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A few days ago, members of the College of Healthcare Information Management Executives (CHIME) testified before a federal panel in Washington, D.C. The hearing was entitled “Real World Experience Working with Meaningful Use.” The panel consisted of members of the Implementation Workgroup of the HIT Standards Committee, who in turn report to David Blumenthal, M.D., HIT’s national coordinator.

CHIME representatives shared their direct experiences mainly to convey the challenges hospitals are facing in meeting the HITECH requirements for achieving “meaningful use” of electronic health records. Not coincidentally, the meeting was assembled about a week after the January 3rd registration opening for the Medicare and Medicaid electronic health record (EHR) incentive programs. The money is now available and qualifying healthcare entities could start receiving payments as early as April or May.

Shortly after becoming HIT’s national coordinator Dr. Blumenthal reinforced that achieving the vision of “an interoperable, national health information system” will require unprecedented collaboration between the public and private sector. Last week’s CHIME meeting panel meeting was an attempt at doing just that.  Think of it as “Policy, meet real world. Real world, meet policy.”  CHIME is an executive organization that serves CIO’s and other senior healthcare IT leaders. In includes more than 1,400 CIO members and over 70 healthcare IT vendors and professional services firms. In meeting with HIT Workgroup, the CHIME delegation hoped that by bringing real word experience with EHR to the committee, they will have some impact on the final qualifying criteria for approving “early adopters” of meaningful use (translation: “please lower the bar, particularly for those organizations that have already spent significant time and resources to achieve the goal.”)

Summarizing CHIME’s input:

1.       Revamp meaningful use reporting: The current reporting requirements for achievement of objectives and quality measures are onerous, difficult and time-consuming.

2.       Create a different achievement-level criteria for smaller facilities who typically have smaller IT staffs and/or need to rely on outside vendors to provide services the incentive qualifications consider to be full time positions.

3.       Take into consideration the balance between autonomy and collaboration, particularly when it comes to the requirement to provide for “HIE use cases” showing EMR has been built into physicians workflow. At the individual physician office level, many want to choose their own technologies, but then also expect to be able to send and receive data at will. There is a definite IT knowledge gap here as many physicians don’t actually understanding what’s necessary to ensure all of these systems can “talk” to each other.

At Redspin, we were pleased to see that CHIME did not call the security provisions of meaningful use “onerous, difficult and time-consuming.” In fact, they did not mention security. We’ll take that as full support of its necessity or at least tacit acceptance. Thus, those early adopters should be moving urgently to perform a security risk analysis in accordance with the requirements of 45 CFR 164.308(a)(1). The rule also requires implementation of security updates as necessary and correcting identified security deficiencies as part of its risk management process. From Redspin’s experience with other regulatory compliance areas, we know there will be some lee-way regarding the corrective aspect of the requirement. But at a minimum, healthcare organizations who want to qualify for Stage 1 and start receiving incentive payments as early as possible must: a) identify security risks, b) have remediation efforts underway, and c) put in place an ongoing risk management process. A HIPAA Risk Analysis is the only way to start this process.

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