Who is responsible for your hospital’s HIT strategy, you or the ONC?  Here are my thoughts regarding “What’s Next” and the “Gap Analysis”  with regard to the ONC’s interim final rule.  Remember, you don’t have to follow the IFR.

What’s Next:

• Most if not all of the current HIT was built prior to government constraints
• The ONC changed the rules after many hospitals already spent millions on EHR and CPOE
• Nobody knows the staying power of the Meaningful Use rules or the impact of reform
  • Will the implementation be pushed back?  Quite possibly
  • Will the requirements be toughened?  Very likely
  • What if reform reduces revenue and increases demand?
  • What if existing doctor and nurse shortages grow worse?
  • What if some of the most vulnerable and expensive patients continue to have no coverage?
  • What if the ONC changes the rules?
  • What if reform cuts costs by eliminating “disproportionate share” payments?
  • What if there is a reduction in Medicare reimbursements?
  • More is unknown than is known about the impact on hospitals and physicians
  • There are two business models in play;
    • The ONC’s and reform’s nationalization and interoperability of healthcare
    • The mission of your organization
    • Do you build your HIT strategy to align with your hospital’s strategy or with the ONC’s strategy
    • Your pre-Meaningful Use HIT goals likely included:
      • Supporting your strategy
      • Consolidation for shared services
      • Clinical integration
      • Operational excellence
      • Reducing functional duplication between departments
      • Process improvement
      • EHR and CPOE implementation
      • Which of those goals would have to be altered because of Meaningful Use
      • What would your HIT strategy have been if there was no Meaningful Use

What’s the GAP between what you had planned and what your now have to consider?

• How many millions will it take to meet Meaningful Use
• What planned HIT projects must be delayed because of timing or resources
• How do those millions compare to what you will receive from the ARRA funds
• Even if the funds exceed the cost to get them, how do the changed systems impact your business model
• You have a number of options to analyze regarding Meaningful Use:
  • Meet Meaningful Use later
    • A wait and see approach buys you time for the uncertainty to settle and for the impact of reform on HIT to become clearer
    • There is no requirement to be first
    • You have five years before Meaningful Use penalties begin
    • If the requirements expand as expected it will likely cost more to modify systems than to wait for a complete set of requirements
• Do not meet Meaningful Use
• Meet all of the Meaningful Use opportunities
• Meet portions of Meaningful Use
• What projects must be undertaken to achieve each option
• Will those projects have long-term value for you, or is their only value meeting Meaningful Use
• What process and change management implications are built into meeting Meaningful Use