It has now been a month since the CMS and the Office of the National Coordinator for Health Information Technology published the interim final rule for EHR certification standards and the proposed rule on the EHR Meaningful Use Incentive Program and meaningful use standards. Another rule proposing the EHR certification process and organizations designated to conduct EHR certification is also expected early this year.
But with incentive payments set to begin in October for hospitals and in January 2011 for physicians, waiting for the release of final rules before worrying about meaningful use standards may not be wise—especially for those hoping to take advantage of the early incentives.
"Despite the fact that there may be some changes, it is time to move forward with enhancements to your information systems that make sense for your organization," says Margret Amatayakul, RHIA, CHPS, CPHIT, CPEHR, FHIMSS, president of Margret\A Consulting in Schaumburg, IL.
So what can you do now to prepare? Much of this depends on how fully you have implemented your EHR and the functionality of the EHR you implemented.
Either way, now is the time to begin, even if some of the legislation is still only proposed. Certainly, CMS may tweak some of the measures for meeting meaningful use, says Chris Apgar, CISSP, president of Apgar & Associates, LLC, in Portland, OR. But he doesn't expect huge changes to the criteria themselves.
For example, one way of measuring whether meaningful use is occurring is through the maintenance of an active medication allergy list by the provider. At least 80% of patients seen by the provider or admitted to an eligible hospital should have at least one entry, or an indication that the patient has no medication allergies, recorded as structured data, says Apgar. "That may change," he says. "Not the criterion itself, but the percentage. They may decide to start off at 50%, for example."
If you already have components of an EHR, talk to your vendor because it will need to start reprogramming and give you a meaningful use–compliant upgrade once the certification final rule arrives this spring.
And ask the vendor about timing. "The vendor can give you an estimate on how much time it is going to take to make the changes to the application, but your vendors are likely not going to start making programmatic changes until that rule is final," Apgar says.
Timing could get tight in the fall for those hoping to catch the first meaningful use incentive payment. You can try to get an estimate as to the timing of available upgrades from your EHR vendor. For example, if your vendor needs a few months to prepare an upgrade for you after the final rule comes out, you may have difficulty implementing the upgrade in time to take advantage of the first opportunity for earning incentives.
"You may be looking at six months to a year implementation time, and then at that point you can start saying you're doing meaningful use," Apgar says. But taking even six months may mean you aren't eligible for the incentive payments until 2011 or 2012.
Also, note that vendors can't really predict how long it will take to certify their applications because that information is not yet available from the government.