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