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Why a Full-Year Meaningful Use Reporting Period Worries CIOs

By Kyle Murphy, PhD

- For those keeping pace with the requirements of Stage 2 Meaningful Use, the 2015 fiscal and calendar years bring with them a full-year meaningful use reporting period and concerns about meeting these demands on their healthcare organizations.


On the surface, a 365-day meaningful use reporting period represents four times the effort of a 90-day reporting period. In reality, the difference between the two is more significant and highlights the increased need for continuity and consistency.

“We just attested the Stage 2 on the inpatient side,” says Faith Regional Health Services CIO Brian Sterud, MBA, CHCIO. “That was a bigger accomplishment than we give ourselves credit for given the number of folks that didn’t do that.”

For the regional hospital and owner of a growing physician practice in northeastern Nebraska, success in a 365-day reporting period means having the right systems and processes in place on time — barring any reduction in meaningful use reporting requirements (e.g., the Flex-IT Act).

“There are certain capabilities that have to be enabled on the first day of the reporting period,” he explains. “If the requirement doesn’t change, then those would need to be enabled as of January 1,2015.  We have those functions enabled and are covered in that respect.”

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Banking on a shorter meaningful use reporting period or experiencing delays in putting these components in place would lead to having to make up the difference in the end, intensifying pressure on providers.

“If we’ve got to do this whole year, it all depends on how deep of a hole you dig and the ability to get out of it,” Sterud maintains.  It’s a numbers game for me. Thus, a 90-day reporting period would allow for us to start as late as October on the provider side. This would allow us nine months to be prepared and ready to achieve all the metrics.”

And while a full-year reporting period for Stage 2 Meaningful Use does not necessarily mean that eligible providers will fail, it will challenge the confidence that these healthcare organizations and providers have in their work.

Not something to take likely

Stage 2 Meaningful Use is not the first phase of the EHR Incentive Programs to require a full-year reporting period. Stage 1 Meaningful Use begins with a 90-day reporting period in its first year and a 365-day reporting in its second year. Of course, changes to the meaningful use timeline have impact the of the Medicare EHR Incentive Program, the Centers for Medicare & Medicaid Services (CMS) expects eligible hospitals and professional to spend two year in each phase of the federally-mandated program before moving on to the next.


Georgia’s Oconee Regional Medical Center just emerged from Stage 1. Even though the healthcare organization headquartered in Milledgeville set its sights on demonstrating meaningful use and receiving EHR incentive payments early on, realizing those goals were a long time coming.

“When the law first went into effect and we began looking at it, I was really skeptical whether or not we could do it,” reveals Oconee Regional Medical Center CIO Alan Whitehouse, CHCIO. “Conceptually, I could understand it. But in reality, it was even worse. I say worse in the context of getting the code done, tested, implemented, and working the way you wanted to do it. So that really was a 2- to 3-year workup just for Stage 1, Year 1 — in other words, the last year we could actually attest and not be penalized.”

Along the way, Whitehouse has learned some valuable lessons about shifting from a 90-day to a full-year reporting as part of Stage 1.

“Personally, I’ll admit that I vastly underestimated the resources required for that,” he observes. “The second year of Stage 1 incorporated a significant number of changes, increased requirements as it were, to meet meaningful use. The 2014 version included things like the patient portal and some clinical quality measure changes.”

While Oconee Regional Medical Center experienced some financial challenges during the beginning of its meaningful use journey, the resource that most threatened its successful participation in the EHR Incentive Programs was personnel as a result of overcoming them.

“We’ve had significant turnover on a director/manager level,” says Whitehouse. “Although you wouldn’t think that impacts IT, every time I turned around it was impacting IT. I always say that IT impacts everything, and everything impacts IT.”

Given the role that these core leaders played in the healthcare organization’s meaningful use efforts, their loss meant that their replacements had to be brought up to speed, leading to disruptions and information gaps.

Despite the frustrations associated with turnover, some positives have emerged from the experience such as in the alignment of the IT and quality departments at Oconee Regional Medical Center. The problem stemmed from the data the two departments used for their reporting not encompassing the same period of time. “We weren’t aligned with what I was trying to get accomplished. And if we would’ve been aligned, we would’ve been much better off,” adds Whitehouse.

Staying the course for a full year

Objects in motion stay in motion unless that impact by an opposing force. The same holds true for meeting the demands of a full-year meaningful use reporting period. For eligible providers, maintaining momentum is the name of the game when moving from a 90-day to a 365-day reporting period in the second year of a meaningful use stage.

For Faith Regional Health Services and Oconee Regional Medical Center, completing a full year’s worth of meaningful use reporting requires the focus of all stakeholders, namely providers and patients. As a result, monitoring the work these stakeholders plays an important role.

“As far as processes we’ve put in place to make sure that we’re there,” says Sterud. “We’re more focused on monitoring, and we have a dashboard that we use to monitor compliance and make sure that we’re hitting the marks where we need to hit them.”


Now that patient engagement comprises an important component of meaningful use, having confidence in meeting those marks is still a difficult thing to achieve. “That’s probably a big focus for 2015 is Stage 2 — the patient portal. We need to maintain our numbers, honestly,” Sterud reveals.

The patient portal has Whitehouse concerned. Oconee Regional Medical Center is dedicating more and more resources in order to get its patient engagement numbers beyond the thresholds required by Stage 2 Meaningful Use. These include identifying patients most likely to use the patient portal, educating patients about the portal using, and having nurses discuss the portal with discharged patient as part of follow-up phone calls.

The healthcare organization is several percentage points away from the five-percent threshold. “It’s going up, but it’s not fast enough. We need to get more folks engaged in that the effort,” Whitehouse explains.

Putting meaningful use in context

Meaningful use isn’t the only health IT-related objective for CIOs to tackle in 2015. Healthcare organizations like Faith Regional Health Services are working to prepare themselves for the long-term goals of healthcare reform by putting in place the appropriate technology.

“The challenge is figuring out what the future will bring for healthcare and how we’re going to operate as far as building toward an outcomes-based reimbursement versus fee for service and leveraging partnerships to that effect,” Sterud explains. “We’re exploring how we can align ourselves properly to be able to operate in that new world and much of that involves IT. The tough part with that is you can’t deploy the system until you’ve figured out what the new world’s going to look like.”

For Whitehouse and Oconee Regional Medical Center, the key to future success is engaging physicians and keeping them engaged.

“If they’re engaged and are committed to it, they’ll find ways or invent ways to make it right,” he maintains. “Getting our physicians to look at it is really the biggest thing. If they take the time to look at it, they say it not as bad as they thought and they provide good suggestions.”

Perhaps the EHR Incentive Programs are a litmus test for healthcare organizations and providers to understand more deeply how to effect sustainable and long-term change. Although industry groups are angling for reduced meaningful use reporting periods, the safest bet is to comply with gathering 365 days of meaningful use data. At the very least, there are lessons to be learned from the experience — some good, some bad.

2015-01-12-chime-smallThe CHIME CIO Features is a collaboration between Xtelligent Media, LLC, and the College of Healthcare Information Management Executives (CHIME), featuring leading hospital and healthcare system CIOs and their experiences in health IT implementation and innovation. For more information about CHIME, visit CHIMEcentral.org.




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