UPDATE: Who knows what HHS is up to, but the original links I had for these documents were moved and/or taken down. So, I found some new links, but the new links have different page numbers. Although, all it looks like HHS did was reformat it with a smaller font and cut it into multiple parts. I wonder if this is just them trying to lower the number of pages since the PR they got for the initial documents was so bad. Looks like there are more of essentially the same documents on Regulations.gov where you can provide feedback on the proposed rules.

As I’ve suggested in my previous posts, I’m planning to do some future blog post analysis of the Meaningful Use Interim Final Rule that was recently released by ONC. However, I can’t help but comment on the amount of legalese (is that even a word) that surrounds these types of regulations. The meaningful use interim final rule (PDF of rule) is 556 pages long. The “Standards & Certification Interim Final Rule: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology” (PDF of rule) otherwise known as the EHR certification requirements is a mere 136 pages.

Yep, that’s a full 692 pages. Granted much of it can quickly be ignored (ie. the glossary, background, etc). However, it’s no wonder that it takes so long to do anything in government if it’s going to take 692 pages to digest what needs to be done. I’m sure there’s a ton of background to why this is the way it is but it’s really quite sad.

Of course, that’s probably why a site like mine will be of benefit to readers. Hopefully I can take those 692 pages and help to summarize the important details and what it will mean to those interested in the EMR stimulus. I also won’t be shy in linking to other people who provide great summaries of the HITECH act. If you know of any, let me know as well so we can all learn and grow together.

Until then, feel free to take a look at ONC/HHS pages on meaningful use and certified EHR. ONC still hasn’t posted the details on EHR certification bodies. So, don’t go looking for that. Much more to come.

Finally, 2 interesting quotes I heard recently (paraphrased):

“Whether you like the health care reform or not, it’s been amazing at how much more educated we are about the legislative process thanks to health care reform.”
I think this is also true in regards to the HITECH act EMR stimulus money.

“It’ll be a great year decade for the EMR consultants….”

No one asked (well at least not publicly), but I wanted to share my opinions on what EMR vendors should be doing in regards to EHR certification. I guess you could say this is a small sample of the advice I’d offer as an EMR vendor advisor albeit not EMR vendor specific and with less detail. Take it for what it’s worth.

If I’m an EMR vendor today, I’d definitely avoid going out and getting either the CCHIT Certified 2011 or the Preliminary ARRA 2011 EHR certifications. One reader of this site emailed me an estimate of $100,000 up front and $9,000 renewal fee per year for the CCHIT certifications they were considering. Certainly it could be less if you just go with the Preliminary ARRA certification, but regardless the cost is quite large.

Instead, I’d take a more reasoned approach. There are 2 important things for an EMR vendor to consider when it comes to EHR certification.

1. EMR vendors need to be able to sell product and allay customers concerns about your EMR not being certified. Many people will be asking for EHR certification and even more people will be asking for the EHR stimulus money.
2. EMR vendors want to make sure that they’re well positioned to become HHS certified (at least most of them) once HHS pulls back the curtain and shows us what that will be. However, they don’t want to waste development dollars on features that don’t improve their product.

With these two considerations in mind, my suggestion is for EHR vendors to take a look at the Preliminary ARRA Certification (in particular the Meaningful Use Matrix Tagged for CCHIT Reference document (pdf) is a good start). Take the list of criteria that CCHIT has created and matched up with the meaningful use matrix. Then, evaluate the criteria to see which ones you don’t have and would be of value to your customers. Next, prioritize that list and add those criteria that add value to your EHR development plans.

The concept is simple. Despite my ripping on CCHIT, there are certain aspects of their criteria which are incredibly valuable to a doctors office. Take those criteria that will provide value to your EHR end users and spend your development time adding value to your product. Then, once HHS/ONC/CMS publishes the final criteria for achieving EHR certification you will have hopefully already developed a number of the criteria while not wasting time developing CCHIT criteria which won’t be required by HHS/ONC/CMS. Once we know what the real EHR certification criteria is going to be, you can decide which “certified EHR” option is best going forward.

There is one caveat to this suggestion. You’re going to have to be able to tell a compelling story to some clinics about why you aren’t doing CCHIT certification. However, from what I’ve heard from other EHR vendors and my experience talking to people, it’s not a huge hurdle to explain how you’re going to get them access to the EHR stimulus money and how CCHIT certification would have increased the cost of your EHR product while not improving the life of the doctor. Let them know that you evaluated the CCHIT criteria list and implemented those of value. Then, list one CCHIT criteria that doesn’t add value and they should see pretty clearly why you made a good choice.

What do people think of this advice? Does it make sense? Is there something else I’m missing?

I’m really coming around on this fact. I’m not sure I should, but I am. I’m beginning to realize how big of an impact for good or bad that all this EMR stimulus money can have. Now, don’t get me wrong. I think long term there’s a lot of other benefits to EMR and I think there’s a strong case that can be made for implementing an EMR based on other EMR benefts. However, I’m starting to realize that to a large extent it is about the money.

Before the EMR stimulus came to the forefront of the EMR and HIT world, I would often be asked about EMR adoption and the trends that I’d seen in EMR adoption. I’d then start to describe that about 4 years ago when I started blogging about EMR, doctors and practices were asking the question “Should I implement EMR?” However, I’d seen a shift where doctors were now asking “how, what and which EMR should I implement?” To me this was a HUGE shift in perspectives and an important one for having widespread EMR adoption. Of course, this shift happened well before the government lit the EMR world on fire with $18 billion of EMR stimulus money.

What I’m now beginning to notice is that there’s a really strong opportunity to accelerate what was already happening. $44k per provider is a big deal for most practices interested in an EMR. The company and/or consultants that can find a simple way to gain access to this money are going to do very well and many EMR are going to be adopted during this time. I think it will be the proverbial straw that breaks the camel’s back for many many doctors.

Basically, I see many doctors who previously said I want to implement an EMR, but… Now saying I want to implement an EMR and I want the $44k, let’s make it happen.

My only words of caution. Don’t rush the process, but don’t waste time either. Take time to find the EMR that will work best for your clinic. There are good EMR out there that will get access to the EMR stimulus money. Make sure you get both a good EMR and the EMR stimulus money.

Ok, I know I should see this coming and just expect it. However, it doesn’t make it any more right or me any more upset that this kind of shady practices occur.

Yes, today I received my first notification that some EMR Consultant…errr…should I say Meaningful Use consultant…err…should I say liar…was giving detailed recommendations to a practice on how to meet meaningful use. The sad part is that the practice didn’t know that nothing is final with meaningful use and may not be until middle of 2010 and so they were handing over their money.

Looks like I need to add meaningful use consultants to my list of Big Winners from the ARRA EHR stimulus money. Of course, if you’re reading this blog, you’re not likely to be the one being duped. So, tell your friends that we still don’t have a final rule for meaningful use or certified EHR. Anyone that tells you so should be kicked out of your office immediately.

I read a number of online forums and blogs about EMR. Most of the time I’m amazed at all the smart people that are participating in the discussion of EMR. However, occasionally I come across comments that just make me cringe. Here’s one of those comments about the EMR selection process:

Key factors to consider are cost of licensing; maintenance and any other cost of ownership fees; types of service level agreements (SLAs); redundancy/mirror imaging (ability to minimize downtime or restore system in minimal time or an alternative process for business continuity); types of technical environment/architecture required; security and access points; implementation costs (avoid customization or keep them to a minimum whenever possible); maintenance costs for customizations, which vendors sometimes treat as a separate cost; cycle for upgrades/fixpacks/major version releases and support; training development and delivery; and optimization to ensure the system is being used as effectively, productively, and efficiently as possible throughout its life cycle. Hopefully, there will be some standardization of key features to ensure ease of usability in the near future.

Are those the key factors that should be considered in selecting an EMR in your book? Not that a number of the items aren’t important. However, most of that list doctors I know don’t care about and quite frankly they shouldn’t. I think most doctors look at the selection in this way: cost/ROI, usability, and let some tech person deal with all the technical details. I think that many have a challenge measuring these, but at the end of the day the ROI and usability of the software is all they really care about. Is that such a bad thing?

What’s interesting about the above statement is that the following statement preceded it:

I would recommend that physicians invest in a reputable and health care industry focused consultant or consulting firm to help in the vendor selection process to determine which system best fits their needs.

I can’t argue with this advice. However, the list of EMR selection “key factors” above makes me think that whoever made the list isn’t a “reputable” EMR selection consultant.

Some of you might remember that I relatively recently wrote an article about types of EHR consultants for MDNG magazine. It was a fun article to write. Considering my word limitations, I had to limit it to just a very specific topic. However, I still have a bunch of other commentary on EHR consultants that I plan on posting either on this blog or as an e-book eventually, but I digress.

What I thought was pretty cool about MDNG was that they took my article and not only published it online and as the cover story of the magazine, but they also did a podcast of a doctor reading my article on EHR consultants.

I love their use of technology in this way. I wish computer voices would improve and then I could easily publish this whole blog as a series of podcasts. Would be pretty cool.

A recent comment asked me what I thought about this person becoming essentially an EMR selection consultant. I started to reply in the comment, but it got so long that I decided that it was worthy of it’s own post. Plus, then all the EMR and HIPAA readers can provide other counsel and advice in the comments which will probably be even more valuable than what I have to offer.

Considering so many people are losing jobs and searching for new emr jobs (no, I wasn’t paid for that link, but I was paid for the EMR Jobs ad on this page), I think this post is timely. So, the follow is my advice to Jim about becoming an EMR selection consultant.

Jim,
I think there are a lot of doctors that could use this type of service. There are 4 things I think our worth mentioning to you.

1. Are doctors going to be willing to pay much for this type of service? It’s certainly a valuable service, but do doctors see this as necessary and worthwhile or do they think they can just do it on their own using some certification or recommendations from friends, organizations, associations, etc. In these economic times, don’t be surprised if many of them aren’t ready to spend money on this either.

2. Why should doctors trust you with this decision? I’m not speaking of you specifically since I don’t know you. My point is that this is a HUGE decision by a doctor. How will you make the doctors feel enough trust in you to have them help you make the decision? Once you earn their trust, it’s gold.

3. Many doctors are just browsing for EMR software. Be sure that whatever contract you create with the doctor, it’s clearly specified what your responsibilities are and what the doctors responsibilities are as well. They’ll HAVE to play a major part in the selection process. However, you don’t want to be stuck ready to go through the process and they’re not willing to commit the time. Then, you’ve wasted your time and won’t get paid. Also, don’t fall in the trap that they have to select the EMR for you to get paid. Otherwise, the doctors will just spin their wheels on the decision making and you won’t get paid for much longer than you planned.

4. Be very clear about any conflict of interests you may have. Try to avoid having conflict of interests at all. However, it’s sometimes too nice to not get paid a referral from an EMR vendor when you’re the one that sent them the business. You’ll have to work that through yourself. However, I ethically believe if you are getting paid to help someone select an EMR, they should be made fully aware of any conflict of interests you may have in your pocket. Now, if we could just get our government leaders to do the same (but I digress).

I know there are many other things, but I hope this helps. I really think there’s going to be a lot of work in the area of EMR selection for a while to come.

I mentioned previously that I was working on an article about EHR consultants. I wanted to sincerely thank all those people who commented on EHR consultants and sent me feedback on things I should include in my article.

As you’ll see, I used a lot of the feedback that you gave me to form the article. That’s really the power of the internet to bring a bunch of bright people together to create something of far greater value than I could have created on my own. Thank you for your feedback.

I’m told the Magazine has been sent to the presses and those of you who get MDNG magazine will see my article soon (hopefully someone will get one to me). The cool thing is that my article is the cover story for the February issue of MDNG.

For those that don’t want to wait for the magazine or don’t get the magazine, my article on EHR consultants has already been posted online. It’s called: Does Your EHR Consultant Have Your Best Interests in Mind?

Let me know what you think about it.

I know that I have a number of EHR consultants that regularly read this blog. Plus, many of my readers have used, are looking to use or have heard stories about EHR consultants. I’m currently working on an article about EHR Consultants and so I’m interested in hearing people’s feedback about their experience with or as an EHR consultant. Here’s some things i’m interested in hearing about:

• Benefits of an EHR Consultant
• Challenges of an EHR Consultant
• Finding a good EHR Consultant
• Making the most of an EHR Consultant
• Does an unbiased EHR Consultant exist?
• etc…

Basically, I’m interested in answering the question of whether an EHR consultant has your best interest in mind and things you can do to ensure a quality experience with a consultant.

Also, you might look back at my five part series on EHR consultants to get you thinking.

Part five of our five part series on the benefits of an EMR or EHR consultant is improved clinical buy-in.

Improved Clinical Buy-In

Hiring a proven EMR consultant alleviates fear and increases clinical buy in. However, more importantly, EMR consultants are able to provide a clinic the tools needed to show an EMR implementation’s ROI. EMR consultants should do a comprehensive analysis to show how an EMR implementation will reduce costs, increase revenues, and better care for patients. Quantifying the potential returns on an EMR investment generates significant buy in at all levels of a clinical organization.

See other parts of Benefits of using an EMR/EHR Consultant:
Benefits of Using an EMR/EHR Consultant – Selection Process
Benefits of Using an EMR/EHR Consultant – EMR Training
Benefits of Using an EMR/EHR Consultant – Clinical Process Mapping
Benefits of Using an EMR/EHR Consultant – Comprehensive Technology Support
Benefits of Using an EMR/EHR Consultant – Improved Clinical Buy-in