A Do-Not-Forget Checklist for EHR Switchers on the Hook for Meaningful Use

Posted on November 21, 2013 I Written By

The following is a guest post by Tom S. Lee, PhD, CEO and Founder at SA Ignite.

According to a recent survey by Black Book rankings, as many as 16 percent of ambulatory EHR users may become  EHR switchers within the next 12 months.  Large health systems such as Intermountain (a client of ours) and the Department of Defense have recently announced that they are switching EHRs or are currently evaluating a change. Many such organizations are planning to switch EHRs while continuing to meet increasingly difficult Stage 2 Meaningful Use (MU) requirements.  According to past National Coordinator  Dr. Farzad Mostashari, there will be no delay of MU Stage 2. That means your health IT road map may now include switching EHRs, managing Stage 2 attestations, and achieving ICD-10 compliance.

How do you switch jugglers while the number of balls in the air increases at the same time?

We have encountered a common set of issues and questions in our work with clients, discussions with prospects, and exchanges with thought leaders in the industry related to the EHR switching scenario, especially as it relates to Meaningful Use.  Here are some things to consider:

1. Assess and properly store data from your old EHR for future MU audits. A recent wave of MU audit notices has been sent by CMS to some of the country’s leading health systems. Each MU attestation is subject to audit 6 years after the attestation date.  With this in mind, be sure to pull out and securely and centrally store all supporting data from your old EHR before its license expires.  Get expert assistance if needed to understand how to build a comprehensive and solid audit trail.  One great place start is the guidance on audit documentation provided by CMS.

2. Optimize the timing of the EHR switch relative to government reporting timelines.  For example, in 2014 there is a one-time opportunity to report on only a calendar quarter’s worth of data for many eligible providers, rather than the entire year.  This modification to MU was originally made to accommodate delayed Stage 2 certifications by the EHR vendors.  However, it can also be leveraged by EHR switchers who can time the switch to happen within 2014 to benefit from a lower compliance bar while the massive impacts of switching EHRs are absorbed by the organization.

3. Plan to merge data across EHRs to meet MU reporting requirements.  Even with the 2014 calendar-quarter reporting reprieve, for many hospitals and eligible providers to achieve Meaningful Use in an EHR-switching year it’ll be necessary to stitch together Meaningful Use data across the old and new EHRs in order to meet many MU reporting requirements.  For example, this may be required simply to meet the minimum certified EHR usage threshold to be eligible for the MU program in that year.  Assume merging data will be necessary, prepare how to do so before your old EHR license expires, seek help, or do both. An interesting contingency we have seen is to drive eligible providers to “over perform” on their MU measures on the old EHR in anticipation that MU performance will drop at the outset of adapting to the new EHR.  This will increase the chances that providers’ total MU performance within a reporting period spanning both EHRs will end up above threshold.

4. Plan to be supporting two EHRs at the same time.  Although it is sometimes possible to do a “big bang” switchover to a new EHR across an entire organization, we often see that rollout plans for the new EHR are phased across specialty, location, or other sub-groups.  During those periods when the organization could be supporting two different EHRs, such as two ambulatory EHRs in different geographic regions, it is important to organize and align teams to not only handle the immediate demands of MU but also transition completely to supporting the new EHR.  For example, MU data reporting and attestation can be hard enough for just one ambulatory EHR, much less two.  It takes preparation well in advance of the EHR switch and government attestation deadlines to avoid 11th hour fire drills.

Is your organization juggling MU requirements while switching EHRs? If so, I’m sure that you’ve found there are additional considerations surrounding an EHR switch that are important to keep in mind. I’d love to hear your suggestions in the comments.