Despite some recent backpedaling on the Meaningful Use Stage 2 Timetable by the ONC, those in the know continue to operate on the principle that the Federal Government will not back off on their long term policy goal of achieving a Nationwide Health Information Network.
In 2014, this agenda has collided with the adoption of ICD10 and the difficulties of adapting to the Affordable Care Act, so it has become necessary for the Feds to temporize the Meaningful Use Stage 2 Timetable to give the smaller EMR Vendors and their Doctor Customers some breathing room. For this reason, the ONC recently announced that Doctors using EMR Vendors that have not yet achieved Meaningful Use Stage 2 will be exempted from the Medicare Payment Penalty, which is based upon 2014 performance and is due to take effect in 2015. However, these Doctors will not receive 2015 Incentive Dollars since they will not be able to attest to Meaningful Use Stage 2 in 2014.
For a small EMR Vendor to achieve Meaningful Use Stage 2 on any timetable is a giant challenge, considering the complexities that must be solved. If these EMR Vendors determine that they lack the resources to get this done, they face a difficult dilemma. Their choices boil down to hunkering down with their present Doctor Customers or selling their assets since new adopters and those switching their EMR will not choose an MU 1 Only Vendor. However, there is the possibility that these EMR Vendors could White Label an EMR/PM that is already Meaningful Use Stage 2. This would, on an immediate basis and without these EMR Vendors having to take the Certification Test, empower these Companies with MU2, allowing their Doctor Customers to attest to MU2 in calendar year 2014. For a specialty EMR, this would involve an alignment of their Application with the White Label MU2 Certified EMR where the Common Meaningful Use Data Set would be entered. Furthermore, these EMR Vendors could at the same time get off the R & D Merry-Go-Round and devote their efforts to marketing and sales since presumably the Company from whom they White Label would keep pace with the future stages of Meaningful Use.
If such a White Label scenario were considered, migration of the EMR Vendor Company’s data for all their Doctor Customers would be necessary. And whether the EMR Vendor had a Client/Server Platform or a Cloud Platform, they would be faced with the question of what kind of Platform was used by the MU 2 White Label Partner Company.
This is important because the delivery of Software to the UI is now quickly evolving to the Cloud Platform so that an EMR Vendor choosing a White Label Partner would not want to make the mistake of looking backward by choosing a Client/Server Partner. Specifically, this choice would directly impact the migration of the data and whether this critical process was accomplished without exceeding a threshold of error so that their Doctor Customers remained satisfied.
Migration consists of 3 parts:
-Access the old data
-Transform the data
-Store the new data
If the data stored in a Client/Server Platform System is migrated to a Cloud Platform, there are many locations converging on one location, the Cloud. The advantages here are that migration steps 2 and 3 are done by the Cloud Company, the migration to the Cloud does not finish unless the migration is correct, any subtle errors found later only have to be fixed in the Cloud (one and done), and all Updates are done in the Cloud (one and done). Migrating to a Client/Server Platform involves work in every Doctor Customer’s Office. If there are 200 Doctor Customers involved, then 200 separate transitions must take place to accomplish the entire migration, and each one of these separate 200 transitions involves Local IT Workers, which increases the chances for error. If there is an error, all 200 offices will have to be fixed individually. Furthermore, when you get to the Go-Live Starting Point, the Software is not necessarily the same in all 200 offices- there is the possibility for varied sets of complications that are unique to one or more sites, resulting in several troubleshooting excavations with specific and discrete results. And, of course, all Updates have to be done 200 times- done in every office.
Migration is not the only reason an EMR Vendor in the market to White Label a MU 2 certified product would want to choose a partner with a Cloud Platform. Per above, the EMR Vendor would be relying on their Partner to attain MU 3, MU4, and MU 5, and these future certifications can best be accomplished with a Cloud Platform. In fact, a Client/Server Platform will increasingly be under pressure to apply makeshift solutions to pass the measures in these future certifications. Another reason to choose a Cloud Platform is that the Interoperability that is the chief goal of the entire Federal Enterprise will ultimately only be possible with a Cloud Platform when all upstream complexities have been fully worked out and have flowed downstream. From that perspective, we have only begun to understand completely and utilize efficiently the possibilities that the Cloud Platform can unlock, for like the human brain itself it undoubtedly contains vast dimensions that are yet to be discovered and harnessed for the good of industry.