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Over the past few months, I’ve been talking with Hospital CIO’s about the HITECH Act or “Health Information Technology for Economic and Clinical Health”. I wanted to hear it from the horse’s mouth rather than from all the politicians, firms, agencies and people who have been hyping it to no end. In my discussions, a clear pattern has begun to take shape. Hospital CIO’s fall into 3 different camps when it comes to their HITECH efforts and concerns.
Camp A (Not Concerned)
The Hospital CIO’s in this camp have read a few articles on HITECH but have not had any meetings or discussions internally on the topic. They feel that things need to shake out before they take any serious action. With the share number of projects already on their plate, HITECH is not something they plan to loose any sleep over. They know of the $44k incentive for their physicians, and how they will need to demonstrate “meaningful use” by 2011, but they are not worried about it. They understand they need to become better informed and educated on HITECH, and they intend to do so, but in their opinion things are still very gray and their willing to wait until everything crystalizes.
The reason for their confidence is that they feel good about their existing IT infrastructure and their current HIS systems, both on the inpatient and ambulatory side. They have no plans of switching HIS vendors and are confident they will be able to close any gaps identified once a thorough analysis is performed. If an ambulatory solution will be needed, they will select one of the major vendors, after some proper due diligence, and then either manage the project in-house or outsource it. In fact, they may even opt to have the system “hosted”.
Hospital CIO’s in this camp are also confident that they have enough or can hire enough full-time IT staff to commit to these projects and they certainly don’t need a third-party firm to come in to provide them with a HITECH assessment. Funding will not be problem, as working capital has been promised, and will be provided by the Hospital Board, to address HITECH initiatives that are required.
Camp B (Somewhat Concerned)
These Hospital CIO’s are a bit more cautious in their treatment of HITECH. It has been a topic discussion internally and they have proactively added it as an important project in their portfolio. Work is underway to determine what they need to do with their existing HIS inpatient system (replace, upgrade or maintain). If the choice is to replace, then they are moving quickly into the vendor selection process, otherwise they simply will not have enough time to get the system implemented. Alternatively, they are studying their options to upgrade to their vendors latest version, or to try and make due with the existing version of the system.
In addition, they have a fair amount of work to do in the areas of IT infrastructure, integration, security and encryption of patient information. The existing environment may be fine for what they are doing today but it will not meet the future requirements of HITECH. These Hospital CIO’s will likely solicit a third-party firm to come in to perform a HITECH assessment and to also validate and find gaps in their thinking and plans.
The Hospital CIO may already have a central ambulatory solution in place for their physicians, but this is likely not the case, so they are also evaluating vendor offerings with the goal of making a selection soon. They must have both implementation and an integration plans to connect the ambulatory application EMR, with the hospitals internal EMR, to meet the interoperability requirements of HITECH. Some hospitals may be fortunate to be using a vendor who offers integrated solutions for both inpatient and ambulatory. However, most hospitals will need to integrate different vendor solutions together to accomplish this. The cost of the ambulatory solution will be a factor so they are reviewing a broader list of vendor offerings and negotiating options that best meet their needs and budget.
The Hospital Board is certainly well aware of the 44k in physician incentives, as well as the penalties, for not achieving compliance. Some funding is available today but additional capital will need to be raised and secured. The Board wants to know the total costs of all these initiatives, but the Hospital CIO and their team are still working through the discovery and negotiation phases, and need more time to size everything up. The Hospital CIO will soon provide them with best and worst case scenarios.
Based on the magnitude of projects and work identified, these Hospital CIO’s are going to run into resource constraints. Their direct reports, management team and IT staff all have “some” capacity but they already juggling a number of important projects. The Hospital CIO is not going to be able to hire additional staff, because of these difficult economics times, and they know they are going to need to bring in outside consulting and staff augmentation resources to achieve the goal. The challenge will be finding these quality resources once the national demand grows on an exponential basis.
Camp C (Very Concerned)
Hospital CIO’s in this third camp have reason for concern. They know they will have to replace their inpatient system or upgrade it to the latest vendor version. Their current system capabilities are insufficient, and/or the share amount of time and money it would take to make it HITECH compliant is just not practical. They also do not have a common ambulatory system for their physicians, so they know they will need to make a decision on this front as well. Add to this, the significant amount of work and investment dollars required to enhance their IT infrastructure to support these new systems, and the costs and timeframe really start to add up.
Most of these Hospital CIO’s have also had to downsize their staff this past year due to the economic times and simply do not have the internal resources to take on and execute these important initiatives. They know they will need outside help to both manage and staff augment these projects, and they are concerned about finding the right resources when they need them.
Funding for this Hospital CIO is a real problem. The capital that will be required to get the hospital from where it is today to where it needs to be is significant. The Hospital Board is concerned about the mounting costs and their ability to raise enough capital in this tight market. In fact, some are concluding that the costs just may be to great, and that they may need to sacrifice the HITECH incentives and deal with the penalties, to keep the hospital’s financial health in order. Sometimes strategy is what you don’t do.
Meanwhile, the Hospital CIO is trying hard to find the most efficient and cost effective way they can accomplish the task at hand. They are deep discussions with their inpatient system vendor to identify creative ways to upgrade, while containing costs and spread them over time. And on the ambulatory side, they are considering inexpensive ambulatory solutions, that offer just enough to meet compliance requirements. Alternatively, some of these Hospital CIO’s are looking at license free open source EMR offerings that might fill the bill such as OpenEMR and ClearHealth. They are talking and working with different infrastructure solution and technology vendors to identify ways to cost effectively improve their environment.
Finally, from a resource perspective, these Hospital CIO’a only have a small management team and staff that manage the day to day operations of the hospital. Without question they will need vendor and outside consulting firm assistance to help them on these many projects and initiatives. This will become yet another challenge for them as they diligently try to navigate through these difficult circumstances.
Hospitals and medical centers now have even more reason to be concerned about privacy and security as new rulings released last week go into effect. Healthcare CIO’s need to heighten the attention they place on the protection of sensitive patient information as it pertains to access, storage and transmission. This will need to be done in conjunction with their new focus on “meaningful use” which includes, CPOE and EMR upgrades and installations, clinical documentation, quality measures and interoperability.
On Wednesday August 19th, the Department of Health and Human Services (HHS) issued their “interim final” ruling that requires healthcare providers and health plans to alert individuals of unauthorized access to their unsecured electronic protected health information (PHI). This came just two days after a Federal Trade Commission (FTC) rule was released which outlined similar requirements for personal health record (PHR) vendors, related PHR entities and third-party service providers.
Both of these interim rulings have been mandated by the very stringent privacy and security requirements outlined in the American Recovery and Reinvestment Act of 2009 (ARRA) for Health Insurance Portability and Accountability Act of 1996 (HIPAA) covered entities and business associates and certain non-HIPAA-covered entities. Try saying that fast five times!
The HHS and FTC worked collaborated to make sure that the rules were in sync and written in such a way that they complimented one another. All entities that are covered by either of these rulings have within 60 days to notify any individuals whose information was accessed without the proper authorization. If a large breach occurred, that falls within the PHI rules, and 500 or more people involved, then those entities must alert the press and media and then either HHS or FTC, depending on which of the rulings they are subject to. If the size of the breach involved less than 500 people, those entities must record and log of the incident and then contact and submit the breach findings to either HHS or FTC at the end of the year. These “interim final” regulations will be in effective for 30 days after publication in the Federal Register on August 24th.
The HHS “interim final” regulations are available at http://www.federalregister.gov/OFRUpload/OFRData/2009-20169_PI.pdf.
The FTC “interim final” regulations are online at http://www.ftc.gov/os/2009/08/R911002hbn.pdf.
As part of the federal American Recovery and Reinvestment Act (ARRA), state and local governments have gratefully received stimulus money, which economists and lawmakers hope will breath some life into the economy. Budget officials, however, are anxious about the impending October 10th date, which is the first quarterly mandated deadline from the the U.S. Office of Management and Budget (OMB). On that date, stimulus fund recipients must upload their detailed financial spending information in a specific format to a website called FederalReporting.gov,
CIO’s around the country are concerned about the challenges of reporting for stimulus spending. Agencies will be required to upload financial spending data in the form of an Excel spreadsheet, CSV, or Extensible Markup Language (XML). These OMB requirements put the burden directly on state and local governments to process, format, prepare and transmit large amounts of financial information. Many CIO’s say that their existing computer systems simply have not been adapted to handle these requirements. They are now faced with a choice that they need to make: a) customize their computer systems and applications to try and meet the requirement or b) purchase a software solution that has been designed to track and report stimulus spending.
President Barack Obama’s administration and the OMB instituted these very stringent reporting requirements to provide transparency as well as spending accountability. This is certainly a worthy and worthwhile goal but it can be an enormous undertaken for CIO’s and their IT teams. They only have a small window of time to modify and enhance their applications to meet the requirements. The problem also becomes exponentially more complex, when you start factoring in that state and local governments have many different agencies, who are using many different systems to capture and track their financial information.
There is some good news, CIO’s have some third-party options they can consider. Microsoft Stimulus360, for example, is a solution that works with the existing Microsoft applications that most government agencies are using today including: Microsoft Office, Microsoft Dynamics ERP, Windows Server, SharePoint and Microsoft SQL Server. The only real additional cost is the product licensing fee.
Acumen Solutions’ START program, on the other hand, takes a completely different approach. The solution is built on top of Salesforce.com platform. This completely hosted option can reduce equipment and software purchase costs. START offers an advantages when the government agencies are not connected on the same area network. As a “cloud” based solution, anyone with an Internet connection and a browser, can easily access the application 24/7. Acumen Solutions’ START regularly receives updates from OMB, so that state and local governments can just focus on populating the system with their data.
Both of these solutions are viable options for CIO’s to consider. They offer all the necessary reporting and data transmission requirements for OMB, and present a compelling alternative to building, managing and maintaining their own in-house developed applications for ARRA.
I can’t tell you how many people have been telling me that Netbooks are not going to last. They explain that they are only a fad and that “real” people won’t tolerate the slow performance, lack of memory, physical storage and small keyboards. They continue by saying that the only reason their popular in the first place, is because their cheap, and in this economy that is the only thing that really matters.
Well then, don’t tell this to all the people that I’ve been seeing lately with their Netbooks in hand. In fact, I’ve been surprised at the numbers of NetBooks that have been coming out at recent seminars, conferences and events. Not to mention, all those Netbooks people are working on in the various coffee houses and cafe’s I visit here in New England. These people, are those “real” people mentioned earlier. I’m talking about business professionals, entrepreneurs, marketing people, event planners, designers and your everyday emailing / die-hard Twitter users.
When I observe these folks, I notice that they really appreciate their Netbooks small size, weight and convenience. As I work away on my Lenovo laptop, I can’t help glancing over and feeling just a bit jealous that I don’t have my own Netbook. To the contrary of what I had been told, these people all seem quite happy with their Netbook, they are being productive, and are not missing a beat.
In a lot of ways, it reminds me about the introduction of the iPhone, which I am the proud user of. My business colleagues told me that “real” people would only use a Blackberry, never these niche toys called iPhones. Well, we all know where that went now don’t we? I love my iPhone, it has changed my life. I use it constantly and it has made me much more productive. However, it’s really not suited to type in a lot of notes and documents. This is when I need to pull out my bulky laptop to do the job. I’ve often thought of how great it would be if I could just expand my iPhone, just for a little while, so I could jot down some thoughts and information. But maybe, just maybe, a Netbook might be the perfect solution for this.
The newer Netbooks are coming with more options, memory, storage and speed. They are managing to do this while keeping the costs down. This is only going to help fuel their further adoption by both consumers and businesses. Microsoft is even concerned about the growing competition from Linux as an alternative OS of choice on Netbooks – http://3.ly/JVI. We also have to remember that Netbooks are really geared towards Cloud Computing, which is becoming increasingly more popular by the month. This all adds up to staying power.
I am quite confident that Netbooks are here to stay. I know that it’s just a matter of time when I, and maybe even yourself, have one of these fine units in hand.
Healthcare CIO’s are all facing the new reality of HITECH. They are evaluating their current EMR’s and existing systems interoperability to determine what will be required to receive the HITECH incentives. They are going to be asked to demonstrate “meaningful use” (once it’s defined). CIO’s are starting their assessments and due diligence.
What is the sense of urgency? The HITECH plan calls for “meaningful use” to be defined by the end of this year. From a Healthcare perspective that means tomorrow. Hospitals and physician practices who demonstrate meaningful use will qualify for some of the billions in incentives coming from the government. The issue is that Healthcare CIO’s cannot wait for the “black and white” definition of meaningful use. They must start now if they hope to achieve the goal.
What Healthcare CIO’s do know today is that the definition of meaningful use is going to breakdown into four main categories. This includes CPOE (computerized physician order entry), clinical documentation, quality reporting and system interoperability. Healthcare CIO’s need to assess their current and planned system implementations to determine the best approach and/or combination to achieve this. They also need to factor in security, privacy and HIPAA compliance.
All this must be accomplished during these trying economic times. Plus, once the fuse is lit, resourcing these projects nationally will become a big challenge. The best thing Healthcare CIO’s can do is to be as proactive as possible and get their strategies, plans and projects in place. This is your classic “carrot or stick” approach to get the CIO’s and their C-Level peers to take action. This after all, is not only an IT initiative, but a directive for the entire organization, where every C-Level must be involved and held accountable.
The budget and execution of the HITECH initiative will transcend the entire organization. The key to accomplishing HITECH compliance will be all about measures. The measure of quality, system interoperability and patient outcomes will be the true test of compliance. This coupled with the necessary security, privacy and HIPPA compliance standards, makes it a complex initiative at all levels.
Healthcare CIO’s certainly have many challenges ahead. The best advice I can give them is to get started and be as proactive as possible. They are not alone. This will be challenge for every hospital and physician practice in the country. Some will be successful and some will not. It’s time to get started to better their odds.
RHIOs across the country have approached things very differentlly with their own standards, measures, goals and stakeholders. RHIOs can make for an interesting case study as there is a lot of good insights, perspectives and information that can be gained by their efforts. The reality, however, is that many RHIOs continue to struggle. They are knee deep in the politics of it all, have inadequate funding, and competing agenda’s from everyone involved.
What we need to do is to take a holistic view of the work RHIOs have done. We can capture best practices, constructive approaches and opportunities that can be universally shared. This due diligence could lead to us instituting a true national healthcare interoperability definition & standard for all RHIOs to adhere to. This would be the foundation of a simplified national health network exchange that all organizations and system vendors could embrace. From a technology perspective this would be very similar to the traditional EDI and ODBC models. All vendors know, understand, and enable these standards in their products.
I hate to say it but for RHIOs to be ultimately successful, they will need to collaborate & work together, and they are going to need a similar “carrot & stick” of the HITECH initiative. Obviously the incentives and penalties would be different but the same motivation and persuasion tactics would be achieved. The reality is HITECH is already going to surface these issues in a big way. True interoperability will only be achieved through system standards. I am not critical of RHIOs, you can certainly understand how they got to where they are. A tremendous amount of thought and good work has been done. Some RHIOs are much more successful than others. However, a true national standard and health network exchange is going to be required before the goal can be ulitmately be achieved.