Here are some of the things that I think I have figured out about document management solutions and electronic health records and the stimulus program. I
send them around not so much under the
thought that they are 100% correct, but rather to make get some correction and
additions from the collected community.
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So here goes…
There is $23 billion in play in two portions.
One portion ($2 billion) goes immediately to HHS and its
sub-agency, the Office of the National Coordinator for Health IT (ONC) and
directs creation of standards and policy committees. We (AIIM) are actively working to connect our PDF/H work up
with the efforts being directed by the ONC.
The second portion sets aside $21 billion (net) to
physicians and hospitals to implement electronic health records. There is a program designed for those
who see large volumes of Medicaid patients, and another for those that accept
Medicare.
In order for physicians and hospitals to qualify for the
incentive payments (that will begin in 2011), they must demonstrate 3 things:
- Use of a certified EHR product with ePrescribing
capabilities that meets current HHS standards.
- Connectivity to other providers to improve access to the
full view of a patient’s history.
- Ability to report on use of the technology to HHS.
So obviously a central question related to number 1 is who
is doing this certification and how does it affect the business of our members?
The legislation does not mandate a specific certifier. Most seem to agree that CCHIT (the
Certification Commission for Healthcare
Information Technology) will wind up being the certifying organization
for acceptable EHR solutions relative to the stimulus funding.
CCHIT is a private nonprofit organization with the sole
public mission of accelerating the adoption of robust, interoperable health
information technology by creating a credible, efficient certification process. The Commission operates with a
nine-member volunteer board of Trustees, 21 volunteer Commissioners who
represent all sectors of health IT and provide strategic guidance and oversight
for the certification process and criteria, and 170 volunteers who serve on 15
workgroups and bring their expertise to the process of creating the
certification criteria.
Last week, CCHIT announced that it has approved final
2009-2010 criteria for certification of Ambulatory (office-based), Inpatient (hospital-based),
and Emergency Department electronic health records (EHR), and for its newly
developed stand-alone Electronic Prescribing certification. The Commission also
approved updated criteria for the Ambulatory add-on options in Child Health and
Cardiovascular Medicine. Besides the detailed criteria and test scripts, the
Commission will publish a companion guide mapping the criteria to the
characteristics of a qualified EHR as described in the American Recovery and
Reinvestment Act (ARRA). The materials will be published on May 29 at www.cchit.org.
Speculation seems to be that CCHIT will then become the
certifying body and the criteria the framework for determining which solutions
will be approved and which will not for stimulus funding.
I am guessing that the criteria will be similar to the
existing criteria, which can be summarized as follows:
- Organizing patient data – demographics, clinical
documentation and notes, medical history
- Compiling lists – problems, medication, allergies, adverse
reactions
- Receiving information – test results, consents,
authorizations, clinical documents from outside the practice
- Creating orders – ordering medication or diagnostic tests;
managing order sets, orders, referrals; generating and recording
patient-specific instructions
- Supporting decisions – presenting alerts and reminders for
disease management, preventive services, wellness; checking for drug
interactions and guiding appropriate responses; supporting standard care plans,
guidelines and protocols; updating decision support guidelines
- Authorized sharing – managing practitioner/patient
relations, enforcing confidentiality, enabling concurrent use among multiple
practitioners and healthcare personnel
- Managing workflow – assigning and routing clinical tasks,
managing the taking of medication and immunizations, communicating with a
pharmacy
- Administrative and billing support – using rules to assist
with financial and administrative coding; verifying eligibility and determining
insurance coverage
So it would seem that the questions before us are something
like the following:
- How will CCHIT as the certifying body and some version of
the above criteria effect business opportunities for our typical document
management solution providers?
- How will the crowding out impact that $20 billion in funding
on “certified” healthcare IT spending have on existing spending?
For example, here are the kinds of health applications in
which many of our companies engage.
How will the presence of the above effect these applications?
- Conversion of medical records from paper to electronic
- Offsite storage of medical records
- Chart Deficiency Management
- Release of Information
- Linkages between existing document management solutions and
certified EHR solutions
- Patient financial services/EOBs
- Common back office administrative functions
So what do people think? What’s right?
What’s wrong? What should
we be worried about?
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