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Strategic Alternatives for Meaningful Use

Award-winning medical center capitalizes on EHR self-certification option to help accelerate $9M in Meaningful Use Incentives



In 2009, the U.S. government passed the Health Information Technology for Economic and Clinical Health (HITECH) Act. This landmark piece of legislation set forth $27B[1]  in Medicare and Medicaid incentive payments to providers for demonstrating meaningful use of certified EHR technology.

“Certification” refers to the process of confirming that an EHR technology contains baseline technological capability, functionality, and security needed to achieve meaningful use objectives and measures. “Meaningful Use” (MU) on the other hand, is meant to assess how effectively EHR technology is utilized and its impact to actual patient outcomes. MU addresses not just technical capacity but effective implementation, training, support, leadership, and governance. Certification and MU criteria, as outlined in HITECH, must both be met in order to qualify for Medicare and Medicaid EHR Incentives.

The Challenge

Our client, a leading patient-centered academic medical center, sought to achieve Stage 1 MU of a Certified EHR within the first years of the program (2011 or 2012). However, the medical center was also simultaneously planning to migrate to a new EHR system in late 2013. The client's existing EHR platform was a legacy system that the vendor was not certifying for MU. Due to the planned migration to a new system, upgrading its current EHR to a vendor certified version made little business or financial sense.

In order to meet the strategic objective of attaining MU, leadership decided to pursue an innovative new form of certification called self-certification, making it one of the first hospitals in the country to pursue and successfully achieve this approach. Self-certification enabled the client to meet eligibility requirements and accelerate attestation for an estimated $9M in HITECH incentives.

Additional challenges beyond self-certification existed as well. The fast-changing policy environment required a close eye on any legislative changes, a flexible MU strategy, and last minute adaptations. Building strong executive support and system wide buy-in was an important issue as well, because successfully obtaining certification and operationalizing MU requires dedication across both the technical and operational realms of an organization.

How We Helped

The client initially engaged Deloitte to evaluate its readiness to achieve MU for both the inpatient hospital and its faculty practice. Deloitte completed this initial assessment by helping to identify specific risks and mitigation strategies, and next steps needed to achieve MU. The assessment helped the client better understand its eligibility and the total incentives it could potentially expect.  The assessment also focused on feasibility for the client to pursue self-certification.

Deloitte employed a collaborative resource model and collaborated with client team members to complete the assessment, leveraging the results to help develop a high level roadmap of certification, technology, workflows and reporting strategies needed to resolve gaps.

This included recommendations regarding an overall governance framework to drive and align Meaningful Use initiatives across the organization.

Following the assessment, Deloitte supported the client in its EHR self-certification efforts, working in conjunction with the client’s MU project team and CCHIT, an Authorized Certification and Testing Body. They worked to obtain certification for the Hospital Inpatient EHR system via the EHR Alternative Certification for Hospitals (EACH) program.

During this phase, Deloitte provided Meaningful Use experience and overall project leadership, including a MU gap analysis and a client tailored certification work plan.

After certification, Deloitte advised the client on operationalization of the clinical and technical changes necessary to successfully demonstrate MU and collect MU incentives. This included driving progress and status reporting, as well as leading the MU Steering Committee Meetings.


The project resulted in the successful certification of the client's inpatient EHR in 2011, making the medical center one of the first hospitals in the country to self-certify its EHR.

As a result of the self-certification, the client was able to attest to MU and be in position to collect its first Medicare Incentive payment. The client is expected to collect close to nearly $4M in 2012, having spent less than $1 million in project fees. Additionally, it is poised to receive another $5M in EHR incentives over the next three years.

1, Incentive Programs and Payment Schedule

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