To Wait or not to Wait?

I'm often asked by clinicians and hospitals if they should wait to purchase an EHR because of the uncertainty regarding meaningful use and certification.

I tell them to move forward now.

Meaningful Use is complete for 2011 and you'll find the finished matrix online.

Although the HIT Policy and Standards Committees only make recommendations/advise the Office of the National Coordinator and HHS, I believe that the regulations issued in the next few months will follow the spirit of the Commmittee work.

Here's my understanding of the events of the next few months:

1. In mid December, CMS will issue a Notice of Proposed Rulemaking (NPRM) regarding meaningful use, then provide a 60 day public comment period. A final rule on meaningful use will be issued in the Spring.

2. In mid December, the Office of the National Coordinator will issue an Interim Final Rule (IFR) regarding certification criteria and standards. A public comment period of 30-60 days will follow and the final rule on certification criteria/standards will be issued by Spring. This is law the day it is issued (unlike a NPRM which is proposed law). While the IFR will solicit comments, the Secretary is not required to respond to the comments or make changes based on them. Hence, for all practical purposes, the industry should treat the IFR as "final" even though HHS reserves the right to make subsequent changes The certification criteria in the IFR are likely to emphasize privacy/security and data exchange standards. They will replace previous CCHIT criteria, but in the interim you will be well served to pick vendors that have passed CCHIT regular criteria and the additional CCHIT Meaningful Use criteria.

3. In mid December, the Office of the National Coordinator will issue an NPRM defining the Certification process. A public comment period of 30-60 days will follow and the final rule on the certification process will be issued by Spring. CCHIT will likely be one of several conformance testing organizations, coordinated by NIST, that will certify products using the new ONC criteria.

Thus, completely clarity in the form of rulemaking will be available in the Spring.

However, the longer your wait to get started, the more challenging it will be achieve meaningful use in practice by 2011. Also, it's important to get vendor commitments and hire staff now before the real competition for resources begins.

Start by purchasing a fully functional EHR or a hosted solution that was certified using previous CCHIT criteria. Also, ensure it supports data exchange. The interoperability goals for 2011 are likely to be

Lab results delivery
ePrescribing
Claims and eligibility checking
Quality & immunization reporting

so, you'll want to be sure that the product or the product plus third party services support those functions.

If you're a hospital organization, develop a governance structure for prioritizing projects, a budget, a training plan, and a communication plan. Spring will be here soon and any ambiguity will be resolved.

Thus, I think we can predict what meaningful use and certification criteria will be based on existing HIT Policy and Standards Committee work, so you should move forward now without delay. When 2011 stimulus payments begin, you'll be thankful you had the time to prepare.

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