The question that the healthcare providers need to answer in 2014 is that whether to stay with their current EHR vendor or not.
According to the poll of 17,000 EHR users by Black Book Rankings, around 1 in 6 medical practices might convert to using another Electronic Health Records System in the near future. Also CMS has made it clear that the exemptions related in achieving Meaningful Use requirement will be evaluated on a case by case basis. Opening a new hospital would qualify but upgrading to 2014 certified electronic health records technology (CEHRT) does not. Changing EHR vendors, physician or hospital office acquisitions would not qualify for hardship exceptions. These objectives required well defined plans, operations and experienced team to successfully execute them.
Final rule for Stage 2 criteria was released by Center of Medicaid and Medicare (CMS) on September 4, 2012. It was for both Eligible Professionals (EP) and Critical Access Hospitals (CAH) to achieve incentive payments. Furthermore to the Stage 2 criteria an exception was also made which reduced the reporting period to 90 days despite the Meaningful Use. This delay was applicable to both the EP which followed the calendar year starting from January 1st, 2014 and for CAH it starts in 2013 from 1st October.
Does CMS have provided any opportunity for healthcare organizations to switch their EHR vendors in 2014?
About 17% of EHR users will be transforming to use a different EHR system, the 90 day reporting period will provide a lesser risk time frame for system conversion. For the second year of 2014 CEHRT will need a 365 day collection period. It is a great risk if you are converting before or after the 90 day period. But with a well thought out plan CAH and EP can take advantage of this small time frame available. Those providers that have already received EHR incentive payment will be subject to audit according to CMS.
There are various things to be considered if you and your healthcare organization is looking to make use of the small time frame that is available to transform to another EHR system. First option is that those healthcare organizations that have updated their EHRs to 2014 CEHRT EHR they will attest the first quarter of the year for second year attestation. The stage 1 for the second year allows the flexibility to attest for first quarter. After the attestation is done, the group needs to focus on adoption level and for new functionality in order to prepare for the second stage.
Second option for healthcare organizations that are using 2014 CEHRT and are either reporting on stage 1 or stage 2 and want more time to further prepare for first or second quarter of the existing year. The extra time can be used to implement the new EHR system in parallel with the existing EHR. Carrying out conversions in parallel will test run the process so that right after the 90 day attestation a final conversion and a go live system can occur. The extra time in the year will allow the healthcare organizations to enhance the adoption levels and implement new system workflows and configurations to meet the selected and core menus for stage 2.
Third option is to instantly convert to the new EHR after the attestation period on stage 1 certified software and to attest in the last quarter of 2014 CEHRT year. This option is best for healthcare organizations that have to switch EHRs and have further time to configure, revise their workflows and implement new technologies for stage 2.
Attesting for the 2nd year at stage 1 in the last quarter of the year will offer a large amount of time to transform while avoiding big changes in the attestation period. This option can also be followed by organizations that are attesting for first year at stage 2 by transforming early in the year and later focusing on increasing adoption processes and levels to support new core and menu objectives for stage 2.