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Can 2-State Medicaid Providers Collect 2 EHR Incentives? – Meaningful Use Monday

Posted on October 31, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

A Meaningful Use Monday reader asked whether a provider who practices near the border of two states and treats patients under the two distinct Medicaid programs can participate in both EHR incentive programs. A similar question has been asked by physicians who have practice locations in two neighboring states. The answer is “No”, even if the EP meets or exceeds the 30% patient volume threshold in both states. 

EPs can receive only one incentive each year, and they must choose the state from which they wish to receive the payment. They can, however, change states on an annual basis when they re-attest—flexibility which is valuable in the event that their Medicaid volume falls below the required level in the first state and they lose eligibility for that program. 

CMS created a single registration system for both incentive programs to enable the States to check for—and make them responsible for preventing—duplicate payments, whether from two states or from Medicaid and Medicare simultaneously. My next Meaningful Use Monday post will discuss the rules for switching between the Medicaid and Medicare EHR incentive programs.

The Commodity EMR, EMR Adoption and Other EMR Tweets

Posted on October 30, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Time to go through some interesting Tweets from the world of EMR and EHR.

@glevin1 – gary levin
Commodization of EMR | HealthWorks Collective

There was a link on this tweet too, but it looked like a link to a page that stole the content from the original article. I’ve been intrigued by the question of whether EMR is a commodity software or not for a while now. I still haven’t come to a firm conclusion. This article uses the idea that you can buy Allscripts MyWay at Costco as a way to say that EMR is a commodity. You can also buy eCW at Sam’s Club I believe. Although, as best I can tell, that was basically a PR move on the various EHR vendors part.

Also, the article says that Allscripts MyWay product came from the purchase of Misys. Actually, I think MyWay was originally Aprima. I believe the Misys EHR software is set to be sunset.

What do you think? Is EMR a commodity?

@BrianSMcGowan – Brian S. McGowan PhD
Percent of US PCPs using EMR = 17% in ’00’ – 28% in ’06’ – 46% in ’09’ (vs 99% in Netherlands) #socialQI #progress??

The link on this one was to a terribly long PDF file. So, I cut it out. I just wish I knew where Brian got his numbers. I call BS on the US having 46% EHR adoption in 2009. I still put us at about 25% EHR adoption now. Maybe a little higher if I’m being generous. Of course, a lot of people define EHR a lot of different ways. So, that might be part of the issue.

@DRZORBA – Zorba Paster
Back to the clinic. Everyone brings their records with them. No EMR here. If they lose their record then they’re @*%&M.

Hmm…imagine a world where the doctor didn’t keep any record. The patient was just responsible for the record. That idea is fraught with trouble and issues, but I bet many doctors would love to not have to worry about the records part of their job.

@medreccom – Medical Records
“Paper is dangerous and inefficient, it doesn’t belong in health care any longer.” Future of #EMR: on.mash.to/uhVkHn

I was interested in this tweet since it linked to an article on Mashable (a mainstream tech site). So, if I get this right, this article and series was sponsored (ie. paid for) by Lenovo and profiles Practice Fusion. In other words, Lenovo paid to advertise Practice Fusion on Mashable. Good for Practice Fusion. Although, I’m not sure how many doctors read Mashable. Maybe the article wasn’t about finding doctors, but was a way to find more tech people to come work at Practice Fusion. The article itself is pretty basic for someone that reads this site. Not a bad play if that was the intent. Full Disclosure: Practice Fusion advertises on this site. Although, they certainly didn’t pay me to write about this and link to it.

Practice Acquisitions By Hospitals Causing Issues with EHR Adoption

Posted on October 28, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The readers of EMR and HIPAA have been incredible lately in sending in great commentary on the EMR industry. The following is one such commentary about the issues associated with the now widely seen trend of Hospitals acquiring practices. The person asked to remain anonymous and for the names of the specific EHR vendors to be removed. I agreed since I think the trend is more important than the specific companies.

One trend that I find extremely (and personally) troublesome is the migration from homegrown EMR’s to less functional Hospital based EMR’s – a migration that is occurring frequently now that most small practices are being purchased by Hospitals.

In our case, our small hospital administration decided unilaterally (without MD input) to implement a poorly designed EMR from it’s IT vendor. This has been a colossal failure, as none of the doctors were able to use the EMR. Hospitals are easily seduced by their IT vendors, and think that they can have only one software vendor. They think that all EMR’s are basically the same, either a Ford or a Chevy mentality. They don’t want the docs interfering with the decision process. They don’t have any idea of information and work flow in a doctor’s office. And now they are getting ARRA stimulus funds, and sometimes grant money from local endowments.

We doctors have asked that administration find us one practice that is successfully using the EMR they selected. I think they found 1 doctor 1,300 miles away who was able to make it tolerable. The hospital EMR is CHIT certified, so that doesn’t mean much. Hospital Software vendors have quickly tacked together some sloppy EMR’s in order to save their customer base, and have easily deceived administrators into buying these inferior products.

Our administration has pulled back from implementation, just having us use the scheduler, nursing putting in vitals/meds, and we just enter the ICD-9’s and charges. But another push to MU is coming soon. I have told admin that they must cut my daily schedule from 20 to 10 patients per day. I think that the ARRA stimulus funds and this whole Medicare push for EMR is having a negative effect so far, as least for me. I was using [EMR Vendor] (and still am unilaterally) to organize my data, and generate notes. It’s light years ahead of the EMR the software vendor selected.

I have heard my story repeated many times. The trend of Hospital owned practices may be inevitable, but it has severe negative consequences for EMR, in my opinion.

John’s Comments: While I don’t necessarily agree with the broad ranging comments about administrators not caring or listening to doctors, I’ve heard it far too many times to disagree completely. There’s little doubt from my experience that many hospitals don’t do a great job listening to doctors in selecting an EMR software. However, I’ve also seen many doctors who are terrible to work with when it comes to any discussion of an EMR. So, let’s not kid ourselves into thinking that the doctors are completely blameless either.

One important point that is made is that doctors like using EMR software that they select. As more and more hospitals acquire practices, this issue is going to come to a head. I won’t be surprised if it’s actually a major part of the reason that the cycle of independent doctors starts again.

Guest Post: Expect New Rules to Expand Notification – Current State of HIPAA Breach Notification

Posted on October 27, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.


Guest Blogger: Jan McDavid is General Counsel and Compliance Officer at HealthPort, a Release of Information and Audit Management Technology company. You can read more of Jan’s posts on the HealthPort blog.

The following is a 4 part series of blog posts on the HIPAA Breach Notification Rules.

It is widely expected that Health and Human Service (HHS) final disclosure rules will mandate notification be done in every case. Should this occur as predicted, additional patient education will be needed to avoid the concerns mentioned above.

Further complicating matters is the fact that hospitals must adhere to HHS rules AND those at the state level. State laws in some cases are more onerous than federal laws and they continue to morph. Just trying to stay on top of all the changes may be reason enough to disclose every instance of breached information. Whether it contains protected health information (PHI) or not, some states require patient notification in every instance of the inadvertent release of certain i.d. information.

In next week’s post, we’ll cover whether small breaches are still reportable.

Meaningful Use Attestation Issues for EHR Companies

Posted on October 26, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Many of you have probably read about the problems that GE Centricity EHR software had with a few of the meaningful use guidelines. If you haven’t read about it, go and check out that link to read Priya Ramachandran’s post about what happened. Plus, you can read a GE representative’s additional comments and clarifications. I actually had the chance to talk with GE in person at MGMA about these issues. While there’s no doubt that GE is taking heat for these problems (and they should), I personally believe it just highlights a bunch of possible problems with meaningful use attestation and raises a lot of unanswered questions.

My first premise is this, “If a large EHR vendor that’s intimately involved in the meaningful use rule creation process can mess up some of the meaningful use guidelines, how many other EHR vendors are going to do the same?”

This is a serious issue. Imagine you’re using an EHR software that runs into this problem. How quickly will that EHR vendor respond? Will they even know that they have an issue with meaningful use attestation before it’s too late? At least GE caught it early and can now address the issue for all of their doctors that are affected and get their EHR stimulus money. Even if they don’t get it resolved this year (which wouldn’t be a good outcome), then they do have next year which pays the same amount of money.

I’m not sure the same outcome will occur for some doctor who instead of proactively realizing a meaningful use attestation mistake gets “caught” with some mistake in some sort of meaningful use attestation audit. I guess we’ll see how those play out, but I imagine it won’t be as pleasant for MU attestation issues to be caught in an audit.

Plus, I think there’s very little doubt that there are other EHR companies which haven’t implemented the meaningful use attestation requirements quite right. I’m sure it’s just a matter of time before we hear of more issues. In fact, I have a feeling that EHR vendors that are reading this post are ready to forward it to their meaningful use expert/development staff to evaluate if they’re at risk for such a problem. The answer is that many EHR vendors likely are at risk. I imagine part of the risk is due to laziness in implementing the meaningful use guidelines (I guess they haven’t been reading our Meaningful Use Monday series), but the other part is that it’s not like meaningful use is that simple. It’s not quite the tax code, but it’s not always that straightforward.

This incident does bring up a whole new set of questions for CMS to answer. For example, what happens if a doctor attests to meaningful use and then realizes that for some reason (their fault, their EHR vendor’s fault or some other situation) they actually didn’t meet the meaningful use guidelines as required? Do they need to show another 90 days of meaningful use? Do they need to return their EHR stimulus check? Will CMS take the money back out of future payments? Can a physician go back and fix any mistakes that were made (this will likely depend on what went wrong)?

I’ll be keeping an eye on this discussion and we’ll do our best to post what GE and others learn from CMS when it comes to mistakes in meaningful use attestation. I have a feeling this could get a little messy. Based on my own experience with CMS in the past, I have a feeling they’re going to be as lenient as they possibly can be. However, they’re still going to have to follow whatever legal guidelines they’ve been given.

One other question that still makes me wonder is why didn’t the CCHIT EHR certification catch this mistake too? This would obviously require a pretty good dive into the EHR certification guidelines and the implementation of these guidelines. To me it highlights how little value the EHR certification process adds to the EHR market.

I have a feeling that this post has people like Dr. West enjoying their Meaningful Use Freedom even more.

The “Smart EMR” Differentiator

Posted on October 25, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

As I’ve been able to talk to more and more EMR companies I’ve been trying to figure out a way to differentiate the various EHR software. In fact, when I meet with EHR software companies I suggest that instead of them showing me a full demo of their EHR software, I ask them to show me the feature(s) that set their EHR apart from the other 300+ EHR companies out there. I must admit that it’s always interesting to see what they show me. Sometimes because what they show me isn’t that interesting or different. Many of my EMR company specific posts come from these experiences.

Today at MGMA as I went from one EHR company to another I started to get an idea for what might be the future differentiation between EHR companies. I’m calling it: “Smart EMR.”

You can be sure that I’ll be writing about my thoughts on Smart EMR software many more times in the future. However, the basic idea is that far too many EHR software are just basic translations from paper to electronic. Sure, some of them do a pretty good job of capturing the data in granular data elements (something not possible on paper), but that’s far from my idea of what a future Smart EMR software will need to accomplish.

I’m sure that many of those that are reading this post immediately started to think about the idea of clinical decision support. Certainly clinical decision support will be one important element of a Smart EMR, but I think that’s barely even the beginning of how a Smart EMR will need to work in the future. However, clinical decision support as it’s been described to date focuses far too much on how a clinician’s discretely entered data elements can support the care they provide. That’s far too narrow of a view of how an EMR will improve the patient-doctor interaction.

Without going into all the detail, EHR software is going to have to learn to accept and process a number of interesting and external data sources. One example could be all the data that a patient has in the PHR. Another could be patient data that was collected using personal various medical devices like a blood pressure cuff, an EKG, and blood glucose meters. Not to mention more consumer centric data devices and apps such as RunKeeper, Fitbit, sleep tracking, mood tracking, etc etc etc.

Another example of an external source could be access to some community health data repository. Why shouldn’t community trends in healthcare be part of the patient care process? None of this is far reaching since we’re collecting this data today and it will become more and more mainstream over time. Something we can’t do today, but likely will in the future is things like genomics. Imagine how personalized healthcare will change when an EHR will need to know and be able to process your genome in order to provide proper care.

I don’t claim to know all the sources, but I think that gives you a flavor of what a Smart EMR will have to process in the future. I’ll be interested to see which EHR software companies see this change and are able to execute on it. Many of the current innovations in EHR have been pretty academic. The Smart EMR I describe above will be much more complicated and require some specific skills and resources to do it right.

New Fujitsu Smart Scanner Combined with CDA Clinical Document Standard Make for Interesting HIE

Posted on October 24, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Today at MGMA, Fujitsu together with Osmosyz announced a new scanner that supports the relatively new CDA “Unstructured Document” HL7 standard at MGMA 2011. I must admit that the press release is a little intense. However, I find what they’re doing with a hardware product to support HIE is quite interesting.

I don’t want the title of this post to be misleading. While certainly HIE has generally become synonymous with some large health information exchange entity, in this case I’m describing a hardware device (a smart scanner if you will) that acts as a small health information exchange. Basically, it’s more along the lines of Direct Project as opposed to NHIN. Although, I imagine that it could send the documents to some larger health information exchange if someone wanted to do so.

The larger application I see of this technology is as a replacement for the fax machine. In some ways, it’s like a second generation fax machine. The major differentiation I see between a document sent using the CDA “Unstructured Document” HL7 standard and a fax is all the meta data that comes with the CDA document.

The fax or scanning workflow for most EHR software consists of receiving faxed documents or scanning documents into what amounts to basically a bucket of all the scanned documents. Then, it’s up to the user to go in and sort through all the various faxes that have been received or documents that have been scanned. At this point, the user can assign the document to a patient in the EHR. You can imagine the challenges that this can pose. I wonder how many documents scanned or faxed into an EHR have been assigned to the wrong patient accidentally.

That’s what makes this new Fujitsu scanner quite interesting. If it’s receiving the document from an outside source, it will come with the meta information for the document as part of the CDA standard. That can then be leveraged to more quickly assign that document to the patient. Not to mention, then all of that CDA information is available for other uses within the EHR.

For inside documents that are scanned in through the Fujitsu device you can actually assign the document to a patient on the scanner itself. That’s right, you can identify which patient a scanned document belongs to while you’re holding the document in your hand. A much better way to ensure that the document you scanned gets attached to the right patient in your EHR.

I’m just touching on a few of the features of what’s possible with this new Smart Scanner from Fujitsu and smart documents. You can do other things on the scanner like dividing document scans between multiple patients.

Meaningful Use Monday Angle
Of course, as most of you know, on Monday we usually do our regular Meaningful Use Monday series. Turns out that the CDA Clinical Document standard that I discuss above is being adopted by ONC as part of meaningful use. I’ll be interested to see how this plays out over time, but don’t be surprised if EHR software has to support this standard in the future.

What I find more intriguing is that the above scanner could be used by someone who doesn’t have an EHR, but wants to exchange patient information. I still think that the long term solution to interoperability of patient information has got to come from connections with EHR software. However, this does illustrate that technology solutions can and will be created to exchange health information. In fact, some combination of these solutions could be a way to meet some of the meaningful use requirements around exchange of health information. You still can’t get the EHR stimulus money without an EHR, but technologies like this could help you achieve meaningful use.

I’ll keep an eye on how this technology progresses. I wonder how many EHR vendors will integrate with this type of technology. Whether we like it or not, documents are going to be a major part of healthcare for the foreseeable future. We’ll see if smart documents and smart scanners are an intermediate step to the health information exchange nirvana (whatever that might be).

“The Freedom of No Meaningful Use Is Bliss”

Posted on October 23, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Today’s short Sunday post comes from Dr. West who blogs over at Happy EMR Doctor. The following comment was made on one of our Meaningful Use Monday posts.

“So glad I’m having nothing to do with the MU program. The freedom is bliss.”

I wonder how many other doctors share Dr. Wests view. Although, more interesting might be EHR users that are jealous of his view. Of course, the interesting thing in all this is that Dr. West is a real fan of EHR software and uses one in his practice. It’s just the government meaningful use requirements that he’s not doing.

Quantified Self Is the Future

Posted on October 20, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I know I’ve mentioned the quantified self a few times in the past. Basically quantified self is that we’re all going to start finding methods, apps, sensors, etc that will collect data about our bodies. I have never been more certain of this movement than I have been talking to the people at the Connected Health Symposium in Boston. It’s going to take a few years for all of the technologies to develop, but it’s going to happen.

A simple example of this is a startup company I met called Ubiqi Health. They have a migraine tracker that helps people to track their migraines and identify their cause. Plus, this is just their first integration. I think it’s really smart for them to work on migraines first. Lots of people have migraines and very few people have a problem admitting that they have a headache (or migraine). For some reason it’s socially acceptable to say you have a headache, but not so much to say you’re depressed for example.

One thing that’s also become clear is that it’s not just going to be devices that work to “quantify” someone. It’s going to be a great mix of devices, but also is going to have to include the narrative that a person provides. The interesting thing is that from the narrative you can often capture events that might have influenced the “disease” and also can explain the quantitative data.

This is going to be really interesting to watch. I’m still thinking about how all of this data is going to affect the doctors and how they treat patients. Either way, it’s going to transform the way we deal with “health care.”

Securing PHI Feels A Lot Like Y2K

Posted on October 19, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Seems like the comments being made on posts and being emailed to me have been really interesting lately. As I often like to do, I want to highlight those that provide interesting stuff in the comments since many people don’t read all the comments. Here’s one such comment from ip-doctor on my post about de-identified healthcare data.

I am interested in knowing how readers answer John’s question re position on use of de-identified data. My guess is that people don’t know it’s going on and will object to it happening in principle.

Securing PHI feels a lot like Y2K. No doubt breaches occur, and, when they do, they are certainly costly for the offending HCO, but how many examples are there of leaked information being used to harm someone? Seems like the same proscriptions vs. extortion, blackmail, and libel would prevent individuals from using illegally obtained PHI to harm patients.

In fact, the odds that there is a Person A who wishes to harm Person B AND who somehow comes up with Person B’s sensitive PHI AND is able to use it to harm Person B without Person B having ample legal recourse against Person A are hopelessly LONG. Breaches of thousands/hundreds of thousands/millions of records are too large and unspecific to be “used” for nefarious purposes.

We need to secure PHI, but we are hoisting ourselves on our own petards if we let legitimate concerns about the use of patient data block or slow our adoption of EMRs and HCIT for ACOs and PCMHs. Just as there are real benefits associated with use of de-id’ed patient data, there are (significant, hidden) costs with not sharing health data.

The irony here is that the most common, undeniably harmful use of sensitive PHI has been to deny coverage to patients with pre-existing conditions. Kind of makes sense. It is, after all, health information.

Nothing like sharing a post about the fears and challenges associated with sharing data and privacy and following up with a post that talks about how it might not be as big of a risk as many like to make it. Of course, the happy place is somewhere in the middle where we do a good job securing the data while as HIPAA outlines, we avoid placing an undue burden on patient care.