Avoiding MU Pitfalls Starts with Following Fundamentals

Building electronic health record systems that comply with the federal Meaningful Use program is a daunting task for providers large and small. But basic "regulatory compliance is a far larger day-to-day challenge" than fighting fraud, says one health system CIO.

When it comes to meeting Meaningful Use requirements, picking the right partner and setting the right policies are the best ways to avoid running afoul of the law or federal regulators, according to a pair of healthcare chief information officers.

"You're making a multimillion dollar investment," said Brian Sandager, CIO at Circle Health, the corporate parent of Lowell General Hospital in Massachusetts. "You want to select a partner who's going to be with you for a very long time."

Finding an EHR partner with longevity potential is particularly important because Meaningful Use is a three-stage process, the Circle Health CIO said. "I can't imagine health systems that are dealing with vendors that are consolidating. To be forced into change has to be an awful feeling as a CIO," he said. "Healthcare is complex enough."

While criminal fraud such as an alleged attestation scam in Texas should always be guarded against in Meaningful Use projects, Sandager said regulatory compliance is a far larger day-to-day challenge. "We're more concerned about the technicalities of the law," he said. "A lot of the rules and laws are really complex. … You have to have an open dialogue with CMS."

Vendor Selection
Circle Health contracted with one of the biggest players in the EHR market, Cerner, to help orchestrate the health system's Meaningful Use program. In addition to the stability that comes with an established partner, Cerner also has "their own people in DC," Sandager said.

John Halamka, CIO at Beth Israel Deaconess Medical Center in Boston, said it is important to consider track record when selecting Meaningful Use equipment and an EHR vendor. "Buy only MU Stage 2-certified technology," he said. "KLAS ratings are also helpful. Vendors such as Epic, Athena, eClinicalWorks, and Greenway are low risk."

Based in Orem, UT, KLAS Enterprises LLC provides performance data on a range of healthcare industry vendors.

On the HealthIT.gov website, CMS offers guidance to providers on selecting a Meaningful Use partner. CMS says "most practices" use the following process: developing an initial plan that identifies key electronic health record goals, conducting a vendor assessment to pick an EHR system that supports the provider's goals, and finalizing the EHR plan after a vendor has been chosen.

Once a Meaningful Use program has been launched, setting effective policies and working with physicians are the crucial ingredients to meeting system design deadlines and avoiding compliance problems, Halamka and Sandager both emphasized.

Federal officials have identified the cut-and-paste feature in many EHR systems as a compliance risk, fearing the ability to duplicate elements of patient records could lead to fraud.

"Cut-and-paste is a matter of policy, not technology," Halamka said. "Use templates for notes and EHR tools that enable medication lists, lab values, and vitals to be incorporated into documentation."

Workflow Issues
Sandager said the cut-and-paste EHR issue is more of a cultural phenomenon in the medical field than a matter of criminal intent. "There's a general fear in the provider base," he said of many healthcare providers who he said have been conditioned to commit overkill on documentation. "The tendency is to just dump it all in."

Circle Health has been working with physicians to make sure the healthcare system's EHR program has the best possible workflow, which has done more than trim a few minutes off each doctor's daily administrative tasks, Sandager said. "The bottom line is we get a better record out of it," he said.

There is also a measure of patience involved in ensuring Meaningful Use compliance in any large healthcare organization, the Circle Health CIO said. "With hundreds of providers, one or two are going to need help," he said.

Many providers are set to launch Stage 3 of Meaningful Use, which is designed to help push the US healthcare system to a value-based model. Sandager said Circle Health is actively planning for Stage 3 and offered one last bit of advice: "Make sure you and your EMR partner are looking ahead."