Under the American Reinvestment and Recovery Act (ARRA), healthcare providers will receive an estimated $30 Billion worth of incentives and reimbursements tied to their adoption and use of Electronic Health Records (EHRs). By anyone’s standards, this is not a small chunk of change. At the small end of the scale, individual physicians could receive as much as $60,000 over time, and larger hospitals sevaral million dollars over time.

Except for the largest hospitals and clinic groups, healthcare providers have been reluctant to move substantially toward a paperless environment for many reasons, chief among them, prohibitive cost (initial cost, cost over time, and a questionable return on investment). With broader policy objectives in mind, Congress sought to address the cost side of the equation through the EHR incentives contained in ARRA. With all of this money available, we would expect to see healthcare providers beating down the doors of EHR providers. But they aren’t–at least not yet. Here’s why.

Uncertainty – ARRA attached eligibility criteria to the EMR incentives and reimbursements, but it did not define all criteria with precision. For example, we know that a healthcare provider must demonstrate “meaningful use” of its “certified” EHR system in order to qualify for funding, and that “meaningful use” includes both EHR system attributes, as well as deployed use by a provider. We’ve been given a vague understanding of the required system attributes (e.g., e-prescribe, order entry, interoperability requirements), but we do not yet have a comprehensive list or definition. The same is true of the certification requirement.

Moving Ahead in the Face of Uncertainty – If you are looking at buying your first EHR system, or expanding your existing EHR system–in either case, with a view to securing federal reimbursement dollars–you have to get over your fear of the uncertain and unknown. Because of the aggressive adoption timeframes established, you do not have the luxury of time to indulge in decision paralysis. You have to start your planning process now.

Strategy – Instead of focusing on what you do NOT know with certainty at the moment, focus on what you DO know with some degree of certainty. Second, transfer as much “uncertainty risk” as possible to others.

For example, we know with certainty now that your qualifying EHR system must include electronic prescribing capability and automated order entry. If you are buying a new EHR system, or you are attempting to qualify your existing EHR system, you will need these functional capabilities. The same is true of the interoperabity feature. We don’t know exactly what sort of interoperability will be required, but we know some form of interoperability will be required.

Risk Transfer – Realize that EHR vendors are experiencing the same pain as you regarding the uncertainty over qualifying criteria for EHR systems. And just like you, they’re not in a postition to sit on their hands until the regulatory dust settles.

Most EMR vendors will be willing to extend broad assurances and warranties regarding their products’ future compliance with EHR qualifying criteria as they are handed down over time. If you ask for these types of assurances and warranties from your candiate EHR vendors, you will probably get them.

Focusing on what you know with certainty at present, and realizing that you can transfer a good deal of uncertainy risk to your EHR vendor, might allow you to begin a meaningful EHR system planning process now.

Stay Informed – Watch for regulatory developments and pronouncements as they are handed down in the coming weeks and months. If you don’t have time to track these on your own, plug into the many free resources out there. Chances are good that many of the professional organizations you already belong to are tracking this information for you. Think about subscribing to their RSS feeds or consolidated weekly updates.

Role of Consultants – If you have a solo practice, or you’re part of a small group practice, you may not have time to investigate your EHR options. If this is your situation, think about hiring a consultant to evaluate your practice vis-a-vis the EHR options available to you. Many good HIT consultants will conduct a “needs analysis” and make recommendations for a smallish fee.

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