Beyond Y2K: It's Not Over Till It's Over.

As you read this, the famous (or infamous) Y2K problem will be assumed by many to have come and gone. It will be back to business as usual--or will it? Does the Y2K risk suddenly disappear after January 1, or does it continue afterwards? The answer depends on: (1) whether all your mission-critical medical and nonmedical equipment is Y2K-ready and (2) whether core business processes (both in the facility and among its business partners) and their supporting automated systems are Y2K- compliant. If this is not the case then the Y2K problem is not over, even for those nursing home facilities that sailed past January 1 with flying colors.

Case in point: While Business Continuity and Contingency Plans (BCCPs), Day One and Rapid Response Plans have been focused on the December 31-January 1 transition, the U.S. Food and Drug Administration has emergency Y2K operations plans (and rapid-response plans) in effect for at least the first two quarters of the year 2000. This is because the FDA anticipates that, even where Y2K problems in computer hardware, software, medical devices, office operations, Medicare claims submission systems and business partner systems were identified, corrected and tested for Y2K readiness before January, other unanticipated Y2K problems might develop and require correction. The "unanticipated" problems have to be viewed and addressed through continued contingency planning.

If all Y2K readiness actions--assessment of Y2K risks, correction of problems and testing of systems--go according to plan, then it is possible that there will be no Y2K systems problems for the organization. However, if embedded chip problems arise, whether in biomedical devices, computer hardware and software or business systems, does the organization have a contingency plan to address these problems? And is this plan more than a disaster plan just for the period immediately following January 1?

What are the steps to take to assure that Y2K "contingencies," if they arise during the early part of the year, will be quickly addressed? First, regardless of your level of preparation to date, a sound backup plan is still needed to keep facility clinical and business operations functioning in the event of Y2K problems. This plan should identify both problems under direct facility control (medical devices, computer hardware and software, claims submission systems, office operations) and those beyond direct control (business partner systems). Second, once Y2K contingency problem areas are identified, a staff team must be assigned to deal with any problems that might arise. This team has to use common-sense approaches to limiting risk and responding to system failures. These include preparing for interacting with systems vendors and business partners, developing outreach/public information plans and arranging for post-rollover testing where needed. It also includes considering practical alternatives to accompl ish key business functions such as using paper records and keying data that normally are electronically transmitted. Third, it might be necessary to triage your response to previously undetected Y2K problems, especially in computer hardware and software, medical devices and Medicare claims submission systems. This could involve obtaining correction patches or embedded devices, contacting billing services or clearinghouses or Medicare Part A Fiscal Intermediaries or Part B Carriers and contacting businesses where electronic data interchange (EDI) takes place.

Several places offer guidance on contingency planning, including: the Contingency Planning Aids section of HCFA's Web site; the HCFA Year 2000 Business Continuity Handbook (a large document); the GAO'S August 1998 Report: Year 2000 Business Continuity and Contingency Planning; and for larger organizations, the Veterans Administration Patient-Focused Year 2000 Contingency Planning Guidebook. In addition, HCFA has a great deal of valuable information easily available to facilities via the HCFA Toll-Free Y2K Outreach Line, 1-800-958-4232 (Monday--Friday from 8:00 a.m. to 8:00 p.m., excluding federal holidays), and the HCFA Provider Outreach Contacts Web site at http://www.hcfa.gov/y2k/provorch.htm. This site contains information on: (1) Electronic Data Interchange claims submittal software; (2) Electronic Data Interchange Front-end Test submittals (phone numbers to contact Fiscal Intermediaries and Carriers to arrange for front-end acceptance testing of electronic data; links to Medicare contractor front-end te sting procedures are included); (3) Medicare Fiscal Intermediaries (Part A) on Y2K issues other than EDI submittal of claims data; (4) Medicare Carriers (Part B) on Y2K issues other than EDI submittal of claims; (5) Y2K Coordinators by Region; and (6) Medicaid Directors by State.

In the event that certain systems prove to be Y2K noncompliant, the quickest way to obtain information remains the U.S. Food and Drug Administration Web site search engine: www.accessdata.fda.gov/scripts/ cdrh/year2000/y2k_search.cfm.. Other sites that can still be used to check for Y2K compliance are: The Medical Devices Bureau of Health Canada's Therapeutic Product Program at www.hc-sc.gc.ca/hpb-dgps/therapeut/index.html; Duke University's database at www.mc.duke.edu/depts/clineng/y2result.htm; the Rx2000 Solutions Institute at www.rx2000.org; and the American Association of Homes and Services for the Aging (AAHSA)/Allied Healthcare Association Services Internet-based tool from Security Third Millennium at www.siiim.com. Remember that experience has shown that there is no single Web site that has information on every device, so be prepared to search multiple sites for needed information.

Malcolm H. Morrison, PhD is president and CEO of Morrison Informatics, Inc., a healthcare information technology consulting company specializing in post-acute care. For more information, e-mail: [e-mail]