Finding the Gaps: A Strategic Approach to Supporting Successful Meaningful Use Stage 2 Attestation

As hospitals move further along in their efforts to attest for meaningful use stage 2, they are finding the new stage is more complicated than the previous one. Unlike MU stage 1, stage 2 requires hospitals to go beyond merely implementing an electronic health record and submitting reports. Instead, it focuses on getting hospitals to demonstrate meaningful information exchange between providers and patients, the goals of which are to enhance communication, increase patient and family engagement and ultimately improve patient care.

One particular aspect of MU stage 2 that is challenging hospitals relates to viewing, downloading and transmitting health information. To consistently meet the intentions of stage 2 in this area, hospitals must offer a patient portal — a Web-based access point for patients to interact and communicate with a hospital, health system or other entity. While the concept of a portal is fairly straightforward, the nuances of how this technology actually facilitates meaningful information exchange are more complex than most hospitals realize. That said, the idea that a hospital or health system can take any patient portal, install it and be automatically ready to attest for MU stage 2 is not very realistic. A more realistic scenario is one in which each system will need to review how they share health information and create a plan to select the most comprehensive and effective solution.

Assessing readiness
To truly appreciate how they are going to comply with MU stage 2, including the requirements related to a patient portal, hospitals must take a step back and conduct a thorough gap analysis. This is a detailed comparison between MU stage 2 criteria and current technological capabilities that will highlight the gaps hospitals must fill before beginning attestation. Such an analysis can also serve as the foundation for an MU stage 2 strategic plan, allowing a hospital to select appropriate technology and implement strong processes that support compliance. Without this type of analysis, hospitals run the risk of wandering aimlessly toward the stage 2 deadline and missing opportunities to implement targeted tools that fully meet hospital needs.

Conducting a gap analysis does not have to be difficult, and the following five strategies can assist hospitals with the effort:

1. Create the right team. Hospitals and health systems should involve multiple perspectives in conducting the gap analysis to ensure they gain a complete picture of current capabilities and expected needs. Information technology staff members are essential for a gap analysis team because they are most aware of what existing systems can do. However, clinical leadership is also essential, because clinicians will be the ones actually using the technology in a meaningful way to improve patient care. Administrative leaders should also be involved because they are in the best position to allocate sufficient resources and remove any roadblocks to the work.

2. Delineate the requirements. Once a team is in place, the group should spend time walking through the different MU stage 2 requirements and making a list of which ones the hospital plans to pursue. As a reminder, to receive financial incentives, eligible providers must report on 20 objectives — 17 core objectives and three menu objectives. Some objectives are extensions of what hospitals did in MU stage 1, while others are new requirements. For each applicable objective, the team should make a list of the criteria involved and the technological characteristics needed to meet the criteria.  

3. Assess current technology. At this step, the team must take a hard look at the hospital's existing technology and see whether it has the necessary characteristics required for attestation. It is important to dive deep into a comprehensive review at this stage, as making assumptions about what a certain technology can do or glossing over potential shortcomings will only cause more problems down the line. The goal of this step should be to gain a thorough and realistic understanding of current technology strengths and weaknesses.

4. Tease out gaps. As the team begins to compare what the hospital requires and what the technology can do, definite gaps will emerge. For example, a large, multi-hospital health system may want to have a portal that seamlessly integrates with several different EHRs, and it may discover its existing technology is not capable of doing that. Similarly, another hospital may be looking for technology with certain certifications and discover its current system does not have those. Making a checklist of hospital "must-haves" is a helpful exercise because this can lay the groundwork for interactive conversations with existing vendors on what a hospital will need and whether the vendor can meet those needs. Most hospitals will find their technology will require an upgrade, but even then, they should be careful not to assume updated technology will fully meet all the hospital's expectations. In some cases, vendors won't be able to deliver the necessary functionality, and the hospital may have to seek solutions elsewhere.

5. Look for strong partners. Ideally, a hospital's current technology vendors will be able to completely support stage 2 requirements. However, if a hospital determines it needs to seek a third party vendor, it should have a plan in place on how to select the right one, and creating a list of pointed questions will help with the selection process. In addition to seeking answers about hospital-specific expectations, it is important to ask whether a potential vendor is certified, and, if not, if they plan to get certified. This will demonstrate how committed the vendor is to delivering MU stage 2-ready products and show the vendor is truly capable of meeting the various requirements. Hospitals should also request to watch a demonstration of any potential products to physically see how they will integrate with existing EHR technology.

While attesting for stage 2 is going to be a demanding journey, hospitals and health systems can smooth the process if they take the time on the front end to conduct a systematic gap analysis, identifying disparities between current technology capabilities and the stage 2 requirements. By using this information as a starting point for conversation with both current and potential vendors, hospitals and health systems can ensure they are committing to technology partners that are able to fully support compliance work and help the hospital achieve meaningful use and beyond. Thinking from this longer-term viewpoint can help ensure the hospital is positioned for success as healthcare regulations and policies evolve.

Gary Hamilton is president and founder of InteliChart, a leading provider of connected health solutions that facilitate patient engagement, health information exchange, population health and the coordination of patient care.

More Articles on Meaningful Use:
5 Things to Know About the MU Extension  
CMS Proposes Extending MU2 Through 2016  
16 Statistics on Providers Receiving MU Payments in October 

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