For example, hospitals must meet all of the 35 stated quality measures. Failure to implement all 35, or a poor interpretation of any one of the measures, will mean the organization gets nothing for their efforts.

"The stimulus bill is pretty prescriptive," May continued. "Our concern is that they basically said you have to be a meaningful user of the ultimate EHR, not just having implemented effective, quality improving and safety improving systems today. It may not be complete, but it doesn't matter. It doesn't matter that you've done a good system that helped you, if it's not the whole enchilada, that's not enough. Regulation is typically the minimum standard. Unfortunately, they've gone in the opposite direction here and they've set a ceiling that's just too high."


According to CMS, Stage 2 "would expand upon the Stage 1 criteria in the areas of disease management, clinical decision support, medication management, support for patient access to their health information, transitions in care, quality measurement and research and bi-directional communication with public health agencies." Rollout of stage 2 is set for 2012. Stage 3 will focus on quality, safety and efficiency improvements.

The certification conundrum

As noted in the beginning of this piece, federal regulators have yet to release their product certification criteria for EHR systems, and everyone's feeling the pinch. In a recent blog post, Mark Leavitt, MD, Ph.D, outgoing head of the Certification Commission for Health Information Technology, writes, "Sounds to us like the soonest the accreditation package would be ready is July 2010, and of course the certifying bodies then have to apply and qualify. By which time, in our opinion, it would be impossible for a provider or hospital to begin shopping for a certified EHR and achieve Stage 1 Meaningful Use in time for the 2011 or 2012 incentives."

Healthcare Information and Management Systems Society (HIMSS) board member and CIO of Good Samaritan Hospital in Vincennes, Indiana, Chuck Christian, elucidated the host of practical implementation issues faced by IT chiefs and managers. "There are still so many unanswered questions that it makes it difficult to plan," he said. "The only thing the OMC has put out right now is the certification criteria; the process of certification has not been defined yet, but is coming. Who that certification body or bodies is going to be has not been named. CCHIT was not included anywhere in the certification criteria. That's not to say that they're not going to be one of the certifying bodies, but as of today, nobody knows who the certifying bodies are going to be, so makes it very difficult for vendors to move forward with development work in those types of things."

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