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Bad Boy EMR List, EMR Apology Letter, and Direct Primary Care

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I’ve always liked the idea of a bad boy EMR list. I’ve called it a meaningful EHR certification before. Or an EMR naughty and nice list. It’s a hard thing to do well…especially if you want to make a business of it.


I’ve posted a number of images lie this before. It’s always interesting to see what they say. This one actually looks like it’s trying to help them meet their MU patient engagement requirements as much as it’s trying to explain the EHR implementation delay. I’ve seen quite a few of these signs in hospitals I’ve visited. Getting patients signed up on the portal is a challenging thing for hospitals.


I need to dig into the direct primary care model a lot more, but it’s one of the really interesting alternative care models that’s worth watching.

August 3, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Eyes Wide Shut – Patient Engagement Pitfalls Prior to Meaningful Use Reporting Period

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July 1, 2015 – the start of the Meaningful Use Stage 1 Year 2 reporting period for the hospital facilities within this provider integrated delivery network (IDN). The day the 50% online access measure gets real. The day the inpatient summary CCDA MUST be made available online within 36 hours of discharge. The day we must overcome a steady 65% patient portal decline rate.

A quick recap for those who haven’t followed this series (and refresher for those who have): this IDN has multiple hospital facilities, primary care, and specialty practices, on disparate EMRs, all connecting to an HIE and one enterprise patient portal. There are 8 primary EMRs and more than 20 distinct patient identification (MRN) pools. And many entities within this IDN are attempting to attest to Meaningful Use Stage 2 this year.

For the purposes of this post, I’m ignoring CMS and the ONC’s new proposed rule that would, if adopted, allow entities to attest to Meaningful Use Stage 1 OR 2 measures, using 2011 OR 2014 CEHRT (or some combination thereof). Even if the proposed rule were sensible, it came too late for the hospitals which must start their reporting period in the third calendar quarter of 2014 in order to complete before the start of the fiscal year on October 1. For this IDN, the proposed rule isn’t changing anything.

Believe me, I would have welcomed change.

The purpose of the so-called “patient engagement” core measures is just that: engage patients in their healthcare, and liberate the data so that patients are empowered to have meaningful conversations with their providers, and to make informed health decisions. The intent is a good one. The result of releasing the EMR’s compilation of chart data to recently-discharged patients may not be.

I answered the phone on a Saturday, while standing in the middle of a shopping mall with my 12 year-old daughter, to discover a distraught man and one of my help desk representatives on the line. The man’s wife had been recently released from the hospital; they had been provided patient portal access to receive and review her records, and they were bewildered by the information given. The medications listed on the document were not the same as those his wife regularly takes, the lab section did not have any context provided for why the tests were ordered or what the results mean, there were a number of lab results missing that he knew had been performed, and the problems list did not seem to have any correlation to the diagnoses provided for the encounter.

Just the kind of call an IT geek wants to receive.

How do you explain to an 84 year-old man that his wife’s inpatient summary record contains only a snapshot of the information that was captured during that specific hospital encounter, by resources at each point in the patient experience, with widely-varied roles and educational backgrounds, with varied attention to detail, and only a vague awareness of how that information would then be pulled together and presented by technology that was built to meet the bare minimum standards for perfect-world test scenarios required by government mandates?

How do you tell him that the lab results are only what was available at time of discharge, not the pathology reports that had to be sent out for analysis and would not come back in time to meet the 36-hour deadline?

How do you tell him that the reasons there are so many discrepancies between what he sees on the document and what is available on the full chart are data entry errors, new workflow processes that have not yet been widely adopted by each member of the care team, and technical differences between EMRs in the interpretation of the IHE’s XML standards for how these CCDA documents were to be created?

EMR vendors have responded to that last question with, “If you use our tethered portal, you won’t have that problem. Our portal can present the data from our CCDA just fine.” But this doesn’t take into account the patient experience. As a consumer, I ask you: would you use online banking if you had to sign on to a different website, with a different username and password, for each account within the same bank? Why should it be acceptable for managing health information online to be less convenient than managing financial information?

How do hospital clinical and IT staff navigate this increasingly-frequent scenario that is occurring: explaining the data that patients now see?

I’m working hard to establish a clear delineation between answering technical and clinical questions, because I am not – by any stretch of the imagination – a clinician. I can explain deviations in the records presentation, I can explain the data that is and is not available – and why (which is NOT generally well-received), and I can explain the logical processes for patients to get their clinical questions answered.

Solving the other half of this equation – clinicians who understand the technical nuances which have become patient-facing, and who incorporate that knowledge into regular patient engagement to insure patients understand the limitations of their newly-liberated data – proves more challenging. In order to engage patients in the way the CMS Meaningful Use program mandates, have we effectively created a new hybrid role requirement for our healthcare providers?

And what fresh new hell have we created for some patients who seek wisdom from all this information they’ve been given?

Caveat – if you’re reading this, it’s likely you’re not the kind of patient who needs much explaining. You’re likely to do your own research on the data that’s presented on your CCDA outputs, and you have the context of the entire Meaningful Use initiative to understand why information is presented the way it is. But think – can your grandma read it and understand it on HER own?

June 30, 2014 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

Lack of Rec Support Cause of Meaningful Use Stage 2 Slowdown?

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By now, I imagine that most of you have read about the meaningful use stage 2 delay and EHR certification flexibility. The details and interpretation are still going on, but it’s a big change to the current meaningful use program. Although, the biggest question I hear asked is if the change leaves enough time for organizations to change course. I think the rule has to be open for 60 days of comment before it becomes final. We’ll see if that leaves people enough time.

We’ll see if this change will provide some relief to a meaningful use program that I described as on the ropes. In response to that post, Deborah Sherl, BSN, RN, CHTS, CHPS, made an interesting comment on a possible cause of the meaningful use stage 2

@ John Lynn…. of course I am slightly biased on the topic of the rapid response & deployment of Stage 1 vs Stage 2. A great amount of Stage 1 success was ushered in with the amazing assistance of professional consultants across the country for those EPs & EHs that were willing to use us…. and we were called the Regional Extension Centers Health IT workforce.

Now that the federal grant is done (Feb.2014) Stage 2 implementations are possibly stalled not only by overburdened EMR vendors, but lack of project management forces that were provided by the RECS. Many RECs have built sustainable business models but are no longer “free” services as was perceived while under the HITECH grant.

I find this a very interesting hypothesis. I’m not sure that it accurately reflects why many organizations chose not to attest to MU stage 2, but it certainly didn’t help things. In fact, it adds one more log to the already burning fire. Think about what happens with MU stage 2. We’re going to pay them less incentive money, require them to do substantially more, and oh yeah…those “free” REC support resources are now gone too. Plus, your EHR vendor may or may not be ready either.

I think the changes to the EHR Certification requirements and delay of meaningful use stage 2 are good. Although, I’m hoping this is just the start of HHS blowing up meaningful use and making it dramatically simpler and more meaningful.

May 21, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Did We Miss the Patient Engagement Opportunity with Meaningful Use?

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One of the most controversial parts of meaningful use is the requirement that a certain percentage of patients engage with the office. The argument goes that the doctor shouldn’t be rewarded or punished based on the actions of someone (the patients) they don’t control. Regardless of the controversy, the requirement remains that doctors have to engage with a certain number of patients if they want to get the meaningful use money.

I’m personally a fan of patient engagement and think there’s a lot of value that will come from more engagement with patients. This reminds me of Dr. CT Lin’s presentation and research on patient engagement. We need to find more ways to make patient engagement an easy reality in healthcare.

The problem I keep running into with the meaningful use patient engagement requirement is that meaningful use requires a certified EHR to meet that requirement. There are a whole suite of patient engagement apps that provide a useful and logical engagement between doctor and patient. However, none of them can be used to meet the meaningful use patient engagement criteria. Yes, I know the patient engagement app could become modularly certified, but that’s really overkill for many of these apps. It really doesn’t make any sense for them to be certified. The software doesn’t get better (and an argument can be made that the software becomes worse) if they become modularly certified as an EHR.

Because of this issue, the requirement basically relegates EHR vendors to implement some sort of after thought (usually) patient portal. Then, the doctors have to try and force patients to use a patient portal just to meet a requirement. Plus, many are “gaming” this patient engagement number in the way a patient signs up and engages in the portal.

Wouldn’t it be so much better to allow the patient engagement to happen on a non-certified EHR? Why does this need to happen on a certified EHR? EHR vendors aren’t focused on patient engagement, and so it shouldn’t be a surprise that they’re not creating amazing patient engagement tools. Think about how much more effective the patient engagement would be if it happened on a software that was working and thinking every day about how they can make that engagement work for the patient and the provider.

I’d love to see ONC make an exception on this requirement that would allow patient engagement to occur on something other than the certified EHR. I imagine if they did this, they could even raise the bar when it comes to what percentage of patients they should engage with electronically. If they don’t, we’ll have a bunch of lame duck patient portals that are really only used to meet the MU requirement. What a terrible missed opportunity that would be.

May 2, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Lack of 2014 Certified EHRs

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I was asked recently by an EHR vendor about the disconnect between the number of 2011 Certified EHR and the number of 2014 Certified EHR. I haven’t looked through the ONC-CHPL site recently, but you can easily run the number of certified EHR vendors there. Of course, there’s a major difference in the number of 2011 certified EHR versus 2014 certified EHR. However, I don’t think it’s for the reason most people give.

Every EHR vendor that gets 2014 Certified likes to proclaim that they’re one of the few EHR vendors that was “able” to get 2014 Certified. They like to point to the vast number of EHR that haven’t bridged from being 2011 Certified to being 2014 Certified as a sign that their company is special because they were able to complete the “more advanced” certification. While no one would argue that the 2014 Certification takes a lot more work, I think it’s misleading for EHR companies to proclaim themselves victor because they’re “one of the few” EHR vendors to be 2014 Certified.

First of all, there are over 1000 2014 Certified EHR products on ONC-CPHL as of today and hundreds of them (223 to be exact – 29 inpatient and 194 ambulatory) are even certified as complete EHR. Plus, I’ve heard from EHR vendors and certifying bodies that there’s often a delay in ONC putting the certified EHR up on ONC-CPHL. So, how many more are 2014 Certified that aren’t on the list…yet.

Another issue with this number is that there is still time for EHR vendors to finish their 2014 EHR certification. Yes, we’re getting close, but no doubt we’ll see a wave of last minute EHR certifications from EHR vendors. It’s kind of like many of you reading this that are sitting on your taxes and we’ll have a rush of tax filings in the next few days. It’s not a perfect comparison since EHR certification is more complex and there are a limited number of EHR Certification slots from the ONC-ATCB’s, but be sure there are some waiting until the last minute.

It’s also worth considering that I saw one report that talked about the hundreds (or it might have been thousands) of 2011 Certified EHR that never actually had any doctors attest using their software. If none of your users actually attested using your EHR software, then would it make any business sense to go after the 2014 EHR certification? We can be sure those will drop out, but I expect that a large majority of these aren’t really “EHR” software in the true sense. They’re likely modularly certified and add-ons to EHR software.

To date, I only know of one EHR software that’s comes out and shunned 2014 Certified EHR status. I’m sure we’ll see more than just this one before the deadline, but my guess is that 90% of the market (ie. actual EHR users) already have 2014 Certified EHR software available to them and 99% of the market will have 2014 certified EHR available if they want by the deadline.

I don’t think 2014 EHR certification is going to be a differentiating factor for any of the major EHR players. All the major players realize that being 2014 Certified is essential to their livelihood and a cost of doing business.

Of course, the same can’t be said for doctors. There are plenty of ways for doctors to stay in business while shunning 2014 Certified EHR software and meaningful use stage 2. I’m still really interested to see how that plays out.

April 11, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

The EHR Market Isn’t Like Other Markets

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Today at a healthcare IT meetup I attended in Dallas I ran into a former contact at an EHR vendor. He no longer works at that EHR company and has moved on to two other companies. In our discussion we had an interesting discussion about the market. Having moved on, he’d lost touch with the EHR market. He asked me, “Are there still 700 EHR vendors?” I told him there were probably 300, but I’ve contended that their have been 300 EHR vendors for a while. I’m not counting the hundreds of ancillary companies that are “certified EHR” but only perform 1-2 EHR related functions.

Over and over again I hear people talking about consolidation of EHR vendors. They say it’s going to happen and we’re going to get down to a really small number of EHR vendors. Some go as far as saying that there will be 2-3 EHR vendors after EHR consolidation happens.

I think this idea is ridiculous. At HIMSS, I figured out why I don’t think it’s going to happen. Someone told me, “Ambulatory healthcare is fragmented. It’s second only to florists when it comes to market fragmentation.”

This to me illustrates exactly why there can and will be so many EHR vendors. The ambulatory market is completely fragmented with thousands of really small businesses (ie. solo doc) doing just fine. Think about it. There are very few businesses that could survive at the size of a solo doctor practice. In every other industry, the businesses the size of a solo doc practice get eating up as the big boy competitors kill them with their buying power. The same can’t be said in healthcare. A solo doctor practice is a very viable business. Thus we see the market fragmentation and the plethora of EHR companies.

The above analysis does make you wonder why the solo doctor practice is still a viable business and if something in the future will make that option unreasonable from a business perspective. Although, that’s a subject for a future blog post.

Of course, when you think about the hospital EMR market there’s a much different story. We’ve seen EHR consolidation. The hospital market is much less fragmented and becoming less so every day. However, I’ll still be surprised if we go below 100 ambulatory EHR vendors.

March 18, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Eyes Wide Shut: Meaningful Use Stage 2 Incentive Program Hardships

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In my January update on Meaningful Use Stage 2 readiness, I painted a dismal picture of a large IDN’s journey towards attestation, and expressed concern for patient safety resulting from the rush to implement and adopt what equates to, at best, beta-release health IT. Given the resounding cries for help from the healthcare provider community, including this February 2014 letter to HHS Secretary Kathleen Sebelius, I know my experience isn’t unique. So, when rumors ran rampant at HIMSS 2014 that CMS and the ONC would make a Meaningful Use announcement, I was hopeful that relief may be in sight.

Like AHA , I was disappointed in CMS Administrator Marilyn Tavenner’s announcement. The new Stage 2 hardship exemptions will now include an explicit criteria for “difficulty implementing 2014-certified EHR technology” – a claim which will be evaluated on a case-by-case basis, and may result in a delay of the penalty phase of the Stage 2 mandate. But it does nothing to extend the incentive phase of Stage 2 – without which, many healthcare providers would not have budgeted for participation in the program, at all, including the IDN profiled in this series. So how does this help providers like mine?

Quick update on my IDN’s progress towards Stage 2 attestation, with $MM in target incentive dollars at stake. We must meet ALL measures; there is no opportunity to defer one. The Transition of Care (both populating it appropriately, and transmitting it via Direct) is the primary point of concern.

The hospital EHR is ready to generate and transmit both Inpatient Summary and Transition of Care C-CDAs. The workflow to populate the ToC required data elements adds more than 4 minutes to the depart process, which will cause operational impacts. None of the ambulatory providers in the IDN have Direct, yet; there is no one available to receive an electronic ToC. Skilled resources to implement Direct with the EHR upgrades are not available until 6-12 weeks after each upgrade is complete.

None of the 3 remaining in-scope ambulatory EHRs have successfully completed their 2014 software upgrades. 2 of the 3 haven’t started their upgrades. 1 has not provided a DATE for the upgrade.

None of the ambulatory EHRs comes with a Clinical Summary C-CDA configured out-of-the-box. 1 creates a provider-facing Transition of Care C-CDA, but does not produce the patient-facing Clinical Summary. (How did this product become CEHRT for 2014 measures?) Once the C-CDA is configured, each EHR requires its own systems integrator to develop the interface to send the clinical document to an external system.

Consultant costs continue to mount, as each new wrinkle arises. And with each wrinkle, the ability to meet the incentive program deadlines, safely, diminishes.

Playing devil’s advocate, I’d say the IDN should have negotiated its vendor contracts to include penalty clauses sufficient to cover the losses of a missed incentive program deadline – or, worst case scenario, to cover the cost of a rip-and-replace should the EHR vendor not acquire certification, or have certification revoked. The terms and conditions should have covered every nuance of the functionality required for Stage 2 measures.

But wait, CMS is still clarifying its Stage 2 measures via FAQs. Can’t expect a vendor to build software to specifications that weren’t explicitly defined, or to sign a contract that requires adherence to unknown criteria.

So, what COULD CMS and the ONC do about it? How about finalizing your requirements BEFORE issuing measures and certification criteria? Since that ship’s already sailed, change the CEHRT certification process.

1. Require vendors to submit heuristics on both initial implementation and upgrades, indicating the typical timeline from kick-off to go-live, number of internal and external resources (i.e., third-party systems integrators), and cost.
2. Require vendors to submit customer-base profile detailing known customers planning to implement and/or upgrade within calendar year. AND require implementation/upgrade planning to incorporate 3 months of QA time post-implementation/upgrade, prior to go-live with real patients.
3. Require vendors to submit human resource strategy, and hiring and training program explicitly defined to support the customer-base profile submitted, with the typical timeframes and project resource/cost profiles submitted.
4. Require vendor products to be self-contained to achieve certification – meaning, no additional third-party purchase (software or professional services) would be necessary in order to implement and/or upgrade to the certified version and have all CMS-required functionality.
5. Require vendor products to prove the CEHRT-baseline functionality is available as configurable OOTB, not only available via customization. SHOW ME THE C-CDA, with all required data elements populated via workflow in the UI, not via some developer on the back-end in a carefully-orchestrated test patient demo script.
6. Require vendor products adhere to an SLA for max number of clicks required to execute the task. It is not Meaningful Use if it’s prohibitively challenging to access and use in a clinical setting.

Finally, CMS could redefine the incentive program parameters to include scenarios like mine. Despite the heroic efforts being made across the enterprise, this IDN is not likely to make it, with the fault squarely on the CEHRT vendors’ inability to deliver fully-functional products in a timely manner with skilled resources available to support the installation, configuration, and deployment. Morale will significantly decline, next year’s budget will be short the $MM that was slated for further health IT improvements, and the likelihood that it will continue with Stage 3 becomes negligible. Vendor lawsuits may ensue, and the incentive dollar targets may be recouped, but the cost incurred by the organization, its clinicians, and its patients is irrecoverable.

Consider applying the hardship exemption deadline extension to the incentive program participants.

March 5, 2014 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

EHR Vendor Says Good Bye to Meaningful Use

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ComChart Medical Software, LLC president, Hayward K. Zwerling, MD, earlier this month posted a letter on The Health Care Blog saying that the ComChart EMR would no longer be meaningful use certified. Here’s a portion of the letter that describes the reasoning:

ComChart EMR will continued to be certified as a Complete EMR for Stage I Meaningful Use. Unfortunately, we will not be able to meet the Stage 2 (or greater) Meaningful Use certification requirements as these requirements are technically extremely difficult to implement.

In addition to the Meaningful Use mandates, there continues to be a never ending stream of new mandates such as ICD-10, PQRI, Meaningful Use 2, Meaningful Use 3, SNOMED, ePrescribing, LOINC, Direct Project, health information exchanges etc. As a result of the mountain of mandates, ComChart EMR and the other small EMR companies will have to choose to implement the mandates or use their resources to add “innovative” features to their EMR. Unfortunately, the small EMR companies do not have the resources to do both.

(I suspect this is also true, to some extent, for all EMR companies.)

While the individual people involved in promulgating these EMR mandates (mostly) have the best of intentions, they clearly do not understand what transpires in the exam room, as many of the mandated features confer little or no benefit to either the patient or the healthcare provider.

In addition to a lack of understanding of what is important during the process of providing healthcare, it has also become apparent to me that the Federal and State health information technology agenda is now largely driven by the strongest HIT companies and health institutions; the individual physician is only an afterthought in the entire process.

This choice basically means that anyone interested in meaningful use and EHR incentive money won’t be doing so with ComChart EMR. The regulations say that even someone attesting to meaningful use stage 1 in 2014 has to use a 2014 certified EHR. ComChart won’t be able to meet that requirement.

I knew that this was going to happen with a number of EMR vendors, but ComChart really missed a huge opportunity with this announcement. The most damning part of the letter is when Dr. Zwerling says “we will not be able to meet the Stage 2 (or greater) Meaningful Use certification requirements as these requirements are technically extremely difficult to implement.” I was aghast by this statement. So much so that I had a brief email exchange with Dr. Zwerling to see if he really meant what he said. Was it that they weren’t able to meet the requirements or that they chose not to meet them?

He responded, “Anything can be done, it is just a question of how much resources are going to be thrown at the problem and what is not going to get done return.”

It seems that Dr. Zwerling didn’t consult a PR or marketing person on how to make the most of this decision. Any of them would have told him that this decision could be a huge opportunity to differentiate the ComChart EHR from all the hundreds of certified carrot chasing EHR companies out there.

If Dr. Zwerling had asked me, I’d have told him that he should have said, “ComChart EHR has talked with our hundreds of physician end users about meaningful use and EHR certification and we’ve found that they don’t value any of the meaningful use criteria. Because of doctors desire to not be bogged down by meaningful use requirements, we’ve chosen to listen to our doctors and focus on what makes doctors lives easier. We’ll continue innovating our product to the needs of doctors, but we’ll be letting doctors drive that innovation versus some committee in Washington.”

I could keep going, but you get the idea. ComChart could have told every doctor out there that they were the ULTIMATE PHYSICIAN EHR that cares so much about the physicians who use their EHR that they’re shunning meaningful use because it’s detrimental to the way physicians should be practicing medicine. Making this case would not be hard and the message would resonate with the majority of physicians.

I’m not sure if this strategy would work or not. Government money that’s perceived as “free” is a hard opponent. However, government bureaucracy and headaches are an easy target that everyone understands and hates. In ComChart’s case, saying that they essentially aren’t capable of the complex meaningful use requirements is sending the wrong message. All doctors hear when they read this is that your EMR development team isn’t sophisticated or strong enough to keep up. What a missed opportunity and likely the nail in ComChart’s coffin!

Hopefully this is a warning message to any other EHR vendors who choose to go the route of shunning meaningful use and EHR certification. I’m not sure that shunning MU is a winning strategy for an EHR vendor, but being the physician advocate at least gives them a fighting chance.

December 30, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

EMR Vendors Struggle With Meaningful Use Stage 2

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CCHIT head Alisa Ray, clearly, is trying to put it delicately. EMR vendors are “struggling a little bit” when it comes to meeting 2014 criteria. “It  has been a slow start,” Ray told Healthcare IT News.

Usually, hearing this would lead to an inside baseball discussion of vendor operations, which wouldn’t be very exciting. But the thing is, meeting 2014 certification criteria is necessary to allow providers to meet Meaningful Use Stage 2. So vendor struggles in complying with CCHIT’s criteria should concern providers a great deal.

There are three areas of Stage 2 that are proving to be an issue for vendors: clinical quality measures, interoperability and automated measure calculation for reporting metrics, Ray said.

This has led to a real lag in certifications. About 40 companies had listed products with the CCHIT in 2011, but a scant 21 percent of those have stepped up and gotten certified in the 2014 criteria.

According to Ray’s chat with Healthcare IT News, “almost everyone has struggled and been surprised by the complexities” of meeting 2014 standards.  Despite having gone through the process yearly since 2006 with CCHIT, several have had to go through repeated certification trials to meet criteria.

ICSA Labs’ Amit Trivedi, meanwhile, noted that while there were close to 3,000 listings, with many having multiple listings — Cerner alone had 800 — so far there less than 300 on ONC’s Certified Health IT Products list.

There are signs that EMR vendors will catch up, the HIT story suggests. For example, vendors have been working particularly hard to offer Continuity of Care Documents or Direct messaging, a capability providers must demonstrate for Meaningful  Use Stage 2, said Matt Kohler, vice president of Network Infrastructure Services at Surescripts.

But vendors clearly have some serious development challenges ahead if they want to keep up with the pace set by Meaningful Use Stage 2.  If I were a provider reading this, I’d call my vendor right away and see where they were at in the certification process.

October 29, 2013 I Written By

Katherine Rourke is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Eyes Wide Shut – Managing Multi-EMR Meaningful Use Stage 2 Is Hard

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Most discussions on Meaningful Use (MU) seem to focus on a single healthcare provider organization (acute or ambulatory), with a single EMR, and a single Medical Record Number (MRN) pool generating unique patient identifiers. Even in that context, the complaints of the difficulties of successfully implementing the technology and obtaining the objectives are deafening. How daunting might those challenges seem, multiplied across a large integrated delivery network (IDN), attempting to make enterprise-wide technology and operational process decisions, in alignment with MU incentive objectives?

Imagine you are an IDN with 9 hospital facilities, sharing a single EMR. You also have 67 ambulatory practices, with 7 additional EMRs. You’ve made the progressive choice to implement a private health information exchange (HIE) to make clinical summary data available throughout the IDN, creating a patient-centric environment conducive to improved care coordination. To properly engage patients across the IDN and give them the best user experience possible, you’ve purchased an enterprise portal product that is not tethered to an EMR, and instead sources from the HIE. And because you’ve factored the MU incentive dollars into the budget which enabled these purchasing decisions, there is no choice but to achieve the core and select menu measures for 2014.

It is now October 2013. The first quarter you’ve chosen to gather Stage 2 attestation data starts on April 1, 2014. All your technology and process changes must be ready by the data capture start date, in order to have the best opportunity to achieve the objectives. Once data capture begins, you have 90 days to “check the box” for each MU measure.

Tech check: are all the EMRs in your IDN considered Certified Electronic Health Records Technology (CEHRT) for the 2014 measures?

Your acute EMR is currently 2 versions behind the newly-released MU 2014-certified version; it is scheduled to complete the upgrade in November 2013. Your highest-volume ambulatory EMR is also 2 versions behind the 2014-certified version, and it cannot be upgraded until March 2014 due to vendor resource constraints. Your cardiology EMR cannot be upgraded until June due to significant workflow differences between versions, impacting those providers still completing Stage 1 attestation. One of your EMRs cannot give you a certification date for its 2014 edition, and cannot provide an implementation date for the certified version. The enterprise portal product has been 2014-certified as a modular EMR, but the upgrade to the certified version is not available until February 2014.

Clearly, your timeline to successfully test and implement the multitude of EMR upgrades required prior to your attestation date is at risk.

Each EMR might be certified, but will it be able to meet the measures out of the box?

Once upgraded to the 2014 version, your acute EMR must generate Summary of Care C-CDA documents and transmit them to an external provider, via the Direct transfer protocol. Your ambulatory EMRs must generate Transition of Care C-CDA documents and use the same Direct protocol to transmit. But did you purchase the Direct module when you signed your EMR contract, or maintenance agreement?

Did you check to see whether the Direct module that has been certified with the EMR is also an accredited member of DirectTrust?

Did you know that some EMRs have Direct modules that can ONLY transmit data to DirectTrust-accredited modules?

You determine your acute EMR will only send to EMRs with DirectTrust-accredited modules, and that you only have a single ambulatory EMR meeting this criteria. That ambulatory EMR is not the primary target for post-acute care referral.

You have no control over the EMRs of providers outside the IDN, who represent more than 20% of your specialist referrals.

Your 10% electronic submission of Summary of Care C-CDA documents via Direct protocol measure is at risk.

Is your organization prepared to manage the changes required to support the 2014 measures?

This is a triple-legged stool consideration: people, process, and technology must all align for change to be effective. To identify the process changes required, and the people needed to support those processes, you must understand the technology that will be driving this change. Of all the EMRs in your organization, only 2 have provided product specifications, release notes, and user guides for their 2014-certified editions.

Requests for documentation about UI, data, or workflow changes in the 2014 versions are met with vague responses, “We will ask product management and get back to you on that.” Without information on the workflow changes, you cannot identify process changes. Without process change recognition, you cannot properly identify people required to execute the processes. You are left completely in the dark until such time as the vendors see fit to release not only the product, but the documentation supporting the product.

Clearly, your enterprise program for Meaningful Use Stage 2 health IT implementation and adoption is at risk.

What is the likelihood that your Meaningful Use Stage 2 attestation will be a successful endeavor for the enterprise?

As a program manager, I would put this effort in flaming red status, due to the multitude of risks and external dependencies over which the IDN organization has zero control. I’d apply that same stoplight scorecard rating to the MU Stage 2 initiative. There is simply too much risk and too many variables outside the provider’s control to execute this plan effectively, without incurring negative impacts to patient care.

The ONC never said Meaningful Use would be easy, but does it have to be this hard?

October 2, 2013 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.