Leading a meaningful use (MU) compliance initiative to its successful conclusion requires a dedicated focus on three foundational work streams: incentive program compliance, organization performance, and electronic health record (EHR) enhancement. Each may be managed separately, but the overall initiative requires comprehensive coordination and oversight to ensure current compliance and to establish capabilities for future health reform initiatives. True MU success is the ability to manage the challenges of universal health reform. It is in this capacity that strong organizational governance can make a critical difference in an organization’s ability to achieve MU success.
Incentive program compliance
Monitoring, tracking, and managing compliance with the various and ever-changing requirements requires a concentrated focus and effort. Stage 1 program rules and regulations outline the administrative component of the incentive program. While CMS’s 2010 final rulemaking is the program’s foundation, rule updates must be monitored closely. These updates require a structure and process to respond quickly and course correct when necessary. Furthermore, each state is allowed Medicaid incentive program administration flexibility resulting in the need to closely monitor state rule differences.
CMS’s recent expansion of the Medicare RAC program to encompass audits for MU compliance further emphasizes the need to remain diligent in this area. Contracted auditing companies have already begun conducting audits under the federal waste, fraud, and abuse program. States are establishing similar Medicaid programs. Critical organization activities to manage include:
• Determining/implementing appropriate activity oversight to ensure regulatory compliance with the standards;
• Working with leadership to appoint/support internal representatives for regulatory compliance oversight and adherence to standards;
• Supporting functional areas with appropriate quality and regulatory resources;
• Monitoring the regulatory environment to ensure continued compliance;
• Maintaining working relationships with external regulatory bodies and community partners;
• Establishing a Health Reform reporting structure to the enterprise quality/performance improvement function, compliance committee, senior management, and board of directors (or similar governance bodies);
• Coordinating /directing activities for internal compliance audits;
• Managing preparation and responses to external compliance audits;
• Establishing organization expertise for all aspects of the HITECH Act to facilitate knowledge transfer to internal SMEs;
• Providing support for key strategic initiatives impacted by MU implementation.
Organizational performance
The foundation of the MU objectives is the use of technology, primarily EHRs, to improve care quality and reduce costs. The need to enhance processes, evidence-based care practices, and organization capabilities (e.g., workforce management, patient throughput, measurement) are critical to achieving MU. High-performing organizations with flexible, efficient improvement methodologies consistently exceed minimum Stage 1 MU requirements as a sustainability strategy. As future MU stages become more complex and pay-for-performance becomes the established reimbursement model, organizational performance will be critical to sustaining and enhancing financial viability. Organizational performance activities orchestrated by the quality/improvement function might include:
• Promoting a culture of performance to sustain compliance;
• Directing the development, implementation, maintenance, and improvement of clinical, financial, and service systems to ensure compliance;
• Identifying potential areas of compliance vulnerability and risk based on analytics;
• Providing process owner guidance to develop/implement corrective plans;
• Working with education leaders to ensure effective compliance training programs that reinforce compliance or implement new regulatory requirements;
• Establishing champions/change managers for all MU-related projects across the facility;
• Facilitating workflow improvements and supporting implementation and full system adoption of certified EHR technology;
• Align MU improvement initiatives with internal current and future quality initiatives.
EHR enhancement
Comprehensive and widespread use of certified EHRs is critical to the achievement and sustainability of MU Stages 1, 2, and 3. However, having a certified EHR system and software that offer the requisite features and functions to enable MU achievement does not alone guarantee that an organization will achieve MU requirements. To ensure success, process redesign and operational improvements in conjunction with the EHR design and build phase as well as subsequent MU testing over and above standard EHR implementation approaches are required. Data capture and management are fundamental to accurate measurement of performance and mandated reporting as well as mandates for data exchange. Moreover, accurate coding coincides with ICD-10 implementation. As part of planning and implementation, changes in data capture forms, clinical processes, and reports should coordinate MU and ICD-10 redesign and training activities.
Expert oversight of a knowledgeable MU IT project manager will support enterprise initiatives in progress to demonstrate MU by:
• Working with the EHR vendor’s IT team during analysis, design and build, implementation, tracking, and reporting to monitor progress of achievements against MU targets and goals;
• Working with MU build and reporting teams to develop program-wide reporting solutions;
• Working with the performance improvement team to facilitate system-wide work flow improvements and implementation and full adoption of certified EHR technology;
• Anticipating and planning for challenges related to the ICD-9 /ICD-10 conversion, HIPAA 5010, and new federal IT security regulations;
• Working with clinical and business owners to establish MU analytics that support monitoring performance for early course correction.
The IT MU project manager manages and facilitates the documentation of changes to EHR software and processes necessary to meet requirements for MU while coordinating this effort with the MU governance bodies.
Marla Roberts, DrPH, RN, is a senior delivery manager for CTG Health Solutions.
