August 6, 2010

Medicaid Cost Containment Task Force Begins Seeking New Ideas

A meeting of the Medicaid Cost Containment Task Force and Medicaid Oversight and Advisory Committee was held on Tuesday July 20 in Frankfort, KY.  This is a joint Senate-House task force charged with advising the legislative chambers and the administration on approaches to reduce the growth in Medicaid spending.

Elizabeth Johnson and Neville Wise, Commissioner and Deputy Commissioner of Kentucky Medicaid, made a lengthy presentation to Senate and House members of the Task Force and Committee.  The Task Force and Advisory Committee included a number of lawmakers including Senate President David Williams and House Speaker Greg Stumbo, both aspiring governors.

The presentation by Commissioner Johnson and Deputy Commissioner Wise covered:

  • An Overview of the Medicaid Program
  • Medicaid Cost Drivers
  • Medicaid Cost Containment Measures
  • Medicaid Pharmacy Benefit

Medicaid provides coverage to approximately 800,000 of Kentucky’s most vulnerable citizens, including 60,000 children.  Medicaid paid for 21,000 births in Kentucky in 2009, approximately 37% of all Kentucky births for that year. That’s a startling percentage given that Medicaid is intended to cover our poorest citizens.

Kentucky’s Medicaid program has seen unprecedented growth in the number of new enrollees over the past year due to a weakening economy.  During 2009, over 3,000 new recipients were added each month compared to 930 per month in 2008.  Most of the new recipients were children.

According to Commissioner Johnson, Medicaid is the primary payer of healthcare in Kentucky.  Medicaid has approximately 40,000 enrolled hospitals, physicians and other providers. 

Commissioner Johnson identified the following cost drivers during 2009:

  • Extraordinary Events
    • Hospital Inpatient Medicaid Settlements
    • American Recovery and Reinvestment Act Payment Acceleration (stimulus funds provided to shore up state shortfalls)
  • “Unprecedented” Eligibility Growth related to the poor economy
  • Cost and Utilization Growth
    • More physician offices converting to Primary Care Centers and Rural Health Clinics (with enhanced payment rates from Medicaid)
    • New services
    • Physician payment increase

The Medicaid cost containment measures taken, or to be taken by Medicaid include the following:

  • Post payment pharmacy audits
  • Prior authorization of certain drugs
  • Changing time when recipients can refill a prescription
  • Fill prescriptions from Medicaid Providers only
  • Modify coverage of OTC medications
  • Enhanced Lock-In Program
  • Quit paying for hospital acquired conditions and never events

Efficiencies achieved by Medicaid outlined by Commissioner Johnson are as follows:

  • Diabetic supplies to be purchased through pharmacy instead of DME
  • New Program Integrity Support Vendor
  • Implement recoupment from providers billing in excess of coverage limits
  • Revenue Intercepts
  • Health Insurance Premium Payments

The following is a list of Medicaid benefit expenditures for selected categories of service in 2009:

  • Inpatient and Outpatient Hospital      $1.05 billion
  • PCC and RHC                                                 $149 million
  • Community living waiver                        $241 million 
  • Physicians                                                       $339 million

Total expenditures for these selected programs in 2009 were $1.78 billion (total Medicaid spending, when including other services such as nursing home care were about $5.5 billion). Commissioner Johnson outlined a total savings of $65 million or 3.6% of the selected services (around 1% of total spending) from the above cost containment measures and efficiencies. Some of those measures have not been implemented as yet.

One interesting point made by Senate President Williams was that Kentucky has many people in low wage jobs that have employer sponsored insurance.  These people would most likely qualify for Medicaid.  In 2014, when coverage mandates begin with Health Care Reform, he speculated that some employers will drop their health insurance and pay the penalty tax.  If this happens, many of these people will likely become Medicaid recipients.

There was much discussion about the Lock-In program proposed by Medicaid.  This is a program where recipients, who have certain utilization characteristics (inarticulately referred to as “frequent flyers” in the industry), will be “locked-in” to a primary care provider, pharmacy, and hospital for non-emergent care.  Commissioner Johnson estimated the savings for Medicaid would be approximately $5 million.  If a recipient goes to the ER for non-life threatening services, the Hospital is to discharge the recipient to their primary care physician (PCP) and will be paid an assessment fee only.

President Williams discussed Medicaid’s “Wrap Around” program.  This is where a Medicaid recipient is covered by an employee sponsored health insurance plan.  Medicaid would pay the recipients premium and be a secondary payer.  The discussion centered on whether the Kentucky Medicaid program was actually saving money with such a program.  Commissioner Johnson wanted to determine if more recipients are eligible for this program.  Senate President Williams wanted the Commissioner to quantify the savings the “Wrap Around” program brought to Medicaid.

Finally, Speaker Stumbo wondered aloud if savings could be achieved by scaling back “optional” programs. For example, pharmacy, dental and home care services are provided at the option of the state. There was some discussion, led by Representative Jimmie Lee of Elizabethtown, around the “unintended consequence of eliminating one of the so-called optional services”. For example, eliminating pharmacy coverage might result in diabetics not getting needed medicines and ending up in the hospital, thereby increasing costs in excess of the savings from cutting the drug benefit.

 

Dean Dorton Ford’s Point of View

Kentucky’s administrative and legislative leaders face many tough decisions over the next several years.  With growing enrollment as a result of the weakened economy and a reduction in federal matching funds from stimulus-enhanced levels, clearly something must be done to bring the Medicaid program under control.

It’s not just a question of saving money. Many are questioning our funding priorities from a longer-term strategic perspective. The Kentucky Chamber of Commerce has pointed out that the increasing percentage of the state budget devoted to Medicaid is coming at the expense of funding for education. Independent of that report, The Kentucky Institute of Medicine has published data showing that poor health status is directly correlated with low education levels.

We are racing to the bottom in this endless pattern of poor education, rising poverty, poor health status and ultimately a workforce that is holding our Kentucky economy back from any real growth.

In our view, this pattern must be reversed.

We believe the citizens of the Commonwealth should commit firmly and finally that our long-term priority will be to provide an outstanding education to every Kentuckian, whether through public or private schools. Our benchmark comparison should be to student achievement in India and Asia, not Arkansas, Illinois or California. Our Medicaid program should be examined with that long-term strategy as a backdrop.

We also firmly believe that health care costs, within Medicaid and generally, are driven by personal choices, in many cases enabled by governmental policies, impacting health status. Some are obvious such as choosing to smoke or deciding not to exercise daily. Some are less so, such as the impact farm subsidy programs have on the production (and consumption) of grains. The various issues leading to the high costs of health care illuminate a complex and multidimensional problem that will respond to decisions made by individuals, policy makers and clinicians.

With that as a background, we suggest that the Task Force, and others studying Medicaid and the Health System in general, consider adopting the following principles:

  • Commit to a singular focus on greater educational achievement.
  • Provide a well thought-out, effective and flexible approach to improving health, wellness and prevention.  An example would be to monitoring a diabetic recipient’s compliance with routine health maintenance and perhaps provide assistance in scheduling meetings with dieticians.
  • Change the way providers are paid, rewarding better health status and reductions in the use of high cost services such as hospital emergency rooms rather than rewarding high utilization.
  • Utilize the Lock-In program for all Medicaid recipients, providing a mechanism for reducing emergency room usage. 
  • Kentucky’s Medicaid program is isolated from competition.  Kentucky should explore encouraging private plans and networks to compete for Medicaid recipients.  Private plans and networks will have to design plans that will attract recipients. 
  • Kentucky’s Medicaid program could offer choice to its recipients.  Kentucky could offer a variety of packages aimed at specific health care needs.  Recipients could then choose the plan which suites their individual needs.
  • One problem Kentucky Medicaid faces is lack of predictability in expenditures, paying for services after they are performed.  Consideration should be given to providing Medicaid recipients with a defined contribution plan or a fixed subsidy with which they could purchase care.

Kentucky Medicaid needs to experiment and be innovative to foster much needed change.  The status quo in Kentucky’s Medicaid program is no longer acceptable.  The current status of the Medicaid program is unsustainable and will only get worse if nothing is done.  Experimentation and innovation must begin now in order to address a crisis once Health Care Reform changes are initiated during 2014.

In summary, we believe the following should be considered in reforming Kentucky’s Medicaid plan:

  • There is a correlation to ones education and health and wellness
  • Case Management plays a very important role in wellness and prevention
  • Without competition, Medicaid costs will continue to climb
  • Payment reform should be geared toward patient outcomes rather than fee for service which increases utilization

 For more information please contact Jeff Presser at jpresser@ddfky.com or Mark Carter at mcarter@ddfky.com

August 5, 2010

Are you a “Meaningful User”?

Do you currently use an electronic health record (EHR) or are you in the process of implementing a new EHR?  If the answer is yes, are you expecting your government incentive payment?  If the answer is yes, you need to first stop and evaluate if you are a “Meaningful User”.  It is not as simple as install the EHR and the incentive payments will come.  In order to be eligible for the Medicare or Medicaid incentive payments that were designated by the American Recovery and Reinvestment Act of 2009 (ARRA), you must first prove that you are using the EHR in a meaningful way.

In December of 2009, The Center for Medicare and Medicaid Services (CMS) released the Interim Final Rule on Meaningful Use.  During the time between December 2009 and July 2010, CMS accepted public comment and feedback on the proposed rule.  On July 13, 2010 the Final Rule was released with some significant changes.  The committees took the comments seriously and adjusted many of the requirements to allow for easier early adoption.  However, there still exists some significant effort to be sure you will be considered a meaningful user.

  healthcare graphic

The first step in this process remains unchanged:  to have a “Certified EHR” in place.  Not any EHR, but a certified EHR.  This is very important for those who have had an EHR in place for the past few years.  Has your vendor achieved the certified status?  If so, have you upgraded to the version that is certified?  If your EHR vendor has not committed to get their solution certified by 2011, it may be time to consider a different solution. 

Once you have a certified EHR, you must tackle the hard part of this process.  As things stand, there are 25 criteria for Eligible Professionals (EP).  Originally, all 25 criteria were to be met in full.  However, the Final Rule relaxed that requirement and broke the 25 into two separate groups, Core Criteria Set and Menu Criteria Set.  Currently, there are 15 Core criteria which must be met.  In addition, there are 10 Menu criteria and the EP must choose 5 of the 10 to meet.  That makes a total of 20 criteria that providers need to meet in order to be considered a Meaningful User.

Meaningful Use will be rolled out in three separate stages.  Stages 2 and 3 are expected to get stricter.  The proposed Stage 2 criteria is expected to be released in late 2011 and will not go into effect until 2013.  The timeline for Stage 3 is not yet determined.  The proposed rule had a timeline for Stage 3 but the final rule repealed any timing definition.     

What else changed between the proposed rule and final rule?  Most of the criteria measures were relaxed in the final rule.  In addition, two criteria were removed and two new criteria were added.

One important fact is the incentives and compliance with Meaningful Use is provider specific.  A multiple provider practice can have providers who are not Meaningful Users or who choose not to be Meaningful Users.  It is very important for each provider to understand the criteria and to do a self assessment.

Until recently, there was a great deal of hesitation to engage in any serious thought about Meaningful Use because it was not final and there were so many potential changes.  Now that the rules on Meaningful Use and the ruling on EHR certification criteria are final, it is time to start taking a serious look at your current EHR situation and how you use it.  It is likely that your practice will require some significant process changes to accommodate the new criteria defined in Meaningful Use.

If you would like more information on the Meaningful Use criteria or to get a copy of the Dean Dorton Ford Stage 1 – Meaningful Use Assessment for Eligible Professionals, please contact Jason Miller at jmiller@ddftech.com or (859) 425-7626

 

Jason D. Miller
Director, Technology Consulting

 Miller Jason

July 30, 2010

Disbursement Risk in the 21st Century

Over the past ten years we have seen significant changes in the way we pay our bills.  Not too long ago, no one would have ever dreamed that we could pay all of our bills without using a mail box or those old fashioned stamps.  I now find it a pain when someone gives me a check and I have to go to a bank to put it in to my account.  These changing times have also provided all of us with a little extra time in our day because it is easier and faster to pay our bills and review our accounts.  However, all of these efficiencies that we have gained have brought significant risks with it.  These risks have resulted in significant losses for some companies.  I hope to give you some insight in to some of the risks that come along with all of the efficiencies we now take for granted.

The main risk that occurs when employees have access to spend money electronically is obviously theft.  Theft of money electronically is much harder to detect than when someone steals cash.  We have had significant controls over cash for a long time.  We have authorized signers on our checks and some companies even require dual signatures.  We have all of these controls over checks and cash but what controls do we have over someone transferring money to their own account.  Most executives would say that it would be detected during the reconciliation procedures every month.  What if the person stealing the money electronically is also the person in charge of reconciling that account?  What if this person transferred small amounts each week or month over several years?  It could add up to a significant sum.

Companies need to have more controls/checks and balances over electronic wire transfers and automated clearing house (ACH) payments.  The best control I have seen is where an account is set up to only allow electronic transfers to certain payees.  There is a specific process with multiple signatures required in order to get a vendor added to this list.  If this same company wants to make a single electronic payment to a vendor, then it would require multiple authorizations.  Another way to control electronic payments is to employ proper segregation of duties.  Even the smallest of companies can segregate duties.  Let’s take an example of the company that only has one person in accounting and that person reconciles all accounts and performs all accounting functions.  In this case, I would recommend that the president/executive director or maybe the treasurer for the board or even someone from another department should be set up to perform electronic disbursements.  Under no circumstances should that accountant be the person in charge of wire transfers.

Another area of concern for electronic payments would be credit cards.  Having too many credit cards or a lack of control over credit cards can lead to theft.  Credit cards are an easy way to make purchases (business or personal).  There are various ways to use a company credit card to personal gain.  The easiest is to go to an office store to purchase supplies and then pick up a few personal items.  This can be almost impossible to detect.  Another way is to buy things online from companies that seem to have a business purpose but are actually for them personally.  Another horror story we have all heard about is using a company credit card while on a business trip for excessive expenses (i.e. expensive wine, Broadway shows, etc…). 

The key to safeguarding against theft of cash via the use of credit cards is to first limit the number of credit cards your organization has open.  The more credit cards that have monthly statements coming in increases the susceptibility for something to slip through the cracks.  The next key is to actually review the credit card statements every month.  Review each and every transaction and determine their specific business purpose.  Transactions should be questioned and receipts should be reviewed.  Even if the expense was charged by the chairman of the board – it should be questioned if the business purpose is not evident.  I have a client where the treasurer for the board gets a copy of all credit card statements each month and reviews the transactions for reasonableness.  This may not be feasible for some companies but is something to be considered.  I normally recommend that companies start by limiting the number of credit cards to one or two mainly to be used for office purchases.  I recommend that all travel and entertainment expenses go through an expense report process and have all receipts provided with that expense report.  Then all you have to do is review these few credit card statements every month.

I hope the information above has provided you with some insight into some of the risks related to electronic payments and ways to mitigate those risks.  If you have any questions or would like additional information, please feel free to contact me at lmann@ddfky.com.

Lance R Mann
Manager of Assurance Services

 Mann Lance

June 9, 2010

IRS is Seeking Input from Exempt Hospitals on New Requirements

IRS has issued Notice 2010-39 in which it seeks comments from the exempt hospital community on the requirements of new section 501(r), enacted as part of this year’s healthcare legislation.  The new statute specifically requires exempt hospital organizations to:

  • conduct community health needs assessment every 3 years,
  • establish financial assistance policy,
  • limit amounts charged for emergency or other medically necessary care, and
  • agree to forego extraordinary collection actions before determining whether individual is eligible for assistance under organization’s financial assistance policy.

IRS is specifically requesting comments regarding the need, if any, for guidance relating to the new requirements, what constitutes “reasonable efforts” to determine eligibility for assistance under a financial assistance policy for purposes of the billing and collection requirements, and the provisions of section 501(r)(2)(B)(ii), which provides that an organization that operates more than one hospital facility “shall not be treated as described in [section 501(c)(3)] with respect to any such facility for which such requirements are not separately met,” including the tax consequences of a failure with respect to some, but not all, facilities and the proper tax treatment in future periods in such a case.

Click here to see  notice for additional information and let us know if there’s anything you want to discuss.  Comments must be submitted by 7/22/2010.

For more information please contact Leigh McKee at lmckee@ddfky.com

McKee Leigh

May 10, 2010

EHR Certification Update – Q2 2010

Whether you have already implemented an electronic health record (EHR) solution or you are still evaluating your options, it is VERY important to understand the issue of certification.  Assuming you are up to speed on the American Recovery and Reinvestment Act of 2009 (ARRA), the HITECH Act, and Meaningful Use (MU), you have heard of the topic “Certified EHR”.  If you are not up to speed on the previously mentioned topics, please visit http://www.ddfky.com/HITECH-Act.html.

There is still some confusion around the details of what the certification process will look like.  Previously CCHIT (Certification Commission for Health Information Technology), an independent body, provided certification standards and testing for healthcare information systems, including EHR’s.  With ARRA, the government has assumed and placed the responsibility of setting standards and the certification process with Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC).

The ONC has outlined a process by which a company can apply for certification and has established the criteria for becoming an accredited certification testing organization.  The ONC will begin accepting applications from organizations who wish to fulfill the role of EHR certification testing in May of 2010.  Currently there are two known organizations that plan to seek accreditation, CCHIT and The Drummond Group.

Here is where the confusion begins.  Any EHR vendor that advertizes their software as CCHIT certified, for any year, is NOT yet certified for MU.  CCHIT 2011 and below does not guarantee ARRA/MU certification.  All EHR systems will need to be tested and certified for ARRA/MU sometime after June of 2010.

CCHIT will likely continue to offer its own certification in addition to any certification that they get approved by the ONC to offer.  However, the standard CCHIT certification will be no more than a Good Housekeeping or J.D. Power and Associates type of achievement. 

It is very important that you understand where your current or potential EHR solution stands.  Demand that your software vendor keep you updated on the roadmap and progress as it relates to certification.  It is highly unlikely that any software solution had the full set of functionality to meet the MU requirements.  Therefore, the vendor’s first step is to make the required enhancements to the software.  This step in and of itself could be quite challenging for vendors with limited resources.  The second hurdle is to participate in testing and demonstrate that the EHR solution in fact does offer all of the capabilities as required for MU.

If you are still in the process of evaluating and selecting a solution, keep in mind that this is only the first round of requirements and testing required.  MU will be rolled out in three distinct stages over the next five years.  This means that any solution provider that you choose will need to be up to the challenge of continual enhancement and certification. 

If you have any questions regarding the HITECH Act, Meaningful Use, EHR Certification, please contact Jason Miller at (859) 425-7626 or jmiller@ddftech.com.

Miller Jason

April 13, 2010

RAC BLACKOUT DELAYED – RAC WILL MOVE AHEAD WITH COMPLEX REVIEWS

The anticipated blackout period for the Recovery Audit Contractor (RAC) for Kentucky has been delayed.  Highmark Medicare Services, Inc. (HMS) was awarded the Medicare Administrative Contract (MAC) for combined Part A/Part B Medicare services in Jurisdiction 15 which is comprised of Kentucky and Ohio.  However, two protests were filed which have delayed the transition from the current fiscal intermediaries to Highmark.  Providers will eventually receive notification of the timeline for the transition once it has been determined.  The ninety day blackout period for the RAC will be defined once the transition timeline is set.  For now, all providers should anticipate the RACs are conducting business as usual and proceeding with their audit agenda.

CGI Federal recently posted new approved issues on their RAC website.  The announcement is further indication that 2010 will be a busy year for providers; particularly for complex reviews involving MS-DRG coding and DRG validation. There are over thirty-eight issues that deal specifically with MS-DRG and DRG validation.   Medical necessity reviews are specifically excluded from review at this time.  With auditors beginning the process of conducting more advanced audits, it is anticipated that RACs will attempt to find evidence of “upcoding”.  It is very resource-intensive to respond to complex reviews. Providers have only forty-five days to respond to the RAC notification.  In some instances, the information they are requesting may go back to October 1, 2007 so the medical records may be in storage, some may be on paper, and some may be electronic.   The complex review will require many more man-hours from providers than an automated review. 

Dean Dorton Ford recommends that providers visit the CGI website frequently and prepare for the complex reviews that are anticipated for 2010.  Here are a few simple measures to help you prepare and reduce your risk in 2010:

  • Review all approved issues for your region
  • Conduct internal audits for coding and DRG validation on the approved issues list
  • Physicians documentation remains key to successful for appeals – conduct documentation audits and education as necessary based on internal review and audit findings

In addition, the Office of the Inspector General (OIG) released a report in February of 2010 on the outcomes of the Recovery Audit Contractors’ Fraud Referrals.  It simply stated that during the Demonstration project, RACs identified over $1 billion in improper payments, yet only referred two cases of fraud to the OIG.  RACs do not receive any contingency fees for the cases they refer so there may be some disincentive for RACs to refer cases of potential fraud to the OIG.   RACs are required to report any cases of potential fraud that they identify; however, they must be able to identify fraud to refer it.  CMS is going to provide mandatory training on the identification and referral of fraud.  Also, the OIG recommends they implement a database system to track fraud referrals that arise from the fraud referrals from the RACs.

For more information please contact:
Pam Hicks
phicks@ddfky.com
859.425.7636

Hicks Pam 2

January 6, 2010

Meaningful Use Defined

As promised, the Centers for Medicare & Medicaid Services (CMS) delivered their proposed rule defining meaningful use of certified electronic health record (EHR) technology.  As provisioned in the American Recovery and Reinvestment Act of 2009 (Recovery Act) incentive payments will be available to eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) who can demonstrate meaningful use of EHR technology.

 On December 30, 2009, CMS released their 556 page proposed rule on the requirements for the EHR incentive program (RIN 0938-AP78 and CMS-0033-P).  The major component of this rule is the definition of meaningful use.  CMS is proposing a multiple stage rollout for meaningful use.  Stage 1 is the focus of the current proposed rule.  Stage 1 criteria will be in effect for reporting year 2011.  CMS anticipates that Stage 2 will be implemented for reporting year 2013, and Stage 3 will be implemented for reporting year 2015.

 The proposed Stage 1 criteria for meaningful use focus on electronically capturing health information in a coded format, using that information to track key clinical conditions, communicating that information for care coordination purposes, and initiating the reporting of clinical quality measures and public health information.  The proposed criteria for meaningful use are based on a series of specific objectives, each of which is tied to a proposed measure that all EPs and hospitals must meet in order to demonstrate that they are meaningful users of certified EHR technology.

 For Stage 1, CMS proposes 25 objectives for EPs and 23 objectives for eligible hospitals that must be met to be deemed a meaningful EHR user.  For a detailed listing of the EPs and hospital criteria, please visit our website: www.ddfky.com/HITECH-Act.html.

 In a separate but related proposed rule, the Office of the National Coordinator for Healthcare Information Technology (ONC) released the proposed set of standards, implementation specifications, and certification criteria for EHRs.  Preliminary review of this proposed rule indicates that the standards are primarily based on existing standards and technology.  The intent is to make the goals more achievable in the desired timeframe.  Subsequent rules are expected to follow, with greater detail and steps toward better interoperability.

 Both of these proposed rules will have a 60-day comment period.  The respective agencies will review all comments and make final changes as quickly as possible.  I encourage all interested parties to review the rules and share your comments and concerns with the respective government agency.

 Jason D. Miller

Director of  Technology Consulting

jmiller@ddfky.com

Miller Jason

December 9, 2009

The “Meaningful Use Guarantee”

On February 17, 2009, President Obama signed The American Recovery and Reinvestment Act of 2009 (the Recovery Act).  A major component of the Recovery Act is its emphasis on improving health information technology (also known as HIT).

To accomplish the improvement in HIT, the Recovery Act includes payment incentives for qualifying professionals.  Physicians and hospitals that are considered early adaptors of electronic health records (EHR) can receive a significant amount of money from Medicare or Medicaid.  However, there are many stipulations and criteria for receiving these incentives.

Being eligible for the incentives is not going to be as easy as just installing an EHR product.  One of the major stipulations in the Recovery Act is the demonstration of “meaningful use” by the EHR product.  The problem facing providers is that “meaningful use” was not defined in the Recovery Act.  CMS does not expect to release the criteria for “meaningful use” until the end of 2009.  There is also expected to be a period of time for discussion and refinement.  I do not anticipate a final definition until sometime late in the first quarter of 2010.

So what is the issue?  Healthcare providers are reluctant to make any major decisions on EHR solutions until “meaningful use” is fully defined.  On the surface, that would seem like a logical process.  However, the incentives become available in 2011 and it is anticipated that you will need some amount of historical information (3 to 6 months at a minimum) in your EHR to be able to demonstrate “meaningful use.”  Again, so what is the issue?  An average EHR solution implementation, for a five physician practice will require a minimum of ninety to one hundred twenty days to be up and running.  That is only considering the EHR functions.  If the practice management (billing, scheduling, etc.) modules are also needed, that will likely double the time required.  Larger practices and hospitals are looking at much longer implementations to account for increased complexities and size.  Another item to consider is the probable increase in demand of EHR products which will only lengthen the implementation time lines.

To help alleviate the concerns of potential customers, the larger EHR solution providers have started offering a “Meaningful Use Guarantee.” The goal is provide potential customers with some comfort that they can go ahead and make decisions even though we do not know what the criteria will be.  The software companies know that we cannot all wait until the first or second quarter of 2010 to make the decision and expect to be ready in time for 2011.  

Providers should be cautious as to how the “Meaningful Use Guarantee” is worded.  I believe it will be very difficult for a software company to guarantee that a healthcare provider will receive the incentives.  There are too many factors within your organization that they cannot control, nor do you want them to.  The kind of guarantee that you should be looking for is one that states that the solution provider will guarantee that their software will be adapted to meet any certification criteria by a set time. I believe that any of the established and large EHR solution providers should be able to react quickly enough to any “meaningful use” criteria.  The ability to accomplish this will primarily be determined by their size and resources.

I believe that there are many safe bets out there that allow you to begin evaluating and working toward selecting an EHR vendor.  Just be sure they are established, motivated, and have the resources to react quickly enough. 

A final thought of caution.  These incentives are there and motivating healthcare professionals to engage in technology improvement.  I do believe this is ultimately a good direction for the profession.  However, please be cautious as you work through determining the right solution for your organization.  Technology itself is NOT the whole answer.  A software solution is only as good as the process and ability of those people using it.  Be sure you do not rush your EHR implementation for the sake of receiving the incentive.  A bad implementation could ultimately cost you and your organization more than these incentives provide.

If you would like assistance on your EHR project, please contact Dean Dorton Ford.  Our team of Technology, Healthcare Compliance, and Performance Improvement consultants are uniquely qualified to help your organization work through the evaluation and transition process. 

For more information, contact Jason Miller.

Jason D. Miller
Director, Technology Consulting
Dean Dorton Ford
(859) 425-7626
jmiller@ddftech.com

Miller Jason