What if the question is “What SHOULD I do” rather than “What COULD I do?”
Since it’s signing in February of 2009, the HITECH Act has made providers and hospitals deal with the question of “What Could I Do” with respect to demonstrating Meaningful Use (MU). That is, what systems do we have in place, what systems do we need to acquire/upgrade in preparation, etc. to demonstrate MU? The clock started ticking when Stage 1 objectives were published in the Federal Register, and the clock has been ticking ever since.
But what if you are a provider or hospital living in the rarefied air of asking the question of “What Should I Do?” That is, if you have the infrastructure, systems AND adoption in place and have already collected the necessary 90-days worth of data to successfully attest – SHOULD you go ahead and do so by November 30th (the deadline to attest in Federal Fiscal Year 2011)?
Today’s post by Joseph Conn of Modern Healthcare entitled EHR Early Birds May or May Not Get the Worm essentially points out this question facing certain hospitals as we near the end of FFY 2011. Conn references The Advisory Board Company’s Protima Advani who recommended delaying Stage 1 attestation until FFY 2012. Advani and Conn nicely described the potential disadvantages of early adoption created by the ONC’s Stage 2 Final Rule timeline – currently anticipated in the summer of 2012 – so I won’t repeat them here.
I agree with Advani, who holds to her original recommendation to sit and wait. Although the HIT Policy Committee has recommended that ONC delay Stage 2 for early attesters (those submitting in FFY 2011), ONC has yet to officially accept this recommendation and change the timeline.
Bottom line, if you are still planning, selecting or implementing HIT, then by all means don’t slow down as you likely still have lots to do. If, however, you have collected the 90-days of MU data and are just waiting to submit, you might as well wait until ONC officially delays Stage 2 or until Nov 30th to make your decision, whichever comes first.