Meaningful Use does add to CIO and IT department workload, but the benefits of moving to the proposed solution ultimately outweigh the risks. The healthcare industry is going through the same transition that the banking, airline, manufacturing, education, and nearly every other modern, technology-enabled industry has experienced. Many of these industries face government mandates and regulation with great success, and healthcare should not be an exception. There is always a fear of the unknown, but if one were to ask a leader of those other industries if they would rather go back to the paper-based past, I would wager that the response would be a resounding 'no'.

My personal opinion is that the financial incentives and penalties related to Meaningful Use mean little. Adoption will not be seamless; early adopters have the biggest financial incentives, but they will also experience the greatest hurdles. Yes, there are many unknown and undecided variables; I personally consider data security, risk mitigation and patient acceptance of EMR ongoing concerns. On the other hand, reducing prescription errors and interactions is a desirable, achievable goal. From a medical standpoint, what could be better than having near-immediate access to years of patient data, x-rays, scans and tests? Better still, data mining could show family history, tie in environmental contributors from other data resources, and eventually include genetic analysis and automate risk calculations. Examination of EMR/EHR data could aid hospitals and medical centers in targeting specialties and treatment options to an area based on trends analysis, census, and CDC data. These studies are far more difficult with the disjointed, non-standardized, recordkeeping methods used in healthcare today.

EMR adoption and Meaningful Use is much like a bus heading to its destination. While many may question the cost of the fare, the number of stops, and the bus' schedule, the fact remains that the bus will make the journey nonetheless. One can either ride the bus and reach the destination or start walking down the road to the rhythm of their shoes. One thing is certain - the bus will get there first.

I wrote the following. It was published yesterday on healthsystemCIO.com.

“My work here is done.”If something is worth doing, it is worth doing badly. Mistakes are inevitable—don’t be afraid to make them. However, pick your mistakes—let them be mistakes of your choosing, not mistakes born out of the hubristic approach of others. Permit me to explain.

Hospital CIOs have a goal or set of goals they must meet to help drive the mission, vision, or strategy of their organization.

Those hard-working people in Washington also have a set of goals relating to healthcare IT, EHR, Certification, Meaningful Use, and interoperability.

The two sets of goals do not necessarily overlap—they may not even intersect. Yet most hospitals are no longer marching to the beat of their own drummer—they may be too far gone to even hear the music. Washington appears to have created a Pied-Piper response—providers are trading their own goals and marching lock-step towards a series of goals that are neither well-defined, nor meet the business requirements of the providers.

Got an example? Sure. Which one of your strategy meetings created a business imperative stating the hospital’s five-year plan includes being able to link to Schroedinger’s Cat Hospital in Any-Zip, USA? None. Yet most hospitals are ready to invest scarce resources to meet DC’s interoperability requirements. (This is different from being able to connect to organizations within your provider network.)

None of the initiatives in Meaningful Use and Certification offer anything to support a hospital whose mission includes retaining ambulatory physicians, improving Patient Equity Management, or increasing revenues.

What if there were no Certification, and no Meaningful Use? To those thinking the question has no merit; Certification and Meaningful Use only have the merit bestowed upon it by providers. Absent providers, Meaningful Use has no meaning.

What few people seem to be asking is, “Why are we paying so much attention to what is coming from Washington?” Providers actually have a choice of which mistake, which risk, they should assume;

• Do you follow the coordination goals coming from Washington and then see how well your business goals fit theirs once you have jumped through hoops to meet Meaningful Use and complied with Certification?
• It is impossible to follow a set of goals which have yet to be finalized
• There are numerous undefined external influences which will impact their goals
• Following DC’s goals will further constrain providers’ ability to meet external influences
• Being flexible enough to meet those influences may prove to be more important to providers than the possibility of collecting incentive dollars
• What percent of your resources will you have to dedicate to meeting DC’s goals
• Which other projects must be sacrificed to meet it
• Do you follow your own business goals and then see if it makes sense to try to meet Meaningful Use and Certification
• Which goals make your hospital more competitive
• Your hospital may not even qualify for the incentive money
• Is the incentive money enough to warrant sacrificing your business goals
• If you do the analysis, you will probably find the ROI from following DC’s path is negative—especially since the requirements of Stages 2 and 3 are not defined.
• If you are not well along the path, you will probably discover you are entering a race that cannot be won in the allotted timeframe
• If you are well along the path, you may not pass the Meaningful Use audit for Stages 1, 2, and 3—especially since the requirements of Stages 2 and 3 are not defined.
•Define for yourselves Meaningful Use, what is meaningful to you, and use your criteria to determine what meaningful means to your hospital.

With the entire industry changing before our eyes, providers owe it to themselves to do the due diligence and at least develop a rigorous analysis before heading down a path from which they cannot easily return. Many, if not most, may be better served by approaching the issue as though there is no ARRA money. There is no guarantee you will get it even if you try for it.

How much money would it take for you to be willing to sacrifice your hospital’s plans? Five million? Ten? I think we all know the best answer is you are not willing to sacrifice your plans for any amount.
If you are interested, this link is for a PowerPoint presentation, “Should you meet Meaningful Use?”

http://www.slideshare.net/paulroemer/should-you-meet-meaningful-use

paulroemer@healthcareitstrategy.com

I have included the actual requirements since there is a lot of confusion but basically meaningful use requires a risk assessment, covered entities can request that their business associates supply a risk assessment, and all business associates must prove that they are compliant.

Meaningful Use Item 23. Protect electronic Information created or maintained by certified EHR technology through the implementation of appropriate technical capabilities. Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1) (HIPAA Security Rule) and implement security updates as necessary.

Under NIST guidelines for HIPAA Security Rule Compliance, Covered Entities “May consider asking the business associate to conduct a risk assessment that addresses administrative, technical, and physical risks, if reasonable and appropriate.” (NIST 800-66, rev 1, p48.

H. Administrative Requirements and Burden of Proof—164.414 Section 164.414(a) requires covered entities to comply with the administrative requirements of§ 164.530(b), (d), (e), (g), (h), (i), and (j) of the Privacy Rule with respect to the breach notification provisions of this subpart. These provisions, for example, require covered entities and business associates to develop and document policies and procedures, train workforce members on and have sanctions for failure to comply with these policies and procedures, permit individuals to file complaints regarding these policies and procedures or a failure to comply with them, and require covered entities to refrain from intimidating or retaliatory acts.