Every summer I plan to grow a larger, more prolific garden than the previous year. I have the previous year under my belt, after all, so surely that learning should count for something? Sometimes I'm relatively successful, but most of the time, we get too little sun or too much rain. Even when I am successful, the rabbits or the deer manage to benefit the most.
Managing a meaningful use program must feel an awful lot like this. In 2011 and 2012, we watched organizations push along their implementations as quickly as possible to maximize incentive payments for their providers. The pace, the shortcuts and the emphasis on "just get it done" were all temporary. Everyone had the best intentions to retrench the following year and "do it right" by learning from their first-year experience.
Changing environment
But, similar to the gardener who switched from growing tomatoes to peppers the following year, there was just enough change to handicap efforts in following through on these plans. In our work with thousands of providers and nearly a hundred organizations in 19 states, we've seen the same issues crop up (no pun intended) year-over-year.
- Employee turnover. MU is a complicated program that requires coordination across many different departments throughout an organization. People who successfully navigate this complexity find themselves valuable outside the organization or in other departments. Organizations that have put too much of the MU scope under a single individual are particularly at risk when employee turnover occurs.
- Lack of senior MU decision-making body. Decisions about which exclusions the organization will allow providers to take, when the supporting audit documentation is considered final and how to interpret a specific measure are sometimes pieced together through contact with various parts of the organization. The lack of a single decision-making body complete with policies, procedures and documentation makes organizations vulnerable at the time of an audit.
- Audit documentation after-the-fact. A client recently was adamant that she wasn't going to give any of her providers credit in their compliance score for meeting the security risk assessment measure until she had the final documentation of its completion in her hands. Smart client. Best laid plans to be thorough about audit documentation tend to follow attestation, versus occurring before it's been completed.
Even for those organizations that tackled these challenges early on, the monsoon hit when CMS announced the notice of proposed rulemaking to grant flexibility to eligible hospitals and eligible providers struggling to implement their 2014 Edition CEHRT for the full 2014 EHR reporting period.
This change — albeit a relief to many — means that, once again, your plans to "do things the right way" are again thwarted by an outside force. And, with three years of the program under our belt, we now know that changes are the norm. We cannot garden with the expectation of 85 and sunny every day.
So what now?
Every single organization is in the same difficult position right now: How do I respond to the fine print in the NPRM and what do I do about stage 2? And, for those that keep putting off their good intentions to "fix the program next year," they are doubly challenged. Here's what I recommend.
Turn the soil
With changing messages from the government and tricky interpretation for certain measures, it is easy to roll our eyes at "yet another government program" and to treat it as such within the organization. MU remains a key part of the broader pay-for-performance initiative and needs to be messaged as critical to the fabric of the organization — not just as an IT project that needs to be done to satisfy the government. Make this message clear from the top down, and change the way people have been thinking about MU.
Install a trellis
The team(s) of people who work through MU details on a daily basis need to know when they can make a unilateral decision and when they need to seek additional support to confirm. Simply defining the types of decisions that need to be brought to an MU committee, CMIO or medical director will shed light on existing gaps and provide a framework for inevitable questions moving forward.
Grow more
It is certainly expected that most providers will use the stage 1 thresholds to attest in 2014. Consider, though, how far you can stretch your providers to meet stage 2 thresholds anyway. Imagine MU under your belt in early 2015 so you can focus on raising your clinical quality measure scores for the Physician Quality Reporting System and the Physician Feedback/Value-Based Payment Modifier program.
Commit to watering
Make the investment in time to revise broken processes, educate more staff and be more disciplined in your procedures and documentation pays dividends, both in tangible and intangible ways. The MU program continues to serve as the basis for other pay-for-performance programs; an investment in this area pays out real dollars while avoiding penalties for the foreseeable future. Less concrete, but equally valuable, the culture of continuous improvement and cross-organization collaboration is a requirement for countless P4P models.
Beth Houck is the vice president of client services at SA Ignite, a provider of software solutions that automate, accelerate and simplify the meaningful use attestation process for eligible providers. She previously led the strategy and business development for Northwestern Memorial Healthcare and the Rehabilitation Institute of Chicago. She earned a B.S. in Industrial Engineering from Northwestern University and an MBA from the Fuqua School of Business at Duke University. Contact her at beth.houck@saignite.com.