KPMG Webinar: Top 10 Stage 1 compliance challenges

Members of the KPMG Healthcare & Pharmaceutical Institute, based in Atlanta, discussed the top 10 compliance challenges for meaningful use (MU) Stage 1 during a March 21 webinar.

“Most of our clients are working on complying with Stage 1,” said Michael Beaty, partner at KPMG, including upgrading, implementing a certified EHR and capturing information in a codified way. “Stage 2 is really where the rubber hits the road in terms of using the technology and the information passing through that technology.” KPMG speakers discussed the following top compliance challenges:

1. Understanding MU requirements.  Intepreting the requirements has been a challenge because there is so much information and the requirements keep evolving, Beaty said.
2. Lack of a fully dedicated MU project team. “Multiple disciplines need to be involved in the governance of MU because they all have a stakehold,” he said. Stakeholders include IT, clinical, health information management (HIM), decision support, business intelligence and finance. “Teams that have most key players at the table seem to be figuring out a doable plan much more quickly. MU is not just an HIM or IT project. It requires comprehensive sets of ideas and skills.”
3. Workflow redesign efforts related to electronic capture of clinical quality measure data elements in the certified system. Healthcare organizations need to redesign their workflow to address clinical quality measures, Beaty said. “Many have captured clinical quality data over the years manually,” but in moving to a certified EHR to report those clinical quality measures, understanding the requirements has been challenging. The level of detail requires changes in workflow and training. “There’s a great deal of risk in the process with respect to data integrity.” The challenges associated with moving from manual to an electronic system will only continue as meanigful use requirements progress.
4. Capturing and incorporating patient information into CCR/CCD documents. This is the first of the challenges that speaks directly to the granularity of the requirements, said Bob Palmeri, director. He pointed out that all of the authoritative content has to be reviewed and understood. “You can’t take any shortcuts.”
5. Ancillary healthcare information systems may require interface or workflow redesign. Palmeri said KPMG often is asked whether users of certified modules that comprise a complete EHR must have a certified interface. A simple point-to-point interface need not be certified, he said, but an interface that applies characteristics of its own to data would have to be certified.
6. Training and change management efforts. Meaningful use is a large, transformative initiative, said Palmeri, that affects all aspects of an organization. A focus on IT has always existed, including testing and upgrades, but “it became very obvious that teams had to expand to include finance, clinical, legal and pharmacy. It wasn’t until all of those came to bear that we were able to ramp up earlier IT efforts into meaningful use implementation. You have to think beyond meaningful use as a pure IT effort.”
7. Developing a documentation retention process and protocols. This became a hot topic because the Centers for Medicare & Medicaid Services (CMS) has issued certain directives about auditing, Palmeri said. CMS is working on an auditing program that will first focus on fraud and abuse and then expand beyond that. Guidance provided to date has been very limited, but Palmeri recommended that hospitals save all documentation to provide evidence of measure and incentive calculations. “It’s a good idea when you start your attestation process to have a good, broad documentation process established and monitored.”
8. Relying heavily on vendors to achieve meanginful use compliance. Although meaningful use requires a certified platform, that really only gets a hospital 20 percent of the way, said Joe Kuehn, partner. “The remaining 80 percent depends on understanding the full meaning of the rules, granularity and changing workflow. It’s really understanding and fully appreciating that meaningful use is more than an IT project. You truly need all disciplines to work together.”
9. Not considering proposed Stage 2 and 3 objectives and other regulatory requirements. Receiving incentive dollars is a significant goals in implementing an EHR and achieving meaningful use but “you want to make sure the process you’re implementing is sustainable for the long haul,” Kuehn said. “Avoid shortcuts to get across the finish line.” This is a particular problem with clinical quality measures, he said.
10. Data governance and controls may not be adequate to ensure integrity of MU reporting information. With the ongoing shift to transparent data available to the general public, Kuehn said the notion of consumerism is only going to accelerate. Patients will be shopping for their healthcare based on quality and outcomes. With the move from fee-for-service reimbursement to funding based on outcomes and quality, “data integrity behind that information is going to be paramount. Take control of that information to support your own destiny.”

The top challenges reflect the complexity of meaningful use, said Brad Benton, national account leader. That complexity will only grow with progressive stages. “Near term economic achievements are critical but the long-term sustainability of this program is equally critical.”

Another important consideration is the human capital questions, Benton said. “The talent necessary to interpret this data and turn them into usable information is going to be scarce to say the least.”

Although the term transformation is used a lot, he said, MU is a transformative program and probably not the only one most hospitals currently face. “It’s important not to view it as a narrow initiative but to think about it in the context of what transformation really means in healthcare today. I do not believe there is an industry facing a more provocative transformation theme than healthcare. That will result in changes to how all institutions in the healthcare ecosystem do business.”