HIPAA Compliance Plan

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The State of Meaningful Use: the HITECH Act Interim Final Rules

One thing that can be said for certain: Meaningful Use remains a wicked problem, despite the fact that HHS has recently issued its Interim Final Rules in an attempt to clarify. Well, there is also the HITECH Act mandate that requires them to do so, but let’s not get hung up on the details. Just how wicked a problem is it? On January 13th, 2010 Dr. John Halamka posted the presentation below on his blog. It describes the requirements of the Interim Final Rule and Notice of Proposed Rulemaking.

Now, those of you who know Dr. Halamka understand that he is one of the most knowledgeable HIT personalities in the nation. He has a special gift for taking a complex topic and breaking it down into understandable "chunks." The effort below does not disappoint. There are lots of good healthcare blogs; Dr. Halamka's in one of the best.

That said, we here at HSG "live and breathe" HITECH, and are constantly surprised by the scope of what it encompasses. Reviewing Dr. Halamka's presentation brought that point home once again. We encourage our readers to read (and study) the presentation, but do not be surprised if it raises as many questions as it answers, that is simply the nature of the beast.

Dr. Halamka: The Standards Rule and the NPRM for Meaningful Use

This post contains links to many of the standards referenced in the presentation. The adoption of these standards as mandated by HITECH, and as proposed in the HHS Interim Final Rules, gives them the force of law. However, implementing the standards, as daunting as that may seem, is only a subset of what is required to demonstrate Meaningful Use, even in Stage 1. The last slide above contains the money quote:

“There are about 25 required projects to achieve meaningful use - a major organizational commitment.”

The phrase "a major organizational commitment" is clearly an understatement. While Meaningful Use will continue to evolve, and in the short run may even be scaled back (a little), given some of the feedback that HHS is receiving, it will nonetheless remain daunting. At a minimum, we strongly urge covered entities and business associates to start climbing the meaningful use curve, even if there are no immediate plans to adopt an EHR in the short run. The risk is not simply whether government will impose meaningful use requirements that you can't meet, but rather that the market fundamentally shifts from market pressures, in a way that destroys your competitive advantage.

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