Waiting Until 2012 To Apply for Meaningful Use May Not Be the Best Option for All Providers

by Gerard M. Nussbaum


In a recent iHealthBeat Perspective, Protima Advani of the Advisory Board Company suggested that health care providers wait until fiscal year 2012 to demonstrate meaningful use of electronic health records. But waiting until 2012 might not be the right solution for every health care provider. In some cases, 2011 might be a better goal date.

Achieving meaningful use requires, for most organizations, a profound number of cultural and workflow changes. Rushing to meet meaningful use might result in a lack of firm cultural foundations and poor adoption of new workflows. However, if an organization already has a solid plan for EHR adoption and is close to meeting meaningful use requirements, moving forward in 2011 might help prevent a loss of momentum and provide public relations benefits.

Deciding when to demonstrate meaningful use also has a financial component. Although delaying meaningful use until 2012 will not result in the loss of total incentive payments, organizations that require EHR incentive payments to fund EHR adoption will need to consider alternative financing if they defer until 2012. Although important, meaningful use incentives should not drive how or when an organization adopts an EHR.

Stage 2 will be significantly harder than Stage 1, and providers will be operating under a considerably shorter timeframe for meeting the requirements. If an organization is ready to move to Stage 1 in 2011, making the move early will give the organization a jump on preparing for Stage 2.

How To Determine When To Apply for Meaningful Use

When determining whether to meet Stage 1 meaningful use requirements in 2011 or 2012, organizations should begin by assessing:

  • The difficulty of meeting Stage 1;
  • The organizations' other priorities occurring from 2011 to 2013; and
  • Any challenges that might occur when adopting known and highly probable Stage 2 behaviors.

The work to move from Stage 1 to Stage 2 will not be executed in a vacuum. Hospitals and physician practices are dynamic places with many initiatives under way simultaneously. For example, a hospital opening a major new facility might want to move to meaningful use before the information systems freeze that would precede the new facility opening. However, others in that situation might wish to defer meaningful use until after the opening, adopting new workflows as part of moving into the new facility.

At the same time, ICD-10 implementation, with a deadline of Oct. 1, 2013, is a major effort for all organizations. Deferring Stage 1 meaningful use until 2012 would put the move to Stage 2 on top of the final push on ICD-10.

If an organization is highly risk averse, then delaying is likely the better option. However, if an organization wants to be a leader, is willing to take reasonable risks and sees the benefit of 2011 adoption -- with a clear understanding of risks and a firm plan for addressing them -- then delaying might not be the best choice. 

Whether a health care organization demonstrates meaningful use in 2011 or 2012, it will need to carefully review its existing vendor contractual commitments regarding timing for delivery of updated applications code to meet any new meaningful use requirements. Furthermore, all providers need to obtain quarterly status updates on their vendors' application development efforts with respect to meaningful use. Understanding the challenges faced by key vendors is critical to a provider's risk mitigation.

Moving Forward

Deciding when to demonstrate meaningful use is not an easy choice. In making the decision, many factors come into play, including the organization's readiness, other initiatives, risk posture, vendor readiness, culture, and expected CMS meaningful use requirements and timing. Organizations need to consider all known information and should also include any necessary risk-mitigation efforts and, where appropriate, alternative plans in their decision-making.

Given the uncertainty, many providers will defer until 2012. However, this decision is not without its own risks and might require action today to address the loss of momentum, cash flow planning, cultural issues and potential for rescission of EHR incentive program funding as part of efforts to control the federal budget.

More importantly, organizations need to ensure that the large investment being made in EHR implementation maximizes the benefits achieved in terms of operating efficiencies, patient safety and quality. Achieving these benefits requires careful consideration of EHR implementation and corresponding workflow changes.

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