Ambulatory Surgery Centers will be required to implement Electronic Health Record systems (EHR) within the next few years. Participation in Medicare/Medicaid will depend on it. This article will explore the definition of EHR, what the prime driving forces are behind mandated EHR systems, and how we can heed the warning and plan ahead for successful implementation of EHR systems in our centers.
EHR = EMR + HIS + CIS + CPR (Electronic Health Record = Electronic Medical Record + Health Information System+ Clinical Information System+ Computerized Patient Record). All the acronyms that have been used in the last four decades to define the electronic storage of patient information have now been rolled into one. The term EHR used to mean an office-based patient documentation system. The Federal government has usurped the EHR label and has given it back to the healthcare industry as the final acronym for describing any of these electronic patient data systems.
Quoting the Centers for Medicare and Medicaid Services: An Electronic Health Record (EHR) is an electronic version of a patient(')s medical history, that is maintained by the provider over time, and may include all of the key administrative clinical data relevant to that person's care under a particular provider, including demographics, progress notes, problems, medications, vital signs, past medical history, immunizations, laboratory data and radiology reports The EHR automates access to information and has the potential to streamline the clinician's workflow. The EHR also has the ability to support other care-related activities directly or indirectly through various interfaces, including evidence-based decision support, quality management, and outcomes reporting.
Simplified definition: Capture and/or storage of patient specific medical information in a digital format, which is queriable and transferable to and from other computer systems.
On Feb. 17, 2009, President Obama signed into legislation the American Recovery and Reinvestment Act of 2009 (ARRA), aka the "Stimulus Bill". Lesser known is that, embedded in ARRA, the Health Information Technology for Economic and Clinical Health Act (HITECH) was created. ARRA also made permanent the Office of the National Coordinator for Healthcare Information Technology (ONC) to set policy and standards, as well as direct, oversee, and measure success of the implementation of EHRs.
ONC established the first set of policies and standards for these systems later in 2009, defining mandated Meaningful Use criteria and Certified EHR requirements (HITECH phrases). EHRs must meet strict conditions for data documentation, clinical decision support, data management, and sharing of data. The legislation allows for Meaningful Use criteria to be expanded by ONC every two years during the initial six year roll-out, making it increasingly challenging for EHR systems to be compliant. The second set of requirements is currently in the final stages of development.
The HITECH Act was pushed into place by CMS without forewarning. CMS maintains a vision for a national health record for patients. The goal is to be able to create lifetime individual medical records that are accessible by any provider, anywhere. Our military health system has a similar goal and is on the way to achieving it. CMS expects utilization and quality reports to eventually be submitted from provider EHR systems directly to CMS. CMS is also expecting EHRs to help decrease healthcare costs. Because CMS reimburses big dollars to these entities, acute care hospitals and physicians' offices are the targets in the first round of mandates for nationwide providers to implement fully integrated EHR systems. The second round will no doubt target ambulatory surgery centers.
EHRs are not an unfunded mandate. There is some ARRA money available to a facility once a properly implemented system is in use. The HITECH act provides for different levels of compensation based on the percentage of Medicare patients served, the facility designation, and the timeliness of implementation. Providers can instead opt to be compensated based on their Medicaid population through funds given to each state. Meeting Certified EHR and Meaningful Use requirements are a prerequisite to any funding. Those affected by the current mandate are required to implement EHR systems by this year (2011) in order to receive full credit. Compensation decreases with delays in EHR installation. If these facilities do not implement EHRs they not only lose out on payment for installation of EHRs, they will also be penalized through decreased Medicare reimbursement for patient care. These penalties are scheduled to increase each year until CMS certification is jeopardized. Acute care hospitals and physician offices must have EHR systems in place, meeting Meaningful Use criteria, by the end of 2014 and 2015 respectively to avoid CMS penalties.
The bad news is ASCs will be federally mandated to implement EHRs. The good news is EHRs can bring benefits to our business processes, our patients, and our owners. EHRs, when properly implemented, are actually strategic investments, helping facilities gain efficiencies and improve the quality of services provided. It is important to realize that even a small EHR project takes 1-2 years to implement successfully. Implementing an effective EHR system before the mandate arrives will bring maximum benefit to a center. Leadership needs to start that process now. EHR projects are costly in money and other resources. Due diligence in planning is key to effective stewardship during project execution.
Below is a brief description of a recipe for success with an EHR project:
• Define the project goals
• Calculate the budget and return on investment based on those goals
• Identify the stakeholders and project champions.
• Create a selection committee with pre-determined structure and purpose
• Select the EHR system
Once the EHR system is selected, disband the selection committee and form an implementation team, again with a pre-defined structure and purpose. This group will take the project through EHR go-live, and some team members will continue in EHR supporting roles after the system is in use. Thoughtfully detailed project organization will smooth the transition from conception through go-live.
Future articles will discuss in more depth the ROI and the steps required for successful EHR projects. For now, remember ASCs are better positioned to address implementation of EHR systems than most acute care hospitals and physician practices were when the HITECH act became law. Let's take advantage of this opportunity to learn from others' experience by planning ahead and acting sooner. (A helpful page with many links to resources regarding EHRs is on the Health Information Systems Society's website at www.himss.org/EconomicStimulus.)