EHR

Should you consider skipping Meaningful Use?

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I am going through an analysis for my client, a hospital chain who has already installed EHR and CPOE to see if they should change their strategic direction to get the ARRA money, or continue along their original course.

It does not have to be an either or decision.  Their options are not do go for MU, to go for all of the money, to go for it at some combination of their hospitals, or to go for it later.  With so many unknowns, it may be best to slow down and evaluate the options. 2011 is around the corner, however you have five years, until 2015 until the penalties begin.

What’s your take?

Who is responsible for your hospital’s HIT strategy, you or the ONC?

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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

Should you consider avoiding Meaningful Use?

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Where were we?

There are a few things stuck in my craw—imagine that.  One is Meaningful Use.  The other is also Meaningful Use.  Permit me to address these one at a time.  I’ll start with Meaningful Use.

Are you kidding me?  Who are these people?  To disguise that of whom I write, let’s invent some aliases, Dr. B and Dr. H.  For all the meetings, all the pronouncements, you’d think sooner or later one of them would state, “There is no way any of this makes sense.”

Why do you say that Paul?  May I?   What if you threw a party and nobody came?  What if you held a $40 billion lottery and nobody won?  Here are the rules.  A handful of people less than seven feet tall decide to buy homes in a community.  All the homes have door openings that are seven feet high.  New people move into the community.  One day the homeowner’s association mandates that all homeowners must build homes with door openings that are seven feet high.  Most homeowners ignore the mandate.  The association then decides to offer the homeowners rebates if they comply with the mandate, and penalize them if they don’t.  Most of the homeowners ignore the mandate.

Indifferent to the fact that their mandate isn’t working, the association decides to add new rules, rules that affect the homeowners who already built homes with seven foot tall doors, and those who didn’t.  One of the rules is that the seven foot tall doors must now be eight feet tall; another mandates that all roofs must be in the basement.  Homeowners who comply will win the lottery.  Those who don’t won’t.

How does the lottery pay out?  It doesn’t.  They made it impossible for anyone to get the money.   Suppose you gave a lottery and nobody won?  Suppose you made it so obtuse that nobody cared if they won.

That’s where I think we are with EHR.  The smart healthcare providers are asking themselves the question, “What if we make a business decision not to meet the Meaningful Use requirements?”  “What if we decide what is and isn’t meaningful.”

There are 2 “business models” in play—the national healthcare model, and the model your firm follows—they have different goals.  I asked my client, “When you made your selection of EHR, did you have any hint that the government was going to create rules to manage what it does?”  I assume their answer is a lot like yours—“Not at all.  We were worried about FDA oversight, but nothing like the stimulus.  The PQRI was available as an incentive to use ePrescribing, but really small potatoes.”

The national healthcare model under development will create an infrastructure such that every patient can be connected to each physician via a series of HIEs and the N-HIN.  To get there, they need you—they can’t do it without you.  What do they need from you?  Participation.  Participation by having and EHR, ePrescribing, and CPOE.

Even if it were to work, what’s in it for you?  Very little.  They know that—that’s why there are payments and penalties.  Most hospitals like the idea of implementing EHR.  Given the choice those same hospital executives would choose to listen to an entire Celine Dion CD if it would allow them to skip implementing CPOE.

If there are not many good business reasons to meet Meaningful Use, why should you build an entire strategy around it?  You wouldn’t paint your hospital pink simply because Washington said you should, although given a choice between the two ideas, pink sounds pretty good.  Let’s say you take them up on meeting Meaningful Use.  You build your strategy, drop current initiatives, implement these systems, train your people—then what?  Indeed.  What happens if the government changes its mind?  Moves the dates, changes the requirements?

In order to go for Meaningful Use you must be able to suspend your ability to think rationally.  If you do not think the HIE and N-HIN model will work—I have not met anyone who thinks it will—why even give Meaningful Use another thought.

My client is a group of 14 hospitals—they could get millions of ARRA dollars.  If you don’t have more than one hospital, your ARRA rebate will be much less.  They have already installed EHR and CPOE.  To get the millions they have to spend millions.  What happens if they spend it and the feds change their direction?  What then?  What do they do with the eight or nine figures of systems they build to follow Washington’s lead?  Take them out?  Modify them?  What happens to their business model as a result of all of this “leadership” from the ONC?

What should you do?  That’s up to you.  Here’s an idea or two.  First, ask yourself what your EHR/HIT strategy would be if there was no ARRA money.  (You do have a written HIT strategy, don’t you?)  Second, decide if you think that the current national roll out strategy will work.  Third, figure out what you won’t be able to do if you have to invest even more time and money meeting Meaningful Use.  Next, add up all the money it will cost you to meet their requirements and compare that to what they will pay you.  I bet the costs are more than the rebate.

I think Meaningful Use won’t exist in 3-5 years.  I think the N-HIN won’t be available by then either.

Here’s the real kicker for hospitals that have more than two beds.  If you have not yet selected your EHR vendor you shouldn’t even be thinking about meeting Meaningful Use for the first year because you can’t there in the time available to you.  That take’s the pressure off, doesn’t it.

Should you consider disregarding Meaningful Use?

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Here’s a reply I wrote to a FierceHealthIT on some of Dr. B’s comments on Meaningful Use.

I know of a hospital who has already implemented a top tier EHR costing millions.  This organization ‘gets it’.  They are currently building a work-plan to see what additional work they must do to meet Meaningful use in time to qualify for 100% of the ARRA money.  First blush—it will take tremendous amount of work for them to do it, but they will get there—if they choose to do so.  They have a choice and the fact that they know that is their trump card.

If a hospital hasn’t even begun the EHR process, as more than 80% have not, coupled with the more than fifty percent failure rates, I’d estimate their chances their chances of making the deadline at less than 1/3.

So, what to do?  Stop and think.  Ask the right questions.  You have a choice of two strategies.  Let ARRA money drive your decision, possibly implement it wrong, and probably miss the deadline.  Then what do you have?  Not much.  Strategy number two; define your requirements, figure out what business problems you need the EHR to help solve, and buy the best one for you.  Confused?  Map out two work-plans for yourself.  One work-plan that shows what you would have to do and what you would have to spend to meet the ARRA requirements.  Draft a second work-plan that shows what you would have to do to implement what you really want.  Compare the two plans and determine your deltas, your gaps.

Are you going to chase this for ARRA money?  Because someone in Washington thinks you should do this?

Answer this question first.  Is every hospital the same?  Are you as good as the best, better than the worst?  The EHR vendors think the answer is yes.  Keep you processes the same, skip change management, and the implementation will be a breeze.  We make every hospital look and operate the same.  When did the EHR vendors become the best practice savants?   The government thinks the answer is yes—that is why they are holding everyone to the same Meaningful Use standard.

One standard does not fit all hospitals—nor should it.  Set your own standards and decide for yourself if you fit your version of Meaningful Use.  ARRA money will end—then what?  You’re stuck with your EHR.  Get one you need.

You’re no Aristotle

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Everything is written with the idea of persuading the reader; either explicitly—what is written is true, or implicitly—what is written is informative or funny, thereby persuading you that the author is informative or funny. Aristotle employed three forms of rhetorical persuasion; pathos, ethos, and logos. For those of you thinking, “Yeah, but you’re no Aristotle,” you’ll get no argument from me, but you have to admit, it’s a good likeness.

I basically write from whatever stream of clatter happens to be knocking about at the time. For me, writing is a little like speaking in parenthesis, only a little quieter and with more ambiguity. So, what is lurking up there at the moment? Sure you want to know?

I’m trying to convince my son the futility of not doing something correctly the first time he does it, arguing that it takes twice as long to do it wrong as it does to do it correctly. I call it the DIRT-FIT Principle—Do It Right the FIrst Time. For instance—loading the dishwasher. It takes a certain amount of time after clearing the counter to place the dishes, glasses, and utensils in the dishwasher pell-mell. It takes twice as long to redo it.  The same principle applies to making his bed, putting away his shoes, and brushing his teeth.

The same principle applies to implementing an EHR system. It costs twice as much to put it in twice as it does to implement it correctly the first time. I bet you know a hospital who is busily implementing EHR 2.0.  There is the difference between EHR implementations and sons. Implementations have the right not to do it correctly the first time—my son doesn’t.

Pass the salt

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Okay campers, we’re going to jump right in to this one. There was a point not too long ago when the US was involved in the SALT talks, the Strategic Arms Limitation Treaty. For those too young to remember, the US and the Soviets—that’s what we used to call the Russians. Actually, they were called Russians before they got married and changed their name to Soviets which is neither here nor there.

This came about because the two countries were MAD at each other. Not in the usual sense, but in the sense of mutually assured destruction—of the world—several times over. Anyway, it finally occurred to both sides that perhaps we only needed enough weapons to blow up the world a few times instead of hundreds of times. What was the result? We’re still here. We’re here because the people who built the weapons agreed to greatly reduce their number of weapons. They learned how to function differently. Instead of saying we can’t do that, they took the approach of saying, “If we wanted to do that, how would we do it?” Getting rid of nuclear weapons—no small feat.

Segue. I realize this is a bit of a stretch just to make a point, but since we’ve come this far we might as well make it. What would you do if you came to work one day and received an email which read that your organization had decided against ever implementing an EHR?

To me that is a perfectly reasonable idea. Of course, I’m someone who wonders how the color purple feels. But why not stop all of this foolishness around EHR?  Agree, or is killing EHR a foolish idea?

I think it’s much less foolish than implementing an EHR and having no reasonable expectation that it will work.  The odds are that your EHR has a better chance of failing than it has of succeeding.

I have no problem with EHR.  I do, however, have a problem with businesses constantly making the same mistakes, making EHR a multi-million dollar repository for their mistakes, and then complain about the fact that the EHR isn’t doing a good job.

What do you think?

What may be driving the Meaningful Use announcement

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I often write not because I have something that needs to be said, but to try to explain something to myself.  If I get to a point where I think I understand an issue, I’ll make it public to see if the comments reflect my understanding, or to see if I need to have another go at my own thought process.  Which leads me to this—

Let’s back up the horses for a minute and return from whence we came.  EHR.  The idea was simple.  Two groups; patients and doctors.  Create a way to transport securely the medical records of any patient (P) to any doctor (D).

For the time being, let’s keep this at the level that can be understood by a third grader.  What two things do I need to satisfy this P:D relationship?  Data standards and a method of transport.

Do we have them?  We do not.  That being the case, what fury hath the ONC wrought?  (1 Roemer 9:17)  if you don’t have what you need, and you don’t have either the authority or a plan to get what you need, you must facilitate (fund) the creation of workarounds to fill the void.

At some point, the conversation must have quickly shifted from, “We need standards and transport”, to, “Since we don’t have standards and a means of transport, we must come up with other ways to try to make this work.”  Now, I don’t believe this is literally what happened, but I think one could see how it might have evolved.

Other ways.  What other ways?  The ONC loves me; it loves me not.  HITECH.  ARRA.  Take the monkey off our back and put it on the backs of the providers.  Pay doctors to implement EHR.  Smote them if they don’t.  Write checks.  Big checks.  Lots of big checks.  Instead of coming up with a single transport plan and one set of standards, provide guidelines.  Make pronouncements.  Fund RHIOs and make them responsible for creating hundreds of unique transport plans and ask the RHIOs what progress they are making towards a single set of standards.  Get the monkey off your back.

Create artificial goalposts that get the HIT world all a twitter every time the ONC makes a proclamation.  What goalposts?  Meaningful Use and Certification.  Just so there is no misinterpretation of what I think the issue is permit me to spell it out—Meaningful Use and Certification exist because there are no standards and there is no means of transport.  Conversely, had the ONC developed standards and transport, there would be no discussion of Meaningful Use and no Certification.  Standards would have forced vendors to self-certify.

The other activity could be viewed as a feint.  Not one developed out of malice, rather one that came about from the void that resulted from the lack of a viable plan.  Meaningful Use and Certification are expensive workarounds for a failed or nonexistent national EHR rollout plan.  As are RHIOs and RECs, the six million dollars, and the forty billion dollars.

The HIT world grinds to a halt at the very mention of an announcement from the ONC.  Their missives are available in PDF or stone tablets.  Imagine someone robs a bank, and as they exit the bank, they jaywalk on their way to their getaway car.  The police missed the robbery, and focus all their efforts on the secondary issue, the jaywalking.

The chain of events has caused the focus to move away from the primary issues of no standards and no plan, and towards a plethora of secondary issues, issues for which hundreds of people are responsible and no single person has authority.

I think that by the end of 2013 pronouncements on Meaningful Use and Certification won’t be able to buy time on MTV.

If any of this is close to being correct, what are the implications for a hospital looking to select and implement an EHR?  Find the EHR that is best for your hospital.  Not the one most likely to earn ARRA money.  Not the one which will pass today’s Meaningful Use test.  Define your requirements.  What requirements?  The ones you believe will most closely align with how the healthcare industry will look in 2015 and beyond.  Meaningful Use will change.  Reform will change.  Funds will change.  Reform will change again.  Will your EHR be able to change?

The ONC’s recent Meaningful Use proclamation required 556 pages.  If you occupy the C-suite of your hospital, I hope you don’t let those pages define your selection of an EHR.  Some would argue that with so many pages that there must be a pony in there somewhere.  From what I read, I’m in no hurry to rush out and buy a saddle.

How measuring Brittan can improve your EHR success

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So, last night I am watching NOVA.  The episode discussed fractal geometry and aired the same time as the Viking Bears game.  Admittedly, not a typical Y chromosome choice, but interesting none-the-less.

A fractal is a fragmented geometric shape that can be split into parts, each of which is a reduced-size copy of the whole.  Simple enough.  Common examples of fractals include the branching of trees, lightning, the branching of blood vessels, and snowflakes.  In the seventies the mathematician Benoît Mandelbrot discovered that fractals could be described mathematically.

It turns out that a shoreline is another example of a fractal.  For example, let’s say you wanted to determine the length of the coast of Brittan by measuring it instead of just using Google.  The coastline paradox says the measured length of the coastline depends on the scale of measurement.  The smaller the scale of measurement, the longer the measurement becomes.  Thus, you would get a longer measurement if you measured the coastline with a ruler than with a yardstick.  This paradox can be extrapolated to show that the measured length increases without limit as the unit of measures tends towards zero.  In the first picture, using a 200 km ruler, the coastline measures 2,400 km.

In this photo, using a 50 km ruler, the coastline measures 3,200 km.

I’m not sure why this idea needed to be discovered, it seems a little obvious—more information yields more informed results.

A few years ago I was hired by a firm to report to their board on their vendor selection process.  The firm was about to issue a two-page RFP to two vendors.  I convinced the firm to redo the process.  They ultimately issued an RFP of more than a thousand requirements and selected a vendor who was not on their original list.

Again it seems obvious, but being obvious doesn’t always result in smart behavior.  If you’re getting ready to spend seven to nine figures on and EHR, wouldn’t you like some degree of confidence that you selected the best one for your hospital?

EHR: Is your scope wrong? I bet it is.

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The hand-written note, scrawled in the best penmanship of my nine-year-old daughter, lay next to the plate of sugar cookies and the warm glass of milk.  It was eleven PM.  Three kids lay in their sleeping bags, asleep on the floor of the play room—cameras ready to capture images of the annual intruder.

Illuminated by the glimmering lights from the tree, I scanned her note.  Two pages.  Itemized.  Fifty-three lines, fifty-three items.  Requests.  The letter begins, “Dear Santa.  I wrote this list today.  I know you already got my letter.  These are other things you could give me.  Please leave them under the tree with the rest of my presents.”

There are a number of ways to view her letter.  It certainly is cute—it’s probably cuter if you’re not her parents.  You know what occurred to me at 11 PM as I stood there in my slippers eating the cookies and drinking the warm milk to reinforce the message to my children that Santa exists?  Two words.  Scope Change.  Plain and simple.

Weeks of thoughtful planning, buying, and wrapping possibly shattered by the scratchings of a number 2 pencil.

Make no mistake; this will happen to you on your EHR project.  Scope change.  Where will it come from?  Users, vendors, the CFO, reform.  Most projects fear change.  Change is feared because the project team never quite got their arms around the original scope.  Most change means more dollars and more time.

Scope change can be healthy.  Why?  I bet most EHR projects are under-scoped.  Did you read that correctly?  Yes.  I bet if an independent party assessed your scope document and work-plan you will find you are under scope in these three areas:

  • Change management
  • Work flow improvement
  • Training

If that’s the case, you will have spent tens of millions of dollars building something slightly more functional than a rather intricate Xerox machine.

Does ego get in the way of making change an imperative?

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My friends who have nicknamed me Dr. Knowledge or the Voice of Reason have seen me on those rare moments when the synapses were firing on all cylinders. There are others who have seen me in my less than knowledgeable moments.

For instance. There was the time I took my three young children to the movies. Upon returning home we heard the calming sound of water flowing; only it wasn’t calming since our home was not built with a stream running through it. After looking in the basement and seeing water streaming through the ceiling, I called our builder’s hot-line. I was furious at them and so told the handyman as he looked at the exposed rafters.

Undaunted, and convinced that the pipes were fine, he proceeded to the first floor to source the leak. I saw water coming through the wall and ceiling of the conservatory and gave him another piece of my mind—something my mother had always cautioned against so as to ensure I still had some left in case I needed it. We headed upstairs, through a bedroom, into my son’s bathroom. By this time we were wading. The sink faucet was in the on position, the drain was in the closed position, and I was in no position to blame the builder.

I learned that my son had been doing a ‘speriment with the soap. He told me it was my fault he didn’t turn off the faucet before we left because I told him, “come down stairs right now.” He no longer does ‘speriments in the sink and most of the waviness in the wallboard has subsided.

I hate being wrong, especially in front of an audience. Once I have an opinion about something, the planet has to shift on its axis before I’m likely to reconsider. I’ve found that to be true with building strategy to support a business that is undergoing radical change, especially when people are asked to consider not doing something, or are asked to consider doing something differently. There’s way too much, “That’s the way we’ve always done it,” and, “That’s the way corporate told us to do it.” What in your strategy would benefit if someone considered doing something differently?