Randy L. Thomas
The American Recovery and Reinvestment Act (ARRA) allocates a pretty substantial slice of the total package to healthcare IT (HIT): $19 billion is "serious" money and underscores the belief of the Obama administration and Congress that HIT is a crucial component in the transformation of America's healthcare system.
Much has been written about how the $19 billion will be applied and the various mechanisms that are being put in place to oversee policy creation, standards definitions, implementation, and the creation of the criteria for "meaningful use" of an electronic health record (EHR). One question that remains, however: What should you do now?
Sometime between now and the end of the year, the recently approved Secretary of the Department of Health and Human Services (HHS), Kathleen Sebelius, must issue final regulations, or interim final regulations, adopting an initial set of standards, implementation specifications, and certification criteria for EHRs. Then, healthcare organizations will have until the end of 2010 to demonstrate "meaningful use" to ensure receiving their share of the stimulus dollars. Given the uncertainty of what these regulations might dictate, the HIT market is essentially frozen.
Organizations that have already implemented an EHR system don't know what, if any, changes they may have to make to their system in order for it to be certified. Other organizations that are just beginning EHR implementation wonder whether they should continue, particularly if rework may be required further down the line. And those organizations that are ready to purchase an EHR system or that are evaluating EHR options may not want to make a decision or continue their evaluation for fear the system they choose may not be certified. (Note: All of the major EHR systems currently available have been certified by the Certification Commission for Healthcare Information Technology [CCHIT]. However, at this point it is unclear whether CCHIT will continue in this role or whether the newly appointed HIT policy committee and still-to-be-appointed HIT standards committee will adopt a different direction.)
Once the regulations are known, healthcare organizations can anticipate a full-court press by HIT vendors and consultants to purchase their EHR systems and services to meet the timelines for "meaningful use," as laid out in the ARRA. They can also anticipate that the queue of organizations requesting services or EHR software upgrades will get rather long, and those at the end of the queue may not get what is needed to effect compliance within the specified time. So despite the fact that there are a number of unknowns, now is the time to act upon what you do know and to prepare your organization for rapid implementation of any required changes. It all starts with planning.
Whether you have a fully or partially implemented EHR or are just starting the selection process, the guiding light as you evaluate your current situation and preparation for ARRA should be your overall IT strategy and its alignment to the goals and objectives of your organization.
Time to Refresh Your IT Strategy?
We all know why ARRA includes money for HIT: Evidence suggests that broad adoption of interoperable EHRs is a fundamental element in improving quality while safely reducing costs. It has been well documented that the American healthcare system is considered inefficient, with uneven access to care. HIT is considered one of the tools our healthcare system needs to increase efficiency, thereby enabling broader access to care for the same or lower cost.
Compare this assessment with the mission, goals, and objectives of your organization. You will likely find a close match. Your organization is likely committed to providing high-quality, safe care at the best price possible. Your organization is probably an active member of your community, committed to improving the health of its citizens. Your organization's IT strategy was created to support the goals of the organization. So, if the intent of the HIT provisions in ARRA is aligned with your organization's mission and your IT strategy is aligned with that mission, your IT strategy is aligned with ARRA.
If you think your organization's IT strategy may be a bit dated, now is the time to dust it off and give it a refresh. As you do so, keep in mind not only the clinical and business goals and objectives of your organization, but also the intent of the national HIT policy over the past four years: to drive effectiveness and efficiency in health care. If, on the other hand, your IT strategy is right on the money, use this time between now and the end of the year to ensure that its intent is well understood throughout your organization. Your organization's approach to HIT adoption should be woven into the fabric of your culture and goals and not simply a response to regulation. Don't let ARRA hijack your HIT strategy.
The currently undefined concept of "meaningful use" that is seizing the market may not be as daunting as you think. First, to state the obvious, "meaningful use" is about use of the technology, not technology itself. If your organization continues to focus the use of its EHR system on improving care, it will almost certainly be on the right track to be aligned with the criteria once released. So, the EHR system you are using is less important than the breadth and depth of adoption and use by your clinicians. If you are in the midst of or have not yet begun the rollout of computerized physician/provider order entry (CPOE), you may want to evaluate the ability of your organization to accelerate adoption now, as CPOE is widely considered to be a significant driver of quality improvement.
Metrics to measure improvement are almost certain to be a component of "meaningful use." If you are using the current quality measures reported to the Centers for Medicare & Medicaid Services and made public on the Hospital Compare web site to measure your improvement over time, you are likely on the right track.
Stay True to Your Strategy
In general, if your organization's IT strategy makes sense for your organization and supports the broad goals of safely delivering high-quality, cost-effective care, your organization is on the right track to benefit from ARRA. At the College of Healthcare Information Management Executives Spring CIO Forum on April 4, 2006, in Chicago, a panel of HIT experts agreed that the bar for compliance will be set neither too high nor too low and will certainly be derived from all work done to date. With tight time frames to comply with the criteria, the incoming secretary of HHS will not start with a blank slate, but will likely incorporate proven approaches into the regulations. Further, the regulation process will provide early insight into the form and content of "meaningful use" as draft regulations are released for public comment.
So, in the immortal advice from The Hitchhiker's Guide to the Galaxy, don't panic! Stay true to your overall IT strategy. Focus on driving improvement. Measure your success. The next 18 to 24 months will certainly be busy, but if the focus of your EHR deployment has centered on improved healthcare quality and efficiency, you should be well positioned to demonstrate meaningful use of your organization's EHR and capture your organization's fair share of the HIT stimulus dollars.
Randy L. Thomas, FHIMSS, is a vice president, Premier healthcare alliance, Charlotte, N.C. (firstname.lastname@example.org
Publication Date: Monday, June 01, 2009