This blog is a consideration of the cacophony of eHealth compliance initiatives and whether a provider should replace one over the other, in particular, Meaningful Use .
One of the questions that has come up frequently in various venues these past few months, as the deadline for HIPAA 5010 arrived, the specter of a security breach loomed, ICD-10 Transition Assessment and Planning began, Meaningful Use Compliance just passed its first (90-day) Attestation and resources are stretched like never before, “Is Meaningful Use more important than ICD-10 Transition”?.
It’s interesting to consider such questions without first understanding what is important to a provider. I suggest the answer to the above question is, “It depends.”
For example, Meaningful Use Incentives for a 280-bed private, acute care facility could be approximately $6 Million. What CFO is going to pass on that opportunity? And consider all the benefits of having a consistent electronic patient health records system through this initiative!
One Core Objective for Meaningful Use Stage 1 includes a Health Insurance Portability and Accountability Act (HIPAA) Security Risk Assessment. The U.S. Department of Health and Human Services (HHS) in conjunction with the Office of Civil Liberties (OCR) and each State’s Attorney Generals’ office now can impose penalties up to $1.5 million annually per entity for violating HIPAA privacy rules. Plus, the breach could lead to loss of Meaningful Use Incentive payments and the loss of professional reputation in the community - A triple-whammy! So, HIPAA Security Risk Assessment and Remediation not only a regulatory must, but it’s a key patient safety issue.
So. ICD-10 Transition. The complexity and cost of implementation is beginning to emerge. According to a recent KLAS report, "…many large health systems are budgeting tens of millions of dollars, and while midsize hospitals will spend less, some are still planning to spend several million dollars…" However, there is also concern the ICD-10 Transition will cause a financial crisis or a short-term revenue slowdown for many healthcare organizations, a position backed up by the recent KLAS Enterprises survey.
However, upside of the conversion to ICD-10 is that this will result in all providers being on the current versions of their software, which will facilitate an easier transition into other initiatives such as Accountable Care Organizations (ACO) and health information exchanges (HIE), which will be a component of Meaningful Use Stage 2.
So consider this outlook- Meaningful Use and ICD-10 are aligned and complimentary initiatives. These initiatives are about standardizing and improving the capture of patient information at the clinical encounter. The Certified EHR system or modules are simply one of a number of applications that will be on your ICD-10 remediation list. Pursuit of Meaningful Use together with ICD-10 Transition is a parallel and complementary initiative. Approaching them as a single health informatics initiative will have significant positive return to your provider organization.
William T. Oravecz
Managing Consultant
Strategic Advisory Services
williamoravecz@santarosaconsulting.com