Accounting Question 300 words

P A R T

Technology as a Financial Tool

VIII

217

Electronic Records: Financial

Management To o l s and Decisions

19 C H A P T E R

INTRODUCTION

While this chapter has a lot of technical terms and foot- notes, you need to pay close attention. Why? Because this chapter describes a major revolution that is occurring in health care systems right now. And if you are working in health care, you too will almost surely be affected in some way.

ELECTRONIC HEALTH RECORDS ADOPTION: WHY NOW?

This section contains an overview of electronic health records (EHRs) and why compliance requirements may force change.

Definitions

A qualified electronic health record, according to the Ameri- can Recovery and Reinvestment Act of 2009 (ARRA), is “an electronic record of health-related information on an individual that:

(A) includes patient demographic and clinical health information, such as medical history and problem lists; and

(B) has the capacity i. to provide clinical decision support; ii. to support physician order entry; iii. to capture and query information relevant to

health care quality; and iv. to exchange electronic health information

with, and integrate such information from, other sources.”1

After completing this chapter, you should be able to

1. Define a qualified electronic health record.

2. Define health information technology (HIT).

3. Recognize ARRA incentive opportunities for hospitals and physicians.

4. Identify three compliance requirements that may force information systems change.

5. Identify three types of ICD-10 adoption costs.

6. Identify the four components of a SWOT analysis.

P r o g r e s s N o t e s

218 CHAPTER 19 Electronic Records: Financial Management Tools and Decisions

Health information technology means “hardware, software, integrated technologies or re- lated licenses, intellectual property, upgrades, or packaged solutions sold as services that are designed for, or support the use by, health care entities or patients for the electronic creation, maintenance, access, or exchange of health information.”2

Historically Slow Adoption Rate

A study published in 2009 revealed that only 1.5% of U.S. hospitals have a comprehensive electronic-records system (defined as a system that is present in all clinical units), and only an additional 7.6% of U.S. hospitals have a basic system (defined as a system that is present in at least one clinical unit). Furthermore, only 17% of hospitals have a computerized provider-order entry system for medications. The authors state that: “A policy strategy fo- cused on financial support, interoperability, and training of technical support staff may be necessary to spur adoption of electronic-records systems in U.S. hospitals.”3 The authors re- port that they surveyed “all acute care hospitals that are members of the American Hospital Association for the presence of specific electronic-record functionalities”4 and achieved a 63.1% response rate.

Three Compliance Requirements May Force Change

Healthcare organizations in the United States are now required to comply with a series of adoption rates for electronic health records. These requirements are driven by a series of fi- nancial incentives and penalties. Figure 19-1 illustrates three such compliance require- ments for adoption of

• Electronic health records (initiated by the American Recovery and Reinvestment Act of 2009)

• ICD-10-CM and ICD-10-PCS codes • Electronic prescribing for physicians and other prescribing professionals

Adoption of Electronic Health Records Initiated by the American Recovery and Reinvestment Act of 2009

The American Recovery and Reinvestment Act of 2009 (ARRA) allows a range of transition dates for inpatient hospital service paid incentives. The transition dates range from Octo- ber 1, 2011, to 2015. The last year that physicians can adopt electronic health records under ARRA without financial penalty is 2014.5

Adoption of ICD-10-CM and ICD-10-PCS Codes

The final compliance date for adoption of ICD-10-CM and ICD-10-PCS codes is October 1, 2013.6

Adoption of Electronic Prescribing for Physicians and Other P rescribing Professionals

The last year for physicians to adopt e-prescribing without a financial penalty is calendar year 2012.7

Compliance dates were set to allow for transition periods, and extensions may occur in the future. Compliance requirements are further described and discussed within this chap- ter and the following chapter.

AMERICAN RECOVERY AND REINVESTMENT ACT OF 2009 (ARRA) INCENTIVES FOR HEALTH INFORMATION TECHNOLOGY ADOPTION

The American Recovery and Reinvestment Act of 2009 (ARRA) that was signed into law on February 17, 2009, includes a program to promote the adoption and use of health infor- mation technology (HIT) and electronic health records (EHRs).8 Federal policymakers are working toward the “development of a nationwide health information technology infra- structure that allows for the electronic use and exchange of information” and an appointed National Coordinator (of the Office of the National Coordinator for Health Information Technology) is instructed to work toward this goal.9 The program provides approximately 17 billion dollars in incentives for hospitals and physicians. A brief description of the ARRA incentives follows. This description is for general information only; consult the legislation for pertinent details.

Hospital Incentives under ARRA

Hospital incentives are based upon inpatient hospital services, and the hospital must be a “meaningful electronic health records (EHR) user” to be eligible for payment. In general, an eligible hospital can receive a $2,000,000 base amount payment plus discharge-related payments that span a four-year period. (The discharge-related amounts are paid for 1,150 through 23,000 discharges. Thus, the first through the 1,149th discharges receive no

American Recovery and Reinvestment Act of 2009 (ARRA) 219

ICD-10-CM and

ICD-10-PCS (final compliance date)

October 1, 2013

Electronic Health Records for I/P

Hospital Services Under ARRA

(transition date with incentives)

October 1, 2011–2015

E-Prescribing for Physicians

(last dates to adopt without penalty)

CY 2012 CY 2014

Electronic Health Records for Physicians

under ARRA (last dates to adopt

without penalty)

Dates to Adopt Information System Changes*

*Date may subsequently move forward.

Figure 19–1 Compliance Dates to Adopt Information System Changes. Source: 74 Federal Register 3328 (January 16, 2009); 73 Federal Register 69847 (November 19, 2008); American Recov- ery and Reinvestment Act of 2009 (ARRA) Title IV Section 4101.

?/Ed: RH too long ok as set?

220 CHAPTER 19 Electronic Records: Financial Management Tools and Decisions

payment, and likewise, discharges over 23,000 receive no payment.) The eligible discharge- related amounts are paid at 100% for year one; at 75% for year two; at 50% for year three; at 25% for year four; and nothing thereafter. Payment years may begin for the fiscal year beginning October 1, 2011. If a hospital has not adopted by 2015 it will face financial penalties.10

The ARRA also requires that the names of hospitals who are “meaningful electronic health records users” will be posted on the CMS Web site. “Meaningful electronic health records user” means the hospital is:

• Using certified EHR in a meaningful manner. • Is connected in a manner that provides for the electronic exchange of health infor-

mation to improve the quality of health care, such as promoting care coordination. • Submits information on clinical quality measures and other measures not yet deter-

mined.11

Physician Incentives under ARRA

These “eligible professional” incentives under ARRA are paid only to physicians as defined by law who are “meaningful EHR users.” It is important to note that these incentive pay- ments will not be made to hospital-based eligible professionals who might be otherwise eli- gible. (The determination is made on the basis of site of service.)12

The maximum amount a physician can receive decreases year by year as follows:

Year 1 � $15,000; except if the first year is 2011 or 2012, then the year 1 payment is $18,000

Year 2 � $12,000 Year 3 � $ 8,000 Year 4 � $ 4,000 Year 5 � $ 2,000 Subsequent years � $-0- (no incentive payments after 2016)13

If the first payment year (year 1) is after 2014, no incentive dollars will be paid. If adop- tion has not occurred by 2015, the physician’s fee schedule amount will be reduced by a percentage.14

The ARRA also requires that the names of physicians who are “meaningful EHR users” will be posted on the CMS Web site. “Meaningful electronic health records user” means the physician is:

• Using certified EHR in a meaningful manner. • Connected in a manner that provides for the electronic exchange of health informa-

tion to improve the quality of health care, such as promoting care coordination. • Reports on measures using EHR.15

In conclusion, we expect interpretations of the ARRA, along with supporting rules and regulations, to emerge over a considerable period of years. (For example, the legislation says to expect more stringent measures of meaningful use over time.)

ICD-10 E-RECORDS OVERVIEW AND IMPACT

This section provides an ICD-10 overview and describes the ICD-10 electronic records impact.

Overview of ICD-10

The International Classification of Diseases, 10th Revision (ICD-10) is designed to “pro- mote international comparability in the collection, processing classification and presenta- tion of mortality statistics.”16 The ICD is the international standard diagnostic classification for all general epidemiological, many health management purposes, and clinical use.17

This classification system has been developed in collaboration between the World Health Organization (WHO) and ten international centers. Other countries that have already adopted ICD-10 during the period 1995 to 2001 include Australia, Canada, France, Ger- many, and the United Kingdom.18

ICD-10-CM AND ICD-10-PCS

The National Center for Health Statistics (NCHS) is one of the ten international centers collaborating with the WHO in the development and revisions of the ICD. The NCHS is an agency within the Centers for Disease Control and Prevention (CDC). As such, NCHS is the federal agency that is responsible for use of the ICD-10 in the United States.

WHO owns the ICD-10 copyright and has “authorized the development of an adaptation of ICD-10 for use in the United States for U.S. government purposes.”19 The NCHS, under the CDC, has developed a clinical modification of the ICD-10, termed “ICD-10-CM.” The ICD-10-CM is slated to replace the ICD-9-CM. The ICD-10-CM diagnosis classification system has been developed for use in all types of healthcare treatment settings in the United States.20

Meanwhile, the Centers for Medicare and Medicaid Services (CMS) has developed a pro- cedure classification system, termed the “ICD-10-PCS.” The ICD-10-PCS is for use in inpa- tient hospital settings only within the United States.21 (Note this difference: ICD-10-CM is for use in all types of healthcare treatment settings, while ICD-10-PCS is for use in inpatient hospital settings only.)

ICD-10 Impact in the United States

The change from ICD-9 to ICD-10 has a ripple effect that impacts nearly every corner of the healthcare industry in the United States.

Related Electronic Transaction Standards in the United States

Electronic records will only reach their maximum potential when such records can be transmitted back and forth between entities. In order to allow such transmission, we must have standards that assure electronic compatibility (or, in governmentese, “electronic in- tercompatibility”). Accordingly, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Public Law 104-191 mandated adopting such standards for “electronically

ICD-10-CM and ICD-10-PCS 221

222 CHAPTER 19 Electronic Records: Financial Management Tools and Decisions

conducting certain health care administrative transactions between certain entities.”22

HIPPA requires these standards to be adopted and used to “facilitate the electronic trans- mission of certain health information and the conduct of certain business transactions.”23

The phrase most used to describe these requirements is thus “electronic transactions standards.”

A whole array of sequential rules and regulations has evolved since 1996 to create these electronic transaction standards and to require their adoption—and a description of such rules and regulations is well beyond the scope of this book. However, two particular items are of interest to us in the context of the ICD-10 transition.

1. It was necessary to update many electronic transaction standards in order to accom- modate the new ICD-10 codes. The groups, or sets, of codes (termed “standard med- ical data code sets”)24 to be used in those electronic transactions also had to be updated. (Note that at the time of this writing, the current standard to be adopted is Version 5010, although new versions will inevitably be introduced in the near future.)25

2. When the Centers for Medicare and Medicaid Services (CMS) staff compute transi- tion costs, they divide some of these costs between the updating of transaction stan- dards such as Version 5010 (which they argue would have to occur anyway) versus the cost of adopting and implementing the ICD-10 codes. We will be referring to this cost-splitting within a later discussion of implementation costs.

Changes in electronic transaction standards directly impact providers, health plans, and others as illustrated in Figure 19-2. Providers affected include, at a minimum, hospitals, physicians, dentists, and pharmacies. Health plans affected include commercial health plans, the Blue Cross/Blue Shield plans, and all government plans such as Medicare and

Providers

• Hospitals

• Physicians

• Dentists

• Pharmacies

Others

• Clearinghouses

• Vendors

Health Plans

• Commercial Health Plans

• Blue Cross/Blue Shield Plans

• Government Plans: Medicare & Medicaid

Healthcare Industry Segments Directly Affected by the Adoption of Updated (Version 5010) Electronic Transaction Standards

Figure 19–2 Electronic Transaction Standards Impact. Source: 73 Federal Register 49761 (August 22, 2008).

Medicaid. Other healthcare organizations that are affected include the electronic infor- mation clearinghouses and the vendors who provide hardware and software to the health- care industry.

P roviders and Suppliers Impacted by the ICD-10 Transition

The companies and organizations impacted by the ICD-10 transition include inpatient providers, outpatient providers, and an array of other support ser vices and suppliers. Figure 19-3 illustrates the entities that are affected by the ICD-10 transition. Inpatient providers impacted include both hospitals and nursing facilities. Outpatient providers include, at a minimum, physician offices, outpatient care centers, medical diagnostic and imaging services, home health services, other ambulatory care services, and durable medical equipment providers. Support ser vices and suppliers include health insurance carriers and third-party administrators, along with the vendors who provide computer sys- tem design and related ser vices.26 Note that pharmacies (both chain and independent pharmacies) are substantially impacted by the required electronic transaction standards updates for pharmacies, while ICD-10 adoption is generally more of a peripheral issue for pharmacies.

ICD-10 BENEFITS AND COSTS

The ICD-10 transition process will require management decisions that take both costs and benefits in account. A brief summary follows.

ICD-10 Benefits and Costs 223

Inpatient Providers

• Hospitals

• Nursing Facilities

Others

• Health Insurance Carriers & Third Party Administrators

• Computer System Design & Related Services

Outpatient Providers

• Physician Offices

• Outpatient Care Centers

• Medical Diagnostic & Imaging Services

• Home Health Services

• Other Ambulatory Care Services

• Durable Medical Equipment

Inpatient and Outpatient Providers and Suppliers Impacted by ICD-10 Transition Costs

Figure 19–3 ICD-10 Transition Costs Impact. Source: 74 Federal Register 3357 ( January 16, 2009).

224 CHAPTER 19 Electronic Records: Financial Management Tools and Decisions

Benefits

Management will need to account for what their own organization will realize in conversion savings as benefits. CMS identified six benefits of transitioning to ICD-10, including:

• More accurate payments for new procedures • Fewer rejected claims • Fewer improper claims • Improved disease management • Better understanding of health conditions and healthcare outcomes • Harmonization of disease monitoring and reporting world-wide27

In regard to recognition of other benefits, see our comment about cost-splitting in a previ- ous paragraph, as the same concept applies to splitting benefits. Thus, the systems conver- sion to Version 5010 also recognizes three types of benefits, including operational savings (better standards); cost savings (increase in electronic claims transactions); and opera- tional savings (increase in use of auxiliary transactions).28

Management should also decide what potential governmental financial assistance might be available to their own organization. The ARRA legislation previously described in this chapter provides financial incentives for the timely adoption of electronic health records. The ICD-10 conversion is, of course, part (but not all) of this adoption process. It is there- fore logical for management to consider part of the financial incentives offered as relating to this system conversion when analyzing benefits.

Costs

Management must make decisions about major costs incurred in the ICD-10 transition, in- cluding direct adoption costs and cash flow disruption costs. Some costs will be one-time costs, while other costs will become recurring costs, and this factor must also be considered in the decision-making process.29

Three Types of ICD-10 Adoption Costs

CMS acknowledges that transition costs from ICD-9-CM to ICD-10 code sets are unavoid- able and are incurred in addition to the Version 5010 standards conversion costs.30 Three recognized types of ICD-10 adoption costs include:

1. System changes 2. Training costs 3. Productivity losses

CMS believes that large providers and institutions will most likely need to make system changes and software upgrades. However, CMS also believes small providers may only need software upgrades.31 This belief is based upon findings that the majority of small providers have simplistic systems.32

Details about training costs and productivity losses are addressed in the following chap- ter. As a final note, also see our comment about cost-splitting in a prior paragraph. Thus,

systems conversion to Version 5010 recognizes two similar types of cost: system implemen- tation costs and transition costs.33

Cash Flow Disruption Costs

Code set transition has a learning curve for all users. Thus, it is to be expected that a greater proportion of claims will be rejected during this learning curve. Rejected claims lead to cash flow disruption, and should be taken into account when decisions are made about im- plementation costs and benefits.

If certain contracts contain stipulations as to ICD-9 codes, these contracts may have to be renegotiated. The much greater specificity of the ICD-10 codes may make such renegotiation necessary in certain cases, and cash flow from contracts may be disrupted in the interim.

SYSTEM IMPLEMENTATION PLANNING

System implementation on this scale requires multiple planning cycles.

Scope of Management Decisions

The financial impact of a misstep in the purchase and installation of hardware and/or soft- ware can be pervasive. Thus, the management may focus primarily on purchase and instal- lation, bypassing the importance of other aspects such as assessing documentation trails and creating training plans. The scope of management decisions for system implementa- tion should thus be extremely broad in the initial phases.

Implementation Planning

CMS recommends that healthcare organizations plan for implementation of ICD-10- CM/PCS by developing a three-step organizational plan that includes:

• Step 1: Situational Analysis • Step 2: Strategic Implementation/Organizing • Step 3: Planning for Strategic Control34

Figure 19-4 illustrates these steps. We believe that development of a timeline and a map of individual responsibilities should also be an important part of this planning process.

1. Situational Analysis: Situational analysis is defined and discussed in the following section.

2. Strategic Implementation and Organizing: The strategic implementation and orga- nizing planning step includes acquiring the resources to implement the plan and evalu- ating the financial impact of the plan. In actual fact, these two steps should be reversed, as the scope of the financial impact should be considered before resources are acquired.

3. Planning for Strategic Control: Developing objectives should, of course, be the first step in planning for strategic control. The remaining planning recommendations are action steps. They include planning measurement tools, evaluation strategies, and ac- tions to implement.35

System Implementation Planning 225

226 CHAPTER 19 Electronic Records: Financial Management Tools and Decisions

SITUATIONAL ANALYSIS

This section contains both a definition and recommendations for a situational analysis.

Definition

A situational analysis does two things. It reviews the organization’s internal operations for strengths and weaknesses and it explores the organization’s external environment for op- portunities and threats. (Thus SWOT: strengths-weaknesses-opportunities-threats.)

A situational analysis allows management to, literally, analyze the organization’s situa- tion. Situational analysis is particularly appropriate for the analysis of electronic records sys- tems implementation because such implementation requires the collaboration of multiple knowledge areas. A meeting of the minds can better occur with the discipline that a situa- tional analysis can impose. It is a powerful tool when properly applied.

Situational Analysis Recommendations for ICD-10

CMS recommends six steps for an ICD-10 adoption situational analysis. We believe the six steps should be divided into two parts. The first part contains strategic steps that must be addressed at the beginning of the project. The second part of the analysis contains developmental steps that we believe can only be properly accomplished after the strategic steps have been com- pleted. (That said, however, we must also acknowledge that sometimes immovable deadlines and/or lack of sufficient planning resources do not allow the ideal two-part process.) Figure 19-5 illustrates the CMS situational analysis recommendations for ICD-10 adoption.

Strategic Steps

The strategic steps that CMS recommends include three steps discussed as follows:

Situational Analysis

See Figure 19.5

Strategic Implementation/

Organizing

• Acquire resources to implement

• Evaluate financial impact

System Implementation Planning Recommendations

Planning for Strategic Control

• Develop objectives

• Plan measurement tools

• Plan evaluation strategies

• Plan actions to implement

Figure 19–4 System Implementation Planning. Source: Centers for Medicare & Medicaid Services (CMS) ICD-10 Fact Sheet.

1. Stakeholders: Step number one is to identify stakeholders. This traditional first step is an important beginning point for the analysis. The array of stakeholders will vary depending upon the size and nature of the healthcare organization. Payers should always be one of the stakeholders. Regulatory agencies may also be recognized as stakeholders.

2. Impacts: Step number two involves as- sessing the impact of the ICD-10 tran- sition. Impacts on all aspects of the organization should be recognized. As with stakeholders, the transition’s impact will also vary significantly de- pending upon the size and type of healthcare organization.

3. Strategies and Goals: Step number three involves formulating strategies and identifying goals. The larger the organization the more likely there will be competing strategies and goals. Compromises may have to be negoti- ated. Tight deadlines and/or lack of planning resources may work to short- change this component of the situa- tional analysis.36

Developmental Steps

The developmental steps that CMS recommends also include three steps, discussed as fol- lows. Note that different knowledge areas are required for these different steps.

1. Training Plans: Training plans must be developed for employees at all levels. The cost of training for ICD-10-CM/PCS implementation is discussed and illustrated in the follow- ing chapter.

2. Systems Change Implementation Plan: Information systems and/or technology sys- tems “change implementation plans” must be developed. These plans must include timelines and individual responsibilities. The timelines should leave sufficient time for testing. (Insufficient testing time is a common pitfall.) A “go live” date is another important part of this plan. If hardware and/or software vendors are involved in a fa- cility’s implementation plan, all timelines and the final “go live” date must also be co- ordinated closely with the vendor.

3. Documentation Change Plan: The documentation change plan will hopefully cover all areas of the organization where documents exist that will reflect ICD-10-CM/PCS

Situational Analysis 227

Identify stakeholders

Assess impact

Formulate strategies

and identify goals

Develop education/ training plans for

employees at all levels

Plan for documentation

changes

Develop information systems/technology

systems change implementation plan that includes testing and “go live” date

Situational Analysis Recommendations

Figure 19–5 Situational Analysis Recommendations. Source: Centers for Medicare & Medicaid Services (CMS) ICD-10 Fact Sheet.

228 CHAPTER 19 Electronic Records: Financial Management Tools and Decisions

changes. A document inventory is the ideal beginning point for a documentation change plan. The inventory allows for a full and complete change plan, but lack of resources often means completing the full document inventory is not possible.37

SWOT ANALYSIS AS A TOOL

A SWOT analysis, properly performed, can be an excellent strategic tool. The four compo- nents of a SWOT analysis include:

• Strengths • Weaknesses • Opportunities • Threats

The SWOT analysis format is illustrated in Figure 19-6. Here we see that the “Strengths” and “Weaknesses” sectors of the matrix are labeled “Internal,” while the “Opportunities” and “Threats” sectors are labeled “External.”

As to the internal components, the SWOT team or task force needs to evaluate resources and thus identify those that should belong in the strengths and weaknesses sectors of the SWOT matrix. For example, for an Information Technology (I.T.) analysis such as the ICD-10 adoption issue, the team might enter “Financial Resources” as a main heading and “Capital Resources Available” as one of the Financial Resources subheadings in the strengths and weaknesses categories.

The team might also enter “Information Technology” as a main heading. Because this is an I.T. project, some of the subheadings in the strengths and weaknesses categories might include:

• I.T. Hardware Resources • I.T. Software Resources • I.T. Storage Capacity • I.T. Staffing Capacity • I.T. Staffing Knowledge Levels • And so on

Understand that the SWOT matrix is built as these resources are evaluated. As to the ex- ternal components, the SWOT team or task force would likewise evaluate the external op-

portunities and threats as a parallel exercise. In an Information Technology (IT) analysis such as the ICD-10 adoption issue, the team might logically enter the government’s in- centive payment as an external opportunity (potential dollars received) and an external threat (compliance requirements to be met).

The four-part SWOT matrix is built as the key internal resources, both strengths and weaknesses, are evaluated, and the key ex- ternal opportunities and threats are identi- fied and evaluated.

StrengthsInternal

External

Weaknesses

Opportunities Threats

Figure 19–6 SWOT Analysis.

We can tie the CMS recommendations to this discussion of the SWOT matrix as follows. Identifying stakeholders and commencing to assess impacts of the ICD-10 adoption are considered part of building the SWOT matrix. Formulating strategies and identifying goals would most likely come after building the initial matrix, because these actions would be in- fluenced and should naturally carry forward from the evaluations performed as part of the SWOT matrix-building process. Finally, the remaining three developmental steps, each of which involves creating a plan, should all come as final steps in the situational analysis process.

We should also acknowledge that there are a variety of approaches to performing a situ- ational analysis, and this brief discussion features only a single approach. No matter what approach is utilized, the results of the situational analysis are what count.

TECHNOLOGY IN HEALTHCARE MINI-CASE STUDY

Even simple technological changes can improve workflow and increase efficiency. This fact is borne out by Mini-Case Study 4, entitled “Technology in Health Care: Automating Ad- missions Processes.” Electronic records are powerful financial management tools that can bring about measurable results, as this case study proves.

INFORMATION CHECKPOINT

What Is Needed? Some description of health information technology (HIT) as defined in the first part of this chapter. This could be a description of HIT within your place of work, or it could be advertising materials attempting to sell HIT hardware and/or software.

Where Is It Found? Possibly in the information technology or administration offices at your place of work. There are many varied sources for HIT advertising materials.

How Is It Used? The HIT description could be used to evaluate or assess current HIT status at your place of work; or such a de- scription could be within a manual (but be careful about proprietary use if that is the case). The advertising ma- terials, of course, are trying to sell the product.

KEY TERMS

Electronic Health Record (EHR) Electronic Prescribing (E-Prescribing) Health Information Technology (HIT) Situational Analysis SWOT Analysis

Key Terms 229

230 CHAPTER 19 Electronic Records: Financial Management Tools and Decisions

DISCUSSION QUESTIONS

1. Do you use electronic health records in your own work? If so, how do you use them? 2. Do you know of a healthcare organization that is either initially installing or upgrad-

ing its electronic health information technology? If so, will you describe how this or- ganization is going about it?

3. Do you think posting the names of the “meaningful health electronic record users” publicly on the CMS Web site is a good idea? If so, why? If not, why not?

4. Why do you think the federal policymakers decided to make the names public on a government Web site?