Guerra On Healthcare: Procrastinators Prosper On Meaningful Use Deadlines
Organizations that rush to attest to Stage 1 in 2011 may find themselves in trouble when they find themselves with a shortened timeframe to prepare for Stage 2 criteria.
When I was an undergraduate studying anthropology, I decided to research the level to which museum goers looked at exhibits with critical eyes. As I suspected, my surveys confirmed most visitors merely assumed everything was accurate because the presentation seemed so official. They never thought that the professionals charged with assembling the displays could, in fact, be wrong.
Due to this same dynamic, many of us have accepted at least parts of the meaningful use notices of proposed rulemaking (NPRMs) and final rules with the same degree of confidence that museum goers grant to exhibits. I would say this had particularly been true of the staging dates, presented with such structured (and apparently well thought-out) charts and graphs. Or perhaps people were so busy commenting on the measures that they neglected to cast a more critical eye upon that staging structure.
Most people didn't question the dates, but not all.
A few weeks ago, I received an email from a friend and member of my advisory/survey panel, Rick Lang, VP & CIO at Doylestown Hospital. He asked if I'd heard about a paper from Advisory Board which was counseling its subscribers to hold off on attesting to Stage 1 in 2011. The paper (linked from HealthSystemCIO.com; registration required) noted that while there was nothing to lose from attesting in 2012, there was everything to gain. Namely, it cautioned that attesting in 2011 would mean an organization's Stage 2 reporting clock would start on Oct. 1, 2012. The problem with that scenario was the final Stage 2 rule would only be released months earlier in mid-2012. Attesting in 2012 would give an organization much more time to absorb the rules and implement necessary changes before its Stage 2 clock started ticking.
I told Lang I hadn't heard of the paper, but if its dates were correct, the implications were tremendous. Those implications had been brought to light by someone whose job it was to question the government's nicely staged meaningful use exhibit, and luckily that person was up to the job. As such, I give hearty kudos to the Advisory Board's research director, IT strategy council, Protima Advani.
Her specific recommendation was discussed during last week's meaningful use workgroup meeting, during which Paul Tang, MD, VP and CMIO at Palo Alto Medical Foundation and chair of the workgroup, seemed to have a, "Wow, really?" moment when asked about the scenario by fellow group member Judy Murphy, RN, VP of information services at Aurora Health Care. To Tang's credit, he's launched ONC on a fact-finding mission of sorts to check out the possible snafu and offer some remedies.
At this point, the staging issue will either be adjusted so those who attest in 2011 don't find themselves at a disadvantage, or it will not. If not, providers can heed the Advisory Board's warning and simply wait until 2012. The only ramification in that case will be an inability to know if a low number of 2011 attestations is due to people waiting for the more auspicious reporting time, or a prohibitively high bar of requirements. If it is fixed, the industry can proceed like it never knew anything was wrong.
But let's not forget that the industry almost didn't know anything was wrong, at least not in time to avoid significant pain. The entire industry, especially those of us tasked with questioning events, must serve our readers, subscribers, and customers better by assuming nothing the government issues is handed down perfectly from on high. The efforts of one organization have shown us that even final rules, put through months of rigorous examination and comment, can, perhaps, be wrong.