Let me state the obvious. An EHR implementation in a hospital is a time consuming and expensive effort. While the idea of switching EMR software is a palpable discussion in the ambulatory space, it is a much more difficult discussion in the hospital EMR space. I heard one hospital CIO whose hospital decided to switch EHR software say it took them 2 years to make this decision. The idea of switching EMR software is not even a discussion point for many hospital CIOs.
With this in mind, I was intrigued by today’s #HITsm chat where we talked about meaningful use stage 2. More than a few people suggested that many EHR vendors are going to fail to meet the meaningful use stage 2 requirements and be 2014 EHR certified. I’ve personally suggested that I don’t think this will be the case. EHR vendors have far too much to lose to not be certified. However, more than a few people disagree with me on this subject, so I started to consider what this would mean for an organization.
For those of you who also read EMR and HIPAA, you might remember my post earlier this year called EHR Penalties after Meaningful Use Failure. In it I discuss how damaging it would be for a hospital that makes a sincere commitment to EHR and meaningful use to then fails to get the EHR incentive money because they fall short of meaningful use or fail an MU audit.
A similar situation could occur if a hospital’s EHR vendor isn’t able to meet the meaningful use stage 2 EHR certification requirements. What does the hospital do in this case? Will they miss out on the EHR incentive money and also suffer the EHR penalties because their EHR vendor wasn’t ready for meaningful use stage 2?
Like I said, I’ll still be surprised (especially in the hospital EHR space) if all the hospital EHR vendors don’t become 2014 EHR certified. However, if they don’t, a lot of hospitals will be put in a precarious position.
My guess is that if this happens, ONC will make an exception in the penalties for not being a meaningful user. I can’t imagine them penalizing a hospital who’s trying to be a meaningful user of an EHR and can’t because of their EHR vendor’s inability to perform. Although this would start a slippery slope of exceptions.
Either way, I want to dig into this topic more. How many EHR vendors won’t have their EHR certified for meaningful use stage 2? What are the timelines for them to complete this certification and then for hospitals to implement everything for MU stage 2?