Achieving meaningful use of electronic health records requires an enterprise-wide effort to transform the way in which the EHR system is used. This includes changes in responsibilities and accountability that may supersede departmental boundaries. To affect this level of change, the leadership team must work together and provide consistent direction to their staffs. However, whilst working together, executives often view meaningful use from a variety of perspectives, which influence their approach and priorities in moving the organization towards achieving meaningful use. The following are representative concerns of key leadership, with discussion of each perspective. Understanding the reasons behind the varying perspectives will assist organizations in developing and executing their plan to achieve meaningful use.
Chief Information Technology Officer: I am concerned that my colleagues assume that meaningful use is "just another IT project" when, in fact, it has significant operational implications and will require coordination and support beyond the initial reporting ('attestation') period to ensure that compliance is sustained.
Meaningful use achievement will require each organization to re-think how it operates on a day-to-day basis. Operational work flows and resource accountabilities must drive achievement of meaningful use to the extent that they utilize and enable technical information streams on an ongoing basis. The EHR is a key ingredient, but it is the actual use patterns of the EHR that are being measured under meaningful use. For those organizations currently implementing their EHR, the operational transformation process should parallel and be integrated with the EHR implementation. The meaningful use-driven transformation effort should be driven by an executive steering committee that includes key leadership from multiple disciplines.
Chief Financial Officer: We have budgeted meaningful use incentive revenue dollars; they are in the five-year financial plans. Some of the dollars are the funding sources for other projects, and we have also structured some of our provider compensation and other professional agreements assuming these dollars in the base. If these revenues are not realized, the organization's financial well-being may be compromised.
Meaningful use achievement is tied to incentive dollars for the short-term; with financial penalties in the future if meaningful use is not achieved. Moreover, partial receipt of incentive dollars in any one year is not an option — if even one of the many meaningful use measures are not met, the organization forfeits eligibility for that year's payment. Significant dollars are at stake. Meeting the requirements of meaningful use for a single year does not guarantee that the payments for all years will be received, as compliance must be demonstrated every year. Over time, the requirements of meaningful use will increase as new stages are introduced. There must be a sound plan in place to orchestrate achievement efforts, as well as a consideration as to the most appropriate allocation of the incentive payments. The costs of operational and workflow changes necessary to achieve meaningful use may entail additional unplanned expenditures.
Chief Nursing Officer: A significant number of meaningful use measures are going to fall upon nursing to complete; we are not fully prepared to implement such broad-sweeping change. How do we assure that other players (such as the medical staff, finance, admitting and health information management) will also be required to do their part?
Meaningful use is not merely an initiative that complete once it is achieved. Rather, meaningful use will need to become an ongoing part of the operational practice of the organization. Organizations will need to continually refine necessary operational changes over time, adapting them as the requirements of meaningful use evolve. No single department, cohort of resources, or role within a healthcare organization will be able to "own" meaningful use. Success will turn, in part, on establishing clear monitoring and accountability within the context of a matrix governance structure. The governance model must include representatives from all major constituencies — nursing, physicians and other clinical departments; as well as information technology and administration. Many of the clinically-related Stage 1 meaningful use measures do not specify who must input or review the data. Subsequent stages may become more prescriptive as to the relevant role (physician versus nurse, or even versus clerk) — with the shift toward requiring the originator of the order to perform the input, so as to make related clinical alerts timely and relevant. These potential requirements should be considered in the current allocation of responsibility for performing meaningful use-compliant behaviors.
Chief Medical Officer: My physician colleagues do not understand the organizational approach or plan regarding achievement of meaningful use.
Many of the meaningful use measures that must be achieved to qualify for the EHR incentive payments are tied to the documentation of clinical information (e.g., recording medications and allergies) and approaches for treatment (e.g., electronic order entry, clinical decision support rules) that fall primarily within the physician's workflow. As such, physician involvement in the workflow redesign process is essential to success in meeting meaningful use and supporting physician efficiency. Clear communication efforts targeting the entire physician community that raise awareness of key issues, educate physicians regarding changes and encourage active physician participation are necessary for successful meaningful use achievement. But involving key physician leaders in the redesign process and the overall meaningful use governance structure, while critical, is not sufficient. For many physicians, the workflow changes driven by meaningful use may be seen as placing further demands on limited physician time. Medical staff leadership must be proactive in addressing physician concerns.
Chief Executive Officer: The community and my board are expecting that we achieve meaningful use — the dollars are in our approved financial plans and the stated results align with our high-level service and delivery goals. However, the executive team is receiving pushback from staff. Plus, my board does not fully understand the complexities of achieving meaningful use and obtaining the funds.
Achieving meaningful use will require clear leadership from the CEO on down. While not a direct participant in the meaningful use governance structure, the CEO will need to assure that status updates in meaningful use achievement are regularly monitored by the senior team and shared, as appropriate, with the board. Additional education for the board on Meaningful Use may be necessary to ensure the board is able to properly discharge its fiduciary duty. Given the complexities of achieving meaningful use, the CEO should be a direct participant in balancing the risks of delayed Meaningful Use achievement, and concomitant loss of some EHR incentive funds, against the ability of the organization to execute on other key business objectives and compliance with other regulatory requirements (such as ICD-10). The concerns of the medical staff and other key constituents will need to be addressed in a consistent manner and may require CEO endorsement of unpopular decisions necessary to support successful and timely meaningful use achievement.
Gerard Nussbaum is the director of technology services in Kurt Salmon's Health Care Group; he may be contacted at 212.508.8396 or at gerard.nussbaum@kurtsalmon.com. Jodi Capistrant is a manager in Kurt Salmon's Health Care Group; she may be contacted at 212.508.8372 or at jodi.capistrant@kurtsalmon.com.
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Chief Information Technology Officer: I am concerned that my colleagues assume that meaningful use is "just another IT project" when, in fact, it has significant operational implications and will require coordination and support beyond the initial reporting ('attestation') period to ensure that compliance is sustained.
Meaningful use achievement will require each organization to re-think how it operates on a day-to-day basis. Operational work flows and resource accountabilities must drive achievement of meaningful use to the extent that they utilize and enable technical information streams on an ongoing basis. The EHR is a key ingredient, but it is the actual use patterns of the EHR that are being measured under meaningful use. For those organizations currently implementing their EHR, the operational transformation process should parallel and be integrated with the EHR implementation. The meaningful use-driven transformation effort should be driven by an executive steering committee that includes key leadership from multiple disciplines.
Chief Financial Officer: We have budgeted meaningful use incentive revenue dollars; they are in the five-year financial plans. Some of the dollars are the funding sources for other projects, and we have also structured some of our provider compensation and other professional agreements assuming these dollars in the base. If these revenues are not realized, the organization's financial well-being may be compromised.
Meaningful use achievement is tied to incentive dollars for the short-term; with financial penalties in the future if meaningful use is not achieved. Moreover, partial receipt of incentive dollars in any one year is not an option — if even one of the many meaningful use measures are not met, the organization forfeits eligibility for that year's payment. Significant dollars are at stake. Meeting the requirements of meaningful use for a single year does not guarantee that the payments for all years will be received, as compliance must be demonstrated every year. Over time, the requirements of meaningful use will increase as new stages are introduced. There must be a sound plan in place to orchestrate achievement efforts, as well as a consideration as to the most appropriate allocation of the incentive payments. The costs of operational and workflow changes necessary to achieve meaningful use may entail additional unplanned expenditures.
Chief Nursing Officer: A significant number of meaningful use measures are going to fall upon nursing to complete; we are not fully prepared to implement such broad-sweeping change. How do we assure that other players (such as the medical staff, finance, admitting and health information management) will also be required to do their part?
Meaningful use is not merely an initiative that complete once it is achieved. Rather, meaningful use will need to become an ongoing part of the operational practice of the organization. Organizations will need to continually refine necessary operational changes over time, adapting them as the requirements of meaningful use evolve. No single department, cohort of resources, or role within a healthcare organization will be able to "own" meaningful use. Success will turn, in part, on establishing clear monitoring and accountability within the context of a matrix governance structure. The governance model must include representatives from all major constituencies — nursing, physicians and other clinical departments; as well as information technology and administration. Many of the clinically-related Stage 1 meaningful use measures do not specify who must input or review the data. Subsequent stages may become more prescriptive as to the relevant role (physician versus nurse, or even versus clerk) — with the shift toward requiring the originator of the order to perform the input, so as to make related clinical alerts timely and relevant. These potential requirements should be considered in the current allocation of responsibility for performing meaningful use-compliant behaviors.
Chief Medical Officer: My physician colleagues do not understand the organizational approach or plan regarding achievement of meaningful use.
Many of the meaningful use measures that must be achieved to qualify for the EHR incentive payments are tied to the documentation of clinical information (e.g., recording medications and allergies) and approaches for treatment (e.g., electronic order entry, clinical decision support rules) that fall primarily within the physician's workflow. As such, physician involvement in the workflow redesign process is essential to success in meeting meaningful use and supporting physician efficiency. Clear communication efforts targeting the entire physician community that raise awareness of key issues, educate physicians regarding changes and encourage active physician participation are necessary for successful meaningful use achievement. But involving key physician leaders in the redesign process and the overall meaningful use governance structure, while critical, is not sufficient. For many physicians, the workflow changes driven by meaningful use may be seen as placing further demands on limited physician time. Medical staff leadership must be proactive in addressing physician concerns.
Chief Executive Officer: The community and my board are expecting that we achieve meaningful use — the dollars are in our approved financial plans and the stated results align with our high-level service and delivery goals. However, the executive team is receiving pushback from staff. Plus, my board does not fully understand the complexities of achieving meaningful use and obtaining the funds.
Achieving meaningful use will require clear leadership from the CEO on down. While not a direct participant in the meaningful use governance structure, the CEO will need to assure that status updates in meaningful use achievement are regularly monitored by the senior team and shared, as appropriate, with the board. Additional education for the board on Meaningful Use may be necessary to ensure the board is able to properly discharge its fiduciary duty. Given the complexities of achieving meaningful use, the CEO should be a direct participant in balancing the risks of delayed Meaningful Use achievement, and concomitant loss of some EHR incentive funds, against the ability of the organization to execute on other key business objectives and compliance with other regulatory requirements (such as ICD-10). The concerns of the medical staff and other key constituents will need to be addressed in a consistent manner and may require CEO endorsement of unpopular decisions necessary to support successful and timely meaningful use achievement.
Gerard Nussbaum is the director of technology services in Kurt Salmon's Health Care Group; he may be contacted at 212.508.8396 or at gerard.nussbaum@kurtsalmon.com. Jodi Capistrant is a manager in Kurt Salmon's Health Care Group; she may be contacted at 212.508.8372 or at jodi.capistrant@kurtsalmon.com.
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