What is Y2014, and why should we think about it? The year 2014 (Y2014) is the starting date for some of the new rules that are part of the health care legislation passed in 2010 by our friends in Washington, DC. The prediction is that Y2014 will make Y2K look like no big deal, and we all know that even with all the overreaction there was a tremendous amount of work put in to locate and prevent potential problems from happening. They spent so much time and effort on pleasing the various special interest groups that no efforts were made to be sure that what was proposed would work and could be implemented in a timely fashion at a reasonable cost. The only good part about this problem (Y2014) is that Congress will push back dates and throw money at certain groups that either don’t need it or should not get any in an effort to make the transition smooth.
Right now, close to $1 billion in grant money is being awarded to groups and companies to work out what the electronic health records (EHRs) should contain. I would assume that the EHRs should contain basically the same information that has been in a patient’s record for years. About every other profession has been scanning their paper records into digital formats for a number of years. Why can’t those same systems that serve the banking and insurance industries be used for health records? What about all the hospitals, physicians, clinics, and others that are presently on EHRs? Will they be forced to change to new formats? It seems to this engineer that if you have something that is working, it is better to use that platform or platforms than to come up with something totally new. If we look at technology advances, the vast majority have been built off of existing technology with new features added and obsolete features deleted, then made to work with other systems under development. So why is a totally new system needed at billions of dollars, and how many problems need to be solved before it works as well as what is in place? Maybe it is part of the recovery stimulus packages?
In June 2010, the final rules were released by the Centers for Medicare and Medicaid Services, known as CMS, and the Office of the National Coordinator for Health IT, or ONC. The document is more than 800 pages long and cites more than 60 sources of information that were included in the rules. Trying to make sense of this set of rules reminded me of my struggle to understand calculus as an undergrad. (I’m not sure how I passed it, and I never used it.) It will take several months before people start to look at the provisions and think of what has to be done to comply. Some of you are thinking, “not my problem,” but it will be. Just how many interconnections will have to be done is not clear.
A problem that many hospitals will face in 2014 will be the same as those faced preparing for Y2K—how is a device that is out of support by the manufacturer upgraded to meet the new requirements? A similar problem is, how will the devices still supported by the manufacturers be upgraded to meet the EHR requirements? Because of our recent economic problems, many hospitals have devices more than 10 years old still in use, and in some cases close to 25 years for radiology devices. Not all these devices can be replaced before Y2014, so there are going to have to be some provisions that will allow for timely replacements of those devices and systems. Clinical engineering groups will have to become very involved in the capital planning processes, if they are not so already.
To prepare for putting together good budget numbers, we will have to go back to some of the same tasks—modified to the current needs—that we did for Y2K. Those tasks include the following functions:
- Review your equipment inventory to determine which devices need to be connected to the EHR system.
- Determine which of those devices need to be updated or replaced to achieve the connection. This will involve the vendors, and it will not be easy to get the information.
- If the devices cannot be updated, what are your options on replacing the devices? Purchase, lease, reagent rental?
- At this same time, you should look at all devices and get those that are no longer supported by the manufacturers scheduled for replacement.
- Work with the medical and financial staffs to determine what gets replaced or upgraded on a schedule. It will be close to impossible to replace or upgrade every device at once, so set up a reasonable schedule to accomplish that task.
- Determine what your department’s workload will be so additional help can be found to accomplish the required changes.
- Work with your in-service department on how the training will be done. Most vendors will not be able to provide a lot of assistance in this area because they will be overwhelmed. Off hours and weekends will be a major problem with the training programs. Also, if a lot of per diem or travelers are used, they will also present a training problem. Remember, it is not only the devices that they need training on but the EHR system.
One interesting item that should be pointed out is that nowhere in the 800-plus pages was anything written about enforcing the “final rules.” If there is no enforcement of the rules, why should they be followed? This will be the position of many lawyers and others that will probably challenge the rules. But, we should prepare for the rules and not get caught without being ready in case some enforcement provisions are added to this or other rules in the future.
David Harrington, PhD, is a health care consultant based in Medway, Mass, and a member of 24×7‘s editorial advisory board. For more information, contact .