We Have Entered Zombie Land
By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: audits@emradvocate.com
The 2011 Edition of certified technology was put to rest on December 31, 2013. The nails were put in the coffin. We said our goodbyes, made our peace, and tried to move on. Now without warning a CMS Proposed Rule threatens to bring it back to life with a package that has something for everyone. Four years at Stage 1? No problem. “Expired software” meeting MU requirements? No problem. In the numerous conversation I have had with eligible providers and vendors in the past 24 hours there is one recurring theme, confusion.
Now I’m all for flexibility but I am starting to see a sense of disbelief out in the field. What was true one week is not true the next. Time lines have been extended and penalty exemptions have been expanded, all well and good, but it is not enough to quell the confusion and doubt that is now surfacing. Even the rock solid concept of certified electronic health care technology (CEHRT) seems to be losing focus. The functionality currently being finalized for the “voluntary” 2015 Edition CEHRT is not guaranteed to be in the “required” 2017 CEHRT. There is too much uncertainty for EHs and vendors. We really should be on more solid footing. And don’t forget the wild card of politics. It wasn’t too long ago that a Congressman from Pennsylvania took it upon himself to blow up the ICD-10 apple cart. You can read about his little maneuver in one of my recent posts, Power Politics and the Hijacking of Healthcare Policy. No wonder CIOs are having trouble planning for the next few years. They deserve better.
We have passed the apogee in the CMS EHR Incentive program. The lion’s share of incentives are gone and what is left on the table is shrinking. There is real concern that providers are beginning to move away from the MU program. It is time for the second booster rocket to fire if we are going to escape earth’s gravity and make it to the MU moon. We need more than just tweaking here and there. There is danger that without clear direction and buy in by stakeholders we could drift more and more away from the end goal of an electronic and interoperable healthcare system.
I’m hoping someone is meeting behind closed doors coming up with a comprehensive plan. I’m even OK if they are smoking cigars in there. There is need for leadership now but I don’t know with all the agendas and committees in place that it could emerge. This most recent Proposed Rule is a short term fix for a longer term problem and it comes at the expense of credibility.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: audits@emradvocate.com. This post was original published on MeaningfulUseAudits.com.