EHR Incentive Payment Dates

Let me be the first to announce the delay of the deadlines to qualify for EHR incentives.  Actually, there is no official announcement or even open discussion – yet.  But, I believe it is inevitable.  I believe this for two reasons:

  1. In my experience, government mandates delays are the rule
  2. This EHR deadlines are completely unreasonable

Remember APCs, the revised Medicare funding mechanism for outpatient procedures?  Remember the big push for the deadline followed by a last minute delay.  In fact can anyone think of any significant government deadline that did not change?  My favorite example is the recent cutover to digital television.  We gave American couch potatoes years to go buy a converter box (or get cable service).  Millions were spent on advertising, web sites and coupon giveaways.  If there was ever a deadline that should have stuck it was that one.  Still, it was delayed from February to June.

We are giving hospitals and medical groups less time to implement EHRs than we gave television stations to change their broadcast capabilities.  The EHR is at least two magnitudes of order more complex.  Integrated Delivery Networks, such as mine, have essentially one year to implement an EHR for doctors and another year to implement the hospital EHR.  Note: I am assuming the rest of 2009 will be used for planning and waiting for the definition of “meaningful use.”  I have been working on this my entire professional career.  It is not a two year effort.

So, a delay is inevitable.  That is not to say that CIOs and other healthcare executives should plan on a delay.  I don’t think that would be prudent.

The other pressure for us is that healthcare, like corporate America, is focused on belt-tightening.  I have a backlog of really good ideas to reduce the cost of care to our patients.  Our new focus on Electronic Health Records will reduce our ability to implement these ideas.  Then again, I think that was the purpose of the incentives.  Get healthcare organizations to make EHRs a top priority to get them implemented once-and-for-all.

9 thoughts on “EHR Incentive Payment Dates

  1. I agree with your assessment. Having read the “deadline” has been moved up to 2010, ooops, that is it sorta is moved up depending on the now new “meetings to discuss”. We’ve all been here over and over again with the government deadlines then inevitable delays. I too have been waiting to hear how “meaningful use” is defined. I too agree that waiting would not be prudent. I also agree this is a distraction. My advise: Focus on your practice’s PM/EMR package but keep checking your back.

    As a side thought: Hmmmm….how is it that our President has yet to utter the words “Insurance Industry” when talking about re-vamping America?

  2. Hmmm … disagreeing with Will is a good way to go broke.

    Having said that … will Congress tolerate a delay of distributing “stimulus funds”? The political need to get this money out, even to hospitals will drive Congress to force DHHS to comply with the law. The Secretary has the abillity to accept standards defined by the ONCHIT predecessor organization if new ones are not forthcoming. Further, the Secretary has the charter to continually raise the bar over the course of the next few years.

    Rather than delay funding as a consequence of delayed standards, I believe it to be more likely that a year 1 set of simple criteria will be established, and tightened up over the next couple years. Sound reasonable?

    Our strategies are the same, regardless of which approach. Will is spot on with that. We must run as fast as we can to what we believe to be reasonable standards, keeping a constant eye on government pronouncements and our internal initiatives, adjusting as soon as we know something new.

  3. Let me provide some direct perspective as we are given deadlines many times in the DoD Healthcare industry that we MUST meet.

    Inevitably one of three things (out of our control) will happen to cause the “deadline” to either be pushed back or not met.

    1) There is a lack of clear guidance on implementation standards or metrics which they will be measuring against.

    2) Those standards/metrics are not provided within a time frame that allows organizations to plan and meet the deadlines.

    3) The funding to meet those standards is not provided early enough to plan, purchase, train, and implement to meet those deadlines.

    In the military our EMR was delayed… not days or months, but years before finally being implemented. AHLTA (the DoD’s EMR) was implemented fully in 2004 and each time there is an version change there is also an assigned estimated completion date and roll out plan to all of the medical treatment facilities. These updates are always delayed (current version > 1 year) due to one of the above 3 reasons, but additionally can also be delayed even further due to local issues or things that we can control, such as; unforeseen technical issues, lack of training for the version update, or everyone’s favorite… provider push back.

    I personally believe that the LIMFACs presented, both inside and outside the organization, will be too much to overcome by the deadline. Policy makers must realize that implementing an EMR is CULTURE change much more than TECHNOLOGICAL change, but that is a whole other can of worms…

  4. I recently did a little math. If 30% of MD’s get stimulus finds (at $44k), and 50% of hospitals (average $2.5 million), that will exhaust the $17 billion available.

    That implies that the legislation did not envision everyone getting stimulus funding. I wonder if that also implies deadlines will not slip so much …

    This seems to be swimming against the current of opinion here … but I think data supports the point.

    • Jay, this is government accounting at work. The $17B is the budget impact. It not only include the incentives to be paid, but also offsetting Medicare and Medicaid savings from these EHR investments. I have read that the government actually believes that their will be $29B in EHR incentive payments.

      • Yes, I’ve seen the $29b number as well … but even under that scenario, there is not enough to go around … if you figure $3m per hospital (a low average, I think), then the $29b covers about 60% of the hospitals and MD’s. Under the $17b scenario the numbers are well under half. Play with the numbers … I can post or send an interesting spreadsheet.

        What matters is … in this easter egg hunt, not all the kids come home with eggs. The CFO’s are all counting on the money. Who is in the crosshairs, if it does not come?

  5. Pingback: Delays in EHR Stimulus Time Frame | EMR (EHR) and HIPAA

  6. Jay, this is government accounting at work.

    That implies that the legislation did not envision everyone getting stimulus funding. I wonder if that also implies deadlines will not slip so much …push back.

    I personally believe that the LIMFACs presented, both inside and outside the organization, will be too much to overcome by the deadline. Policy makers must realize that implementing an EMR is CULTURE change much more than TECHNOLOGICAL change, but that is a whole other can of worms…

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