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Apr 08: What to remember when EHR replacement meets Meaningful Use

ehr replacements
If you’re thinking about EHR replacement, chances are you’re also looking for a way to optimize and streamline your participation in the EHR Incentive Programs as the industry approaches Stage 2 of Meaningful Use.  There are innumerable tasks to keep in mind when switching one system for the next, including data migration, workflow adjustments, testing and support, and the potential for hurt feelings and confusion among the staff.
Meaningful Use requires providers to keep certain key elements at the forefront of their thoughts in order to continue participation during the sometimes chaotic transition.
Start with a data governance plan
Every big project should start with a detailed, comprehensive plan.  Meaningful Use isn’t just about meeting yearly reporting objectives: it’s a long-term roadmap towards making the best of electronic health records which requires unique input from each and every provider that changes and increases on a regular basis.
“From the EHR perspective, this is where that long-term plan comes into play,” points out Shane Pilcher, Vice President at Stoltenberg Consulting.  “Providers know the type of questions that they’re looking for today.  They need to anticipate the type of questions they’re going to asking in the future.  But in most cases, you don’t know what you don’t know, so you’ve got to be as creative, as imaginative as you can today when you’re setting up your roadmap.  That’s going to give you the information that you need to start defining what used to be collected today in the EHR and what you need to grow.”
Developing a data governance plan will ensure that your clinicians understand what is expected of them now and how that will change in the future to keep up with Stage 2, Stage 3, and any additional incarnations of the EHR Incentive Programs.
You might hope to be paperless, but hard copies are important
Once you switch off your old EHR, it might be hard – if not impossible – to retrieve any Meaningful Use reporting, quality metrics, or other data from the defunct system.  If you haven’t saved your information before pulling the plug, you may be in trouble when it comes time to attest, or if you’re one of the unlucky providers who are chosen for an EHR audit by CMS.
“Not everybody’s system is able to go back to the date you attested and show what the data looks like,”  cautions Rob Anthony, Deputy Director of the HIT Initiatives Group, Office of E-Health Standards and Services at CMS.  “They may have a system that has rolling data, which means that information that you’ve entered long after the close of the reporting period could actually affect the measurement that your system does when you make a subsequent report.  So I always suggest that providers make a print or electronic copy of the actual report that they used for attestation so they can show those numbers when an auditor requests supporting documentation.”
“More is better,” adds Kathleen Rafter, RN, MSN, President of Kathleen A. Rafter Consulting.  “Go through each Meaningful Use objective, know exactly why you chose to report on it, and have a copy of the report.  If it has a yes/no option, you need a screenshot.  And I do suggest having your contracts, because I’ve known situations where the auditor has come back and asked to see where it says that the hospital has purchased certain functionality.”
As providers invest in new software with different add-on packages or plug-in apps, keeping track of contracts, whether or not you’re expecting an audit, will help identify what you’ve bought and coordinate how to use it.
Don’t forget that incentives are a thing of the past
Early EHR adopters had the benefit of up to $44,000 in Meaningful Use incentives to help lessen the sting of the big purchase.  You may have acquired your original EHR during the incentive phases of the program, but don’t forget that the money is trickling to a halt in 2015 as penalties for non-users start to pick up steam instead.
At this point, any EHR replacement activities will be paid for out of the provider’s own pockets, which may affect which type of system you choose.  Ad-supported and cloud-based systems that require little in the way of hardware investments are an increasingly attractive choice for the cash-strapped replacement market. Just don’t be tempted to shave a few dollars off the bill by buying a product from a company that hasn’t been properly certified for 2014 yet.  Time is running out for vendors to push their products through the ONC process, and you don’t want to be stuck with a vendor that can’t make the grade. Source
HIMSS Special Part 1: HIT Visionary Zach Fox
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