplement the costs or risk loosing out.
Certified – The National Coordinator on Healthcare IT will need to identify standards (or, more likely, standards bodies). Very likely that this will fall to standards bodies like HITSP and certification programs like CCHIT as there simply isn’t time to build something like this from scratch.
This is where I get concerned (with full credit here to Jeff Cash, CIO at Mercy Hospital in Cedar Rapids who raised the issue). CCHIT certifies systems based on single-vendor solutions and requires those solutions to cover an entire range of functionalities. Vendors covering 80% of those solutions aren’t certified even if providers who implement those solutions cover the remaining 20% with other packages. Many vendors will be unable to achieve certified systems and then have any significant portion of their clients do complete upgrades within the available two-year window before payments begin. Providers, on the other hand, may audit their systems, identify gaps, and implement smaller applications to fill required functional gaps in that time.
Let’s say, for example, that your EMR can’t generate a CCD document today (a CCHIT requirement for Ambulatory EHRs). That’s a relatively easy function to add through a third-party application, but it could keep your system from certification!
The Payment Card Industry (PCI) standards provide a better model to follow. Applications can be certified, but compliance is judged based on implementation. The implementation environment is taken into account and solutions that have not received certification can be compliant based upon the actual implementations. Going through the process still isn’t fun, but it does represent a scalable compliance model that offers a real opportunity for providers to qualify for these incentives.