If we don't count today or weekends, there are only 17 full work days left until the July 1, 2014 implementation deadline for the Hospice Item Set (HIS). This is getting really serious.
I have had the opportunity in the past week to take my HIS show on the road to two State hospice organizations (Massachusetts and New Jersey). The most important thing I learned from attendees at both 3 hour workshops is that there has been very little information provided by electronic medical record (EMR) vendors with regard to the HIS support that they will/will not be providing to their customers. To be more precise, the overwhelming majority of attendees at both workshops use electronic medical records and the overwhelming majority of these attendees had not heard much of anything from their EMR vendors with regard to HIS support. Is this a statistically valid sample that is indicative of how things are across the land? I don't know, but I am very afraid it might be. It does indicate to me that there is, potentially, a huge and critical problem here. Let's break this down a bit.
What if the majority of hospices in the US have an EMR vendor and are assuming/hoping/ believing that their EMR vendor is going to pretty much handle their hospice's compliance with HIS requirements? Well, here it is, 17 work days before the deadline and hospices have not heard from their EMR vendor about what the vendor will/will not be doing to support HIS compliance efforts much less received any training, demonstrations, etc, etc.
I hate to do it, but let me burst some bubbles here.
- EMR vendors are NOT obligated to support a hospice's HIS efforts. (If they want to retain customers and attract new ones they should - but they do not have to);
- HIS compliance responsibility falls on the hospice, not the EMR vendor. (It is the hospice, not the EMR vendor, that will have a 2% reduction in reimbursement from CMS if HIS data is not reported on every single patient within the deadlines!); and
- Even if you have the most supportive, magnificent, and responsive EMR vendor in the world, they still cannot manage the entire HIS process for you. There are parts of the process that can only be done by humans. Exactly how much you will need to do depends on what the EMR vendor is/is not doing.
Enough bubble bursting. What can you do right now?
- Find out TODAY what your EMR vendor is planning with regard to HIS support.
- Make sure they have "mapped" all of the HIS data elements so that you know where they are in the documentation. Your intake staff and clinicians need to know where the HIS data go, so the data will be there to be abstracted into the HIS records.
- Along with the extent of the support, you need to know when they are going to be ready, when they are going to demonstrate/let you test features of their HIS functionality and what training they are planning to provide.
I am including with this blog post a checklist of questions to ask your EMR vendor regarding HIS support. Melanie Merriman and I developed this list for The Hospice Item Set: A Step-by-Step Implementation Guide and you may use it with our permission even if you have not purchased our guide. In fact, we are practically begging you to use it if you do not know what your EMR vendor is doing regarding the HIS.
Please let us know, in the comments section, what you find out. We are very, very concerned that this may be a big problem, and this is one time we would love to be wrong. Either way, we want to know - and you need to know.
Table of Contents for The Hospice Item Set: A Step-by-Step Implementation Guide
Ordering information to download The Hospice Item Set: A Step-by-Step Implementation Guide
Free webinar on implementing the HIS - a collaboration between Weatherbee and Relias Learning. Presented/recorded on June 5, 2015 (today) at 3:00-4:30 EST. Available on demand by June 6th.
FYI -- The CMS' HIS webpage was updated yesterday with some new downloads:
- The new, updated/revised HIS Manual (you need this - go get it)
- FAQ's to their help desk for the first quarter of 2014. Unfortunately the link is broken but maybe by the time you read this someone will have fixed it.
- A clarification of completion deadlines and completion dates. Sadly, there is nothing helpful here in terms of clarifying why the completion deadlines are even necessary at all - especially given the operational and logistical nightmares they create.
Posted by Heather P. Wilson, Ph.D. CEO - Weatherbee Resources, Inc.