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A Few Thoughts After AHIMA About the HIM Profession

Posted on September 30, 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 13 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.

This year was my 4th year attending the AHIMA Convention. There was definitely a different vibe this year at AHIMA than has been at previous AHIMA Annual Convention. I still saw the humble and wonderful people that work in the HIM field. I also still saw a passion for the HIM work from many as well. However, there seemed to be an overall feeling from many that they were evaluating the future of HIM and what it means for healthcare, for their organization, and for them personally.

This shouldn’t really come as a surprise. Think about the evolution that’s been happening in the HIM world. First, they got broadsided by $36 billion of stimulus money that slapped EHR systems in their organizations which questioned HIM’s role in this new digital world. Then, last year they got smashed by a few lines in a bill which delayed ICD-10 another year. It’s fair to say that it’s been a tumultuous few years for the HIM profession as they consider their place in the healthcare ecosystem.

While a little bit battered and scarred, at AHIMA I still saw the same passion and love for the work these HIM professionals do. I might add, a work they do with very little recognition outside of places like AHIMA. In fact, when EHR systems started being put in place, I think that many organizations wondered if they’d need their HIM staff in the future. A number of years into the world of EHRs, I think it’s become abundantly clear in every organization that the HIM staff still have extremely important roles in an organization.

While EHR software has certainly changed the nature of the work an HIM professional does, there is still plenty of work that needs to be done. We’d all love for the EHR to automate our entire healthcare lives, but it’s just not going to happen. In fact, in many ways, EHR software complicates the work that’s done by HIM staff. Remember that great HIM modules, features, and functions don’t sell more EHR software (more on that in future posts). Sadly, the HIM functions are often an afterthought in EHR development. We’ll see if that catches up with the EHR vendors.

As I’ve dived deeper into the life and work of an HIM professional, I’ve seen how difficult and detailed the job really can be. Not to mention, the negative consequences an organization can experience if they don’t have their HIM house in order. Just think about a few of the top functions: Release of Information, Medical Coding, Security and Compliance. All of these can have a tremendous impact for good or bad on an organization.

What is clear to me is that the HIM professional has moved well beyond managing medical records. If done well, the HIM functions can play a really important part in any healthcare organization. The challenge that many HIM professionals face is adapting to this changing environment. I see a number of real stand out professionals that are doing phenomenal things in their organization and really have an important voice. However, I still see far too many who aren’t adapting and many who quite frankly don’t want to adapt. I think this will come back to bite them in the end.

The Future of Healthcare IT Publishing

Posted on September 26, 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 13 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.

During today’s #HITsm chat, Karen DeSalvo joined the chat and asked what healthcare IT will be like in 2024. Brian Eastwood, Senior Editor at CIO.com, tweeted the following:


The topic was of interest to me as a health IT blogger myself. However, this was my response:


This of course led to Brian and I contributing to a series of possible 2024 Health IT Headlines we have to look forward to:

I’m pretty sure this wasn’t what Karen DeSalvo had in mind when she asked the question, but I thought it was fun to think about these possible headlines. Plus, I think there’s a fair amount we can learn from thinking about the future in this type of headline fashion. What do you think the healthcare IT headlines will say in 2024?

The Medication List Said, “Raised toilet seat daily”

Posted on September 25, 2014 I Written By

The following is a guest blog post by Lisa Pike, CEO of Versio.
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With over a third of healthcare organizations switching to a new EHR in 2014, there is a lot of data movement going on. With the vast amount of effort it took to create that data, it’s a valuable asset to the organization. It can mean life or death; it can keep a hospital out of the courtroom; and it can mean the difference between a smooth-running organization and an operational nightmare.

But when that important data needs to be converted and moved to a new EHR, you realize just how complex it really is.

During a recent conversion of legacy data over to a new EHR, we came across this entry in the Medication List:  Raised toilet seat, daily.

Uh, come again??

How about this one?  “Dignity Plus XXL [adult diapers]; take one by mouth daily.”  What does the patient have, potty mouth?

Now, while we may snicker at the visual, it’s really no joke. These are actual entries encountered in source systems during clinical data migration projects. Some entries are comical; some are just odd; and some are downright frightening. But all of them are a conversion nightmare when you are migrating data.

Patient clinical data is unlike any other kind of data, for many reasons. It’s massive. It requires near-perfect accuracy. It’s also extremely complex, especially when you are not just migrating, but also converting from one system “language” to another.

Automated conversion is a common choice for healthcare organizations when moving data from legacy systems to newly adopted EHRs. It can be a great choice for some of the data, but not all. If your source says “hypertension, uncontrolled,” but your target system only has “uncontrolled hypertension,” that’s a simple enough inconsistency to overcome, but how would you predict every non-standard or incorrect entry you will encounter?

Here are some more actual examples. If you’re considering automated conversion, consider how your software would tangle up over these:

SOURCE SYSTEM SAYS COMMENTS
346.71D  Chm gr wo ara w nt wo st ???
levothyroxine 100 mg Should be mcg. Yikes!
Proventil Target system has 20 choices
NKDA (vomiting) NKDA= no known drug allergies.
Having no allergies causes vomiting?
Massage Therapy, take one by mouth twice weekly ???
Tylenol suppositories; take 1 by mouth daily Maybe not life-threatening, but certainly unpleasant
PMD
(Pelizaeus-Merzbacher disease)
Should have been PMDD
(premenstrual dysphoric disorder)
Allergy:  Reglan 5 mg Is patient allergic only to that dosage, or should this have been in the med list?
Confusing allergies and meds can be deadly.
Height 60 Centimeters or inches? Convert carefully!

 

These just scratch the surface of the myriad complexities, entry errors, and inconsistencies that exist in medical records across the industry. No matter how diligent your staff is, I guarantee your charts contain entries like these!

When an automated conversion program encounters data it can’t convert, it falls out as an “exception.” If the exception can’t be resolved, the data is simply left behind. Even with admirable effort, almost no one in the industry can capture more than 80% of the data. Some report as low as 50%.

How safe would you feel if your doctor didn’t know about 20% of your allergies? What if one of those left behind was the one that could kill you? What if a medication left behind was one you absolutely shouldn’t take with a new medication your doctor prescribed? Consider the woman whose aneurysm history was omitted during a conversion to a new EHR, so her specialist was unaware of it. She later died during a procedure when her aneurysm burst. I would say her family considered that data left behind pretty important, as did the treating physician, who could be found liable.

Liable, you say?

That’s right. The specialist could be found liable for the information in the legacy record because it was available….even if it was archived in an old EHR or paper chart.

You can begin to see the enormity of the problem and the potentially dangerous ramifications. Certainly every patient deserves an accurate record, and healthcare providers’ effectiveness, if not their very livelihood, depends on it. But maintaining the integrity of the data, especially during an EHR conversion, is no trivial task. Unfortunately, too many healthcare organizations underestimate it, and clearly it deserves more attention.

There is good news, however. With a well-planned conversion, using a system that combines robust technology with human expertise, it is possible to achieve 100% data capture with 99.8% accuracy. We’ve done it with well over a million patient chartsIt isn’t easy, but the results are worth it. Patients and doctors deserve no less.

Lisa Pike is the CEO of Versio, a healthcare technology company specializing in legacy data migration, with a proven track record of 100% data capture and 99.8% quality. We call it “No Data Left Behind.” For more information on Versio’s services or to schedule an introductory conversation, please visit us at www.MyVersio.com or email sales@myversio.com.

What Healthcare Must Plan for in Q4

Posted on September 19, 2014 I Written By

The following is a guest blog post by Ben Quirk, CEO of Quirk Healthcare Solutions.
Ben Quirk
In some ways, 2014 turned out to be not quite as cataclysmic. The early announcement of delaying the adoption of ICD-10 and the more recent announcement to allow hospitals/CAHs and Eligible Professionals participating in CMS’ Meaningful Use programs to attest using their existing Certified Electronic Health Record Technology (CEHRT) took the pressure off healthcare providers scrambling to upgrade their CEHRT to a version that was both ICD-10 and MU-compliant. However, this is only a temporary reprieve through the end of 2014 and there are other priorities that must be addressed before the year ends.

Navigating the ever-evolving healthcare environment will seem much less daunting if you focus on these four areas:

  • Meaningful Use
  • Value-Based Payment Modifiers
  • Transparency
  • Open Enrollment for ACA

Meaningful Use (MU)

If you were not able to upgrade to the 2014 Edition EHR, you will still be able to attest for MU using 2013 criteria. This provides reprieve from the 2014 criteria that requires the implementation of and patient enrollment in a patient portal.

In order to be MU-ready, your organization must proactively:

  • Determine your strategy based on the final rule. Gather data and be prepared to attest for MU by the deadline for the MU program you participate in..
  • Create an audit binder which should include screenshots of required EHR configuration during the reporting period. Should you get an audit 2 years from now, you can refer to this binder for accurate information.
  • Prepare a statement citing why you should be allowed to opt out of those MU measures that you think do not pertain to your practice. Auditors will ask for this on any audit preformed.

All organizations should be prepared to start collecting data for MU 2 by January 1, 2015. This includes having a strategy around the implementation of a patient portal and patient enrollment, sharing data amongst community and other healthcare providers, and radiology interfaces.

Value-Based Payment Modifier

The current Value Based Payment Modifier for providers who serve Medicare beneficiaries is a descendent of the Physician Quality Reporting System (PQRS). It is a way to keep the ACA cost-neutral, but there are some important things you need to know about this newer system. Value-Based Payment Modifier takes claims, Meaningful Use, and physician quality data and rates the quality of care you provide against your peers. Consequently,

  • When you report your Clinical Quality Measures or any clinical data to CMS, make sure your thresholds demonstrate that your practice is providing high quality care.
  • If your practice suffered from vendor problems with data accuracy in the past, this should be fixed.

Transparency

Transparency is something all providers should be aware of. Although available only in a few markets right now, all patients will soon be able to look up information about physicians before deciding where they would like to have their medical procedures done. For instance, if a patient decides to have an ACL repair, s/he can go online to compare exact costs and quality measures (based on the Patient Quality Reporting System) for ACL repair. Practices need to be aware that their prices and quality are being reported publicly. The implications go beyond losing reimbursement. You can actually be delisted from an insurance network. To ensure that your practice remains a viable option for patients:

  • Market your own practice and post your own prices.
  • Make sure you are reporting good quality data.
  • Use sources such as MGMA or OPTUM to see what providers in your area are charging and how you compare.
  • Determine how your reimbursement ranks vs. your competitors on the Medicare website and ensure data accuracy.

Open Enrollment for the ACA

November 15 marks the beginning of the second Open Enrollment period for the Affordable Care Act and there is no indication that this time around will be any easier than the first. Patients will be choosing plans, dealing with things very unfamiliar, and perhaps unaffordable, to them, like deductibles. This directly impacts clinics and the bottom line, especially with those patients who cannot pay their share of the costs. Last year, patients became the number one payor for many practices, even more than insurance companies, because so much revenue came from deductibles. That all resets January 1, but there are things you can do to avoid a possibly painful Q1 of 2015:

  • Check and confirm all patients’ eligibility, what plan they are on, and what their deductible is prior to their scheduled appointment, preferably through an automatic batch eligibility service. Keep this information in the practice management system.
  • Notify patients about their deductibles before they come into the clinic, and make sure to collect payments upfront, or keep a card on file.

The healthcare industry as we knew it for the past many years has ceased to exist. As we move into a new era of integrated delivery systems and a greater emphasis on value-based rather than volume-based reimbursements, the industry is going to remain in a state of flux before it stabilizes once again. The only way organizations are going to survive in this shifting landscape is by anticipating and planning for the next change so that they can stay ahead of the curve. The more an organization knows, the better it can be prepared to confront any potentially negative impact of the ever-evolving nature of the industry.

About Ben Quirk
Ben Quirk is CEO of Quirk Healthcare Solutions, a consulting firm specializing in EHR strategic management, workflow optimization, systems development, and training. The company’s clients have enjoyed remarkable success, including award of the Medicare Advantage 5-star rating. Quirk Healthcare presents a weekly webinar series, Insights, to inform clients and the general public about government programs and industry trends. Mr. Quirk is also Executive Director of the Quirk Healthcare Foundation, a learning institution which fosters innovation in the healthcare industry.

What If Meaningful Use Were Created by Doctors?

Posted on September 17, 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 13 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.

It’s safe to say that meaningful use is growing through its challenges right now. My post yesterday about killing meaningful use and the new Flex-IT Act should be illustration enough. While it’s easy to play Monday Morning Quarterback on meaningful use, I think it’s also valuable to consider what meaningful use could have been and then use that to consider how we can still get there from where we are today.

Many of you might have read my post on The Purpose of the EHR Incentive Program Accordign to CMS. CMS clearly stats that the purpose of the EHR incentive money and meaningful use is to move providers towards advanced use of health IT to:

  • Support Reductions in Cost
  • Increase Access
  • Improve Outcomes for Patients

This has very clearly been CMS’ goal and it’s reflected in what we now know today as meaningful use. Let’s think about those from a physician perspective.

Support Reductions in Cost – So, you’re going to pay me less for doing the same work?

Increase Access – So, you’re going to send me patients who can’t pay their bill? Or does this mean I have to do more work making my records accessible?

Improve Outcomes for Patients – Every doctor can support this. However, many are skeptical (with good reason) that the various elements of meaningful use really do improve outcomes for patients.

If I were to step back and think what a doctor might consider meaningful use of an EHR system, this might be what they’d list (in no particular order):

  • More Efficient
  • Improved Care
  • Increased Revenue

More Efficient – Will the technology help me see patients more efficiently? Will it allow me to spend more time with the patient?

Improved Care – Will the technology help me be a better doctor? Will the technology help me make better use of my time with the patient?

Increased Revenue – Will the technology help me get paid more? Will the technology lower the cost of my malpractice insurance and reduce that risk? Will the technology create new revenue streams beyond just churning patient visits?

I’m sure there are other things that could be listed as well, but I think the list is directionally accurate. When you look at these two lists, there’s very clearly a major disconnect between what end users want and what meaningful use requires. With a lot of the EHR incentive money already paid out, this divide has become a major issue.

Killing Meaningful Use and Proposals to Change It

Posted on September 16, 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 13 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.

Isn’t it nice that National Health IT Week brings people together to complain about meaningful use? Ok, that’s only partially in jest. Marc Probst, CIO of Intermountain and a member of the original meaningful use/EHR Certification committee (I lost track of the formal name), is making a strong statement as quoted by Don Fluckinger above.

Marc Probst is right that the majority of healthcare would be really happy to put a knife in meaningful use and move on from it. That’s kind of what I proposed when I suggested blowing up meaningful use. Not to mention my comments that meaningful use is on shaky ground. Comments from people like Marc Probst are proof of this fact.

In a related move, CHIME, AMDIS and 15 other healthcare organizations sent a letter to the HHS Secretary calling for immediate action to amend the 2015 meaningful use reporting period. These organizations believed that the final rule on meaningful use flexibility would change the reporting period, but it did not. It seems like they’re coming out guns blazing.

In even bigger news (albeit probably related), Congresswoman Renee Ellmers (R-NC) and Congressman Jim Matheson (D-UT) just introduced the Flexibility in Health IT Reporting (Flex-IT) act. This act would “allow providers to report their Health IT upgrades in 2015 through a 90-day reporting period as opposed to a full year.” I have yet to see any prediction on whether this act has enough support in Congress to get passed, but we could once again see congress act when CMS chose a different course of action like they did with ICD-10.

This story is definitely evolving and the pressure to change the reporting period to 90 days is on. My own personal prediction is that CMS will have to make the change. I’d love to hear your thoughts.

Happy National Health IT Week!

RACs’ Limited Restart and Partial Payment Window Opens

Posted on September 15, 2014 I Written By

The following is a guest blog post by Dawn Crump, VP of Audit Management Solutions at HealthPort.
Dawn Crump - HealthPort
The RACs are back and they’re offering acute care and critical access hospitals a sweet deal—at least for now.

The Recovery Audit Contractor (RAC) program had been on hold due to the reassigning and re-contracting of regions. In addition, there was a lawsuit pending between Centers for Medicare and Medicaid Services (CMS) and CGI over RAC reimbursement rates, models and approaches. The lawsuit was resolved in August. But CGI quickly appealed causing further delay in full resumption of the RAC program.

So while everyone awaits another court decision and green light from CMS, two important RAC announcements were made by CMS.

  • A “limited” restart of the RAC program began in August, 2014, including a restricted number of claim reviews and service targets.
  • Some claims currently pending appeals of inpatient-status claim denials by RACs may be eligible for a partial payment settlement.

Limited Restart Underway

Until the RAC program is 100 percent back in session, some reviews will be conducted. These will be mostly automated reviews, but there will be some records requests and a limited number of complex reviews in certain select areas. During the restart, RACs will not review claims to determine whether the care was delivered in the appropriate setting. CMS said it hopes that the new RAC contracts will be awarded later this year.

From the Aug. 5 edition of the American Hospital Association’s News Now: “CMS will allow current RACs to restart a limited number of claim reviews beginning this month. The agency said most reviews will be done on an automated basis. However, a limited number will be complex reviews on certain claims, including spinal fusions, outpatient therapy services, durable medical equipment, prosthetics, orthotics and supplies, and Medicare-approved cosmetic procedures.

One example of the latter is blepharoplasty, also known as an eyelid lift. The number of claims for this procedure has tripled in recent years, so I expect the RACs will make this procedure a hot target. To be covered under Medicare, vision must be impaired. What’s needed? Physician documentation of the reasons for surgery (e.g., eyelid droop interfering with vision).

Here are three specific steps to take with regard to the limited RAC restart:

  • Stay abreast of all RAC news and announcements and remain diligent in communicating with your regional peers regarding new RAC region assignments, contacts and educational opportunities.
  • Conduct an internal probe to ensure you’re following all of Medicare’s National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs).
  • Educate coders, billers and physicians around documentation, coding and billing for specific targets as mentioned above.

But the limited restart wasn’t the only important news.

Partial Repayment Deal Announced

In their September 9th, 2014 inpatient hospital reviews announcement, CMS announced an administrative agreement for acute care and critical access hospitals.  To reduce the backlog of cases in appeal status and overall administrative costs, these hospitals now have the option to withdraw their pending appeals in “exchange for timely partial payment (68% of the allowable amount)”, according to the CMS administrative agreement.

Of course there are parameters to understand and details to sort out regarding the settlement opportunity. Here is what we know so far:

  • Only acute care and critical access hospital claims are eligible.
  • Claims must already be in the appeals process for inpatient-status claims with an admission date prior to October 1, 2013.
  • Services might have been found reasonable and necessary by the Medicare contractor, but treatment as an inpatient was not.
  • Hospitals may choose to settle some claims and continue to appeal others.
  • Hospitals should send their request for settlement to CMS by October 31, 2014.

Many more details are available on the CMS.gov website.

Settle….Or Not?

Eligible hospitals must determine if requesting a settlement offer makes sense for cases in appeal that meet the specified parameters. For some cases, it will make sense to take the 68 percent settlement and cut your losses. For other denials, waiting out the appeal process may be a better choice.

Each denial will be different and each case unique. Time, money and resources must be balanced against the potential revenue retained or returned potential. Audit management directors, in conjunction with their revenue cycle and finance teams, must analyze RAC data for each eligible case.  It’s a complicated equation. And with a deadline of October 31, 2014, there is no time to lose.

About Dawn Crump

Dawn Crump, MA, SSBB, CHC, has been in the healthcare compliance industry for more than 18 years and joined HealthPort in 2013 as Vice President of Audit Management Solutions. Prior to joining HealthPort, Ms. Crump was the Network Director of Compliance for SSM. She is a former board director of the Greater St. Louis Healthcare Finance Management Association chapter and currently serves as the networking chair.

EHR Certification Flexibility Final Rule Commentary and Analysis

Posted on September 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 13 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 news came out late on Friday that the EHR Certification flexibility was published as a final rule. I covered my initial take on the EHR Certification Flexibility on Hospital EMR and EHR. I’ve now had a chance to dig through the delicious 90 pages of government rule making and comments that make up the final rule. For those following along at home, you can skip to page 10 of the document to start the fun read. Although, I’ll also direct you to specific sections that might be of interest to you below.

In this post, I’ll just cover the EHR certification flexibility. You can see the meaningful use extension and delay timelines here. Here’s the important chart when talking about the EHR Certification flexibility (CMS Calls it CEHRT):
2014 EHR Certification Flexibility - CEHRT

The EHR Certification flexibility has a number of major talking points:

  • What Does “unable to fully implement” and “2014 Edition CEHRT availability delays” mean?
  • Fairness of EHR Certification Flexibility
  • 90 Day Reporting Period in 2015 Instead of 365 Days
  • Future Audits

What Does “unable to fully implement” and “2014 Edition CEHRT availability delays” mean?
On page 62 of the rule is the best description of the rule’s intent. It says that if you want to take advantage of this EHR flexibility, then they (Eligible providers or hospitals) “must attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to the meaningful use objectives and measures.” This basically covers the asterisk in the chart above.

This piece of the rule was so unclear that CMS in the final rule used 12 pages (pg. 36-48) to describe when this rule would apply and when it would not apply. CMS tried to make this apply as broadly as possible, but I think they also wanted to encourage as many organizations as possible to not use the exception.

My short summary of these 12 pages is: If you have the 2014 Certified EHR software and can attest to meaningful use stage 2, then you better go ahead and do it. Trying to find a loophole that allows you to avoid meaningful use stage 2 and just do MU stage 1 puts you at risk during a future meaningful use audit.

Of course, if you’re EHR vendor hasn’t provided you the proper software/updates/training, etc that you require to attest to meaningful use stage 2, then this rule will apply. CMS’ intent seems pretty clear. If you can attest to meaningful use stage 2, then you should. However, if your EHR vendor prevents you from being able to attest, then they don’t want to hold the providers accountable for the EHR vendors failure. Although, CMS notes multiple times in the final rule that they don’t want to point blame at the EHR vendors since it could have been other outside issues (ie. final rule was late, ONC-ACB’s were backlogged, etc) that caused the EHR vendors to not be ready.

I wonder if one of the unintended side effects of this rule will be EHR vendors taking their sweet time releasing and rolling out their 2014 Certified EHR product and updates. It’s too late for this in the hospital setting since hospitals have to do a full year of MU 2 on a 2014 Certified EHR starting October 1, 2014. However, the same might not be true on the ambulatory side where they have until the end of the year to start on meaningful use stage 2.

I’ll be interested to see how many organizations are able to take advantage of this delay. Had this rule been finalized in early 2014, it would be a very different story. However, at this late date, I’m not sure that many providers or hospitals will be able to change course.

I mostly feel bad for those organizations that rushed their EHR implementations onto barely-beta-tested 2014 Certified EHR software and will now have no choice but to go forward with meaningful use stage 2. This change in rule makes many of these organizations wish they’d slowed their implementation to make sure they’d done it right and they’d have also only been required to do MU stage 1.

Fairness of EHR Certification Flexibility
The last paragraph above highlights part of the reason why many providers feel that this EHR certification flexibility is unfair. While it’s not a direct penalty on organizations that were on top of things, the change rewards those organizations that didn’t take the risks, push their EHR vendors, and push their implementation timelines to meet the MU stage 2 requirements. The reward an organization gets for going after MU stage 2 is that they have to do a lot more work (Yes, MU2 is A LOT more work) while their procrastinating competitors get to do the much simpler MU1.

This was such an important complaint that CMS addressed these comments in two different places in the final rule (pg. 21-22 and pg. 48-50). CMS tries to argue that in their research they didn’t see providers that were deliberately trying to delay MU stage 2, but found that providers wanted to do MU stage 2, but their EHR vendors weren’t ready. I’d suggest that CMS may want to dig a little deeper.

However, let’s set providers aside for now and assume that they all want to do MU stage 2, but their EHR vendors just aren’t ready for it. This EHR certification flexibility still lets EHR vendors who procrastinated their 2014 EHR certification off the hook. In fact, it rewards them and their users for not performing well. Once again, CMS doesn’t want to point the finger at EHR vendors, but will blame themselves for not finalizing the rule fast enough and ONC-ACB’s for having a backlog. However, if you’re an EHR vendor who’s been 2014 Certified for a while now, no doubt this rule makes you angry since it rewards your competitors in a big way (intended or otherwise).

Certainly there are a lot of reasons why an EHR vendor isn’t yet ready to be 2014 Certified. However, most of them have little to do with the rule making process and the EHR certification backlog. Some freely admit it, and others hide behind excuses. I think CMS realized this EHR Certification flexibility would benefit these EHR vendors, but they didn’t want to punish the providers who use these EHR software.

I still think the simple solution here was to extend this same flexibility to all providers and all EHR vendors. However, in the final rule CMS argues that doing so would reduced the amount of meaningful use stage 2 data that they’d have available to make the adjustments needed to meaningful use stage 3. I understand how a provider doing MU stage 2 this year might feel like the government’s guinea pig. We need you to do MU stage 2 so we can figure out how to make it right in MU stage 3. CMS also argues that they need more people on meaningful use stage 2 in order to push their agenda and the intent of the HITECH act forward. What doesn’t seem aligned to me is the goals of meaningful use and providers’ goals. I think that’s why we see such a disconnect.

90 Day Reporting Period in 2015 Instead of 365 Days
This seems to be one of the most heated discussion points with the final rule. CHIME President and CEO, Russell P. Branzell, even suggested that “Now, the very future of Meaningful Use is in question.”

CMS’ comments about this (pg. 34-36) basically say that a change to the EHR reporting periods was not part of this proposed rule. Then, they offered this reason for why they’re not considering changes to the reporting periods:

We are not considering changes to the EHR reporting periods for 2015 or subsequent years in this final rule for the same reasons we are not considering changing the edition of CEHRT required for 2015 or subsequent years. Changes to the EHR reporting period would put the forward progress of the program at risk, and cause further delay in implementing effective health IT infrastructure. In addition, further changes to the reporting period would create further misalignment with the CMS quality reporting programs like PQRS and IQR, which would increase the reporting burden on providers and negatively impact quality reporting data integrity.

What this comment doesn’t seem to consider is what will happen if almost no organizations choose to attest to meaningful use because of the 365 day reporting period. Talk about killing the “forward progress” of the program. From a financial perspective, maybe that’s great for the MU program. CMS will pay out less incentive money and they’ll make back a bunch more money in the eventual penalties. However, it seems counter to the goal of increasing participation in the program. Personally, I’m not sure that the end of organization’s participation in meaningful use would be such a bad thing for healthcare. It would lead back to a more rationale EHR marketplace.

Future Audits
On page 55-56, the final rule addresses the concerns over audits. We can be sure that some organizations will be audited on whether they were “unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays.” Sadly, the final rule doesn’t give any details on what documentation you should keep to illustrate that you meet these requirements for which you will have to attest. The final rule just says that they’ll provide guidance to the auditors on this final rule and that audit determinations are finalized on a case by case basis that will cover the varied circumstances that will exist.

This wouldn’t give me much comfort if I was going through an audit. Not to mention comfort that the auditors wouldn’t interpret something differently. I’ll defer other audit advice to my auditor friends, since I’m not an audit expert. However, in this case you likely know how far you’re stretching the rule or not. That will likely determine how comfortable you’ll be if an audit comes your way. Now you can see why my advice is still, “If you have the 2014 Certified EHR software and can attest to meaningful use stage 2, then you better go ahead and do it.

Conclusion
I really see the meaningful use program on extremely shaky ground. I don’t think this final rule does much to relieve any of that pressure. In fact, in some ways it will solidify people’s bad feelings towards the program. We’ll see for sure how this plays out once we see the final numbers on how many organizations attest to meaningful use stage 2. I don’t think those numbers are going to be pretty and 2015 could even be worse.

Note: For those following along at home (or work), here’s the final rule that I reference above.

Healthcare IT Career Resources

Posted on August 26, 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 13 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.

About 10 months ago, we added Healthcare IT Central to the Healthcare Scene family of healthcare IT websites. It’s been a really amazing addition to the network and I’ve been amazed at the thousands of people that have been able to find health IT jobs thanks to Healthcare IT Central. I love blogging because you get the direct interaction with readers, but there’s a really amazing feeling that comes when you play some small role in helping someone find a job.

The other great part about the addition of Healthcare IT Central is the related Healthcare IT Today career blog. If you’re not reading that site, we just added it to our Healthcare Scene email subscription lists so you can receive the latest posts in your email inbox.

Just to give you a little flavor of the type of content we’ve been posting on Healthcare IT Today, we asked the questions, “Has There Been an EHR Consulting Slow Down?” and “Who’s More Satisfied – Full Time Health IT Professionals or Health IT Consultants?” Plus, we even posted really interesting data like a look at the Epic Salary and Bonus structure. Then, since it is a healthcare IT career website, we cover things like LinkedIn tips and LinkedIn as a professional or personal profile.

If you’re someone looking for a healthcare IT job or looking for a better healthcare IT job, we have hundreds of health IT jobs available. You might also check out Cordea Consulting, ESD, and Greythorn that recently posted jobs with us.

If those jobs aren’t your style we have other jobs like this Sales Account Executive at EHR vendor, gMed, or these system analyst jobs at Hathaway-Sycamores Child Family Services and Pentucket Medical.

If you’re an employer looking for amazing healthcare IT professionals, you can register for the site and post your jobs or search our database of over 12,000 active health IT resumes.

Hopefully some of these health IT career resources are helpful to readers of EMR and HIPAA. One thing that’s universal in healthcare is the need to find a job or hire the right talent. Hopefully we’re doing are part to help both sides of the coin.

Can a Client Server EHR Provide All the Same Benefits of Cloud EHR?

Posted on August 25, 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 13 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.

One of the most popular battles discussions we’ve had on this site since the beginning is around client server EHR software versus cloud EHR software. It’s a really interesting discussion and much like our US political system, most people fall into one camp or the other and like to see the world from whatever ideology their company approaches.

The reality I’ve found is that there are pros and cons to each side. Certainly cloud has won out in most industries, but there are some compelling reasons why cloud hasn’t taken hold in many parts of healthcare.

With that in mind, a client server EHR vendor asked me to list out the reasons why someone should go with a Cloud EHR over client server. Here’s my off the cuff responses:

No IT Support Needed beyond desktop support – This is a big benefit that many like. Plus, they add in the cost of the server, the cost of the local IT person and so they see it as a huge benefit to go with cloud software

Automatic Updated Software – Not always true with the cloud, but they like that the software just updates and they don’t have to go around updating software. Of course, this also has its downsides (ie. when an update happens automatically and breaks something)

Small Upfront Cost – Most Cloud solutions are billed on a monthly charge with little to no upfront cost. We could argue the accounting pieces of this and whether it’s really any better, but it feels better even if many cloud providers require the 1-2 year commitment. In some large organizations this type of payment plan is better for their accounting as well (ie. depreciation of equipment, etc)

More Secure – Obviously this could be argued either way, but those that believe cloud is more secure believe that a cloud provider has more resources and expertise to make their cloud secure vs an in house server where no one might have expertise

More Reliable (backup/disaster recovery) – Similar to the secure argument as far as expertise and ability to provide this reliability

Single Database – There are cool things you can do with data when every doctor is on one database and one standard data structure.

Available Everywhere – At home, office, hospital, etc. (Yes, this can be done by many client server as well, but not usually with the same experience).

I’m sure that a cloud EHR provider could add to my list and I hope they will in the comments. As I was making the list, I wondered to myself if a client server EHR vendor could provide all of the benefits listed above. Let me go through each.

No IT Support Needed beyond desktop support – Some EHR vendors will do all the IT support for the user. Plus, it’s a little bit of a misnomer that you need no IT support with a cloud hosted EHR. You still need someone to service your network and computers. More importantly though, most client server EHR vendors are offering a hosted EHR option which basically provides this same benefit to a practice.

Automatic Updated Software – More and more client server vendors are moving to this approach for updates as well. This is particularly true when they offer a hosted EHR environment where they can easily update the EHR. It’s a different mentality for client server EHR vendors, but it can be done in the client server environment.

Small Upfront Cost – We’ve seen this same offer from almost all of the client server EHR companies. It’s a hard switch for EHR companies to make the change from large up front payments to reoccurring revenue, but I’m seeing it happening all over the industry. The only exception might be the big hospital EHR purchase. In the ambulatory EHR market, I think everyone offers the monthly payment option.

More Secure – This is one that could be argued either way. Either one could be more secure. Client Server vs Cloud EHR doesn’t determine the security. A client server EHR can be just as secure or even more secure than a cloud EHR. I agree that generally speaking, cloud EHR is probably more secure than client server, but that’s speaking very broadly. If you care about security, you can secure a client server EHR as much or more than a cloud EHR.

More Reliable (backup/disaster recovery) – Similar to secure, you can invest in a client server infrastructure that is just as reliable as a cloud EHR. It’s true that a cloud EHR vendor can invest more money in redundant systems usually. However, a client server EHR vendor that hosts the EHR could invest just as much.

Single Database – This is the one major challenge where I think client server has a much harder time than a single database cloud EHR provider. Sure, you can export the data from all of the client server EHR software into a single database in order to do queries across client server EHR installs. A few vendors are doing just that. So, I guess it’s possible, but it’s still not happening very many places and not across all the data yet.

Available Everywhere – This can be done by client server as well, but the experience is often a subset of the in office experience. Although, this is rapidly changing. Bandwidth and technology have gotten so good, that even a client server install can be done pretty much anywhere on any device.

Conclusion
Looking through this list, it makes a great case for why client server EHR software is going to be around for a long time to come. There’s nothing on the list that’s so compelling about cloud hosted EHR software that makes it a clear cut winner.

As I thought about this topic, I tried to understand why cloud’s been the clear cut winner in so many other areas of technology. The answer for me is that in our lives portability has mattered a lot more to us. In healthcare it hasn’t mattered as much. Plus, new client server technologies have been portable enough.

Long story short, I’m a fan of cloud technologies in general, but if I were a provider and a client server technology provided me more features, functions, better workflow, etc, than a cloud EHR, I wouldn’t be afraid to select a client server EHR either.

Also worth clarifying is that this post outlines how a client server EHR can provide all of the same benefits of a cloud EHR. However, just because a client server EHR can provide those benefits, doesn’t mean that they do. Many have chosen not to offer the above solutions. Although, the same goes for cloud EHR as well.

What do you think? Are there other reasons why cloud EHR technology is so much better than client server? Is there something I’ve missed? I look forward to reading your comments.