Dr. Kaplan is immediate Past President of ACEP. Ms. Tomar is federal affairs director for ACEP.

What Should You Be Doing Now?

By Todd B. Taylor, MD, FACEP

By June 30, 2017, CMS will release a list of qualified CDS mechanism (CDSM) solutions. This list may or may not include specific EMR employed solutions. Depending on your current EMR, workarounds may be necessary. Nevertheless, most EMR vendors are already focused on this requirement.

Process

• Determine if your hospital already has a plan for adoption of a CDSM. If not, make them aware and take initiative in managing the impact on the emergency department. These efforts may also be driven by radiology as penalties apply to radiologist reimbursement as well as the hospital.
• Insist on being involved in the development and review of the CDSM adoption plan. This plan may be quite detailed, but here are a few elements you should note:
  1. Perform an “environmental assessment” (ie, what you currently have, what may be barriers to adoption, who are the stakeholders, etc.).
  2. Define the scope of the project to include time lines, functionality review, safety assessment, impact on workflow, implementation schedule, training, etc.
  3. Explore solutions (eg, are they available within your current EMR or will you require a qualified third party CDSM?). This evaluation must include a functional suitability assessment. For example, if the CDMS integrated within your EMR is not suitable for the emergency department, it may require adoption of a third-party solution. Remember, most solutions are designed with a “traditional” outpatient focus and NOT for an ED environment.
  4. Review the implementation plan. Note: Most IT projects fail not because of the technology (ie, the software), but rather due to poor implementation. With many IT projects, there have been reasonable successes and unmitigated disasters with exactly the same product.
• Non-negotiables:
  1. The CDSM must be CMS qualified.
  2. ED physician leadership must be included in the process of evaluation, selection implementation, and ongoing assessment. (See ACEP Policy: Health Information Technology.)
  3. The plan must address the additional administrative overhead related to this requirement and how it will be mitigated by the chosen CDSM solution. This may result in a determination that the current EMR lacks functional tools and a third-party solution is required.
  4. The CDSM solution must accommodate the unique needs of the emergency department versus merely forcing a routine outpatient system onto the emergency department.
  5. The solution must be safe and effective. It may be difficult to imagine how this could impact patient safety, but if inordinate delays result then that may be the result. Whether this particular CDSM effort is “effective” remains to be seen. Evidence from other initiatives such a provider order entry have been mixed for both safety and effectiveness.
  6. The emergency physician leadership should advise administration that they will make every effort to comply with the CDSM system as designed, but cannot be held responsible for situations in which no logical “approved” indication exists based on the patient’s clinical findings. In such circumstances, the closest alternative approved indication will be selected. It may be prudent to flag such instances to provide feedback to the vendor and provider-led entity.