Early reaction to the Electronic Health Record Incentive NPRM

Last week, I posted the Notice of Proposed Rulemaking from CMS that offers flexibility to Meaningful Use attestation in 2014 .Since then, I’ve received hundreds of emails about it from my fellow CIOs across the country.   Here’s a summary:1.  To clarify, the NPRM offers flexibility for hospitals to attest to Stage 1 criteria for 2014 from July 1 to September 30.   However, it offers no flexibility for 2015 which begins October 1, 2014.    This means that hospitals which are struggling with Transition of Care summary exchange, Electronic Medication Admission Records (EMAR), and Patient Portals such that their implementations cannot be ready by July 1, must be fully ready by October 1, since 2015 requires a full year reporting period for attestation.     Thus, the NPRM as written really only provides a 90 day delay from July 1 to October 1.   It’s too little, too late for hospitals to achieve the business transformation, cultural changes, and workflow redesign needed.   The solution - either relax the Transition of Care summary exchange requirements, EMAR requirements, and Patient Portal usage requirements or make the 2015 reporting period any 90 days in 2015 to enable more time for implementation.2.   Even if a hospital has installed 2014 Edition software and can send Transition of Care summaries, most community-based physicians cannot receive them.   Also, few communities have provider directories which en...
Source: Life as a Healthcare CIO - Category: Technology Consultants Source Type: blogs