A recent comment from Jim Hook from The Fox Group had a nice checklist of items that doctors and practice managers could start doing to make sure that their EMR implementation is ready to meet the meaningful use standards. This isn’t an exhaustive list, but I thought was a good list for those providers wanting to being their preparation for showing meaningful use and obtaining the EMR stimulus money.

Everyone should keep in mind that there are no systems “Certified” at this point.

Here are some things to check as you get ready to claim your incentives for EHR Meaningful Use under the HITECH Act. This information is based on (EPs) qualifying for the Medicare incentives.

1) Start talking to your vendor about their plans to submit their EHR software for certification as “Certified EHR Technology”. The system does not have to be certified as of January 1, but it does need to be certified by the end of the 90-day period you are using to attest to your EHR Meaningful Use.

2) Keep in mind that if you are using a stand-alone EMR product with an existing legacy practice management (PM) system, the system needs to be Certified EHR Technology also. This is because some of the functions of a certified system, such as recording patient demographics electronically, are most likely functions of your PM system, not the EMR product. So talk to that vendor, too.

3) Verify that any eligible provider attesting to meeting EHR Meaningful Use objectives provides 10% or more of his/her Medicare services in an outpatient setting (not inpatient or in a hospital ED). CMS will look at the percent of services rendered in an outpatient setting for the fiscal year ending 09/30/2010 to determine the IP/OP percentages. Your EHR healthcare consultant must be qualified to do the analytical and reporting work in preparing the self-attestation report, based on the current fiscal year and the individual EHR Meaningful Use objectives in place, starting January 2011.

4) Make sure all eligible providers you are planning to certify for EHR Meaningful Use have an NPI number and are enrolled in PECOS.

5) For EPs in group practices, confirm the tax Id number – group or personal – of each provider for payment of the incentive amount. Payments can be made to either number.

6) CMS will be establishing an Internet-based enrollment process for EPs planning to apply for incentive payments. Keep checking this site for the Registration process, and enroll when it is available.

7) As soon as you start the clock on your 90-day period, make sure you are meeting all the EHR Meaningful Use objectives applicable to your practice, and, for objectives with numerical thresholds, that you are attaining the levels specified. If your EHR system is Certified EHR Technology, it should be capable of supporting all Stage 1 Meaningful Use objectives.

8) Monitor the CMS website on EHR Incentive Programs to determine the format of the attestation for 2011. And keep in mind that accuracy is paramount; attesting to EHR Meaningful Use is making a claim to a Federal program. And the penalties for false claims are significant!

Attestations can be completed as early as April, 2011, and CMS has stated payments will be made in May. For EPs seeking incentive payments under the Medicaid / Medical program, visit the CMS website for further information.

When I wrote my previous post about EMR consultant challenges, I thought it might be valuable to create a list of possible ways to do EMR consulting. This list is just off the top of my head, so please feel free to add other EMR consulting opportunities that exist out there in the comments:

EMR Selection – Consult on selecting the right EMR.
EMR Implementation – Consult on the best way to implement the EMR. Map EMR workflows to their existing paper workflows.
Meaningful Use – Consult a practice on how they can achieve meaningful use and get the EMR stimulus money.
EMR Vendors – Consult EMR vendors on their software, their marketing, etc.
IT Consulting – Consult practices on the right IT infrastructure to support an EMR in their practice.
EMR Review – Review an already implemented EMR and suggest ways that the implementation could be improved.
EMR Training – Train end users on a particular EMR. This often is similar to or included in EMR implementation consulting.
EMR Certification – Consult EMR vendors on preparing for and getting EHR certified (some are even still looking for help with CCHIT Certification).

Ok, what other types of EMR consulting are out there?

Everyone has been touting all the tremendous opportunities that are out there for EMR consultants and healthcare IT people. No doubt, there’s a lot of action right now around EMR. However, I’ve started to see many EMR consultants starting to wonder where the fountain of youthwork is that they heard was coming for EMR consultants.

EMR consultants face a really interesting challenge. The small clinics usually can’t afford the services of a consultant (or feel that they can’t) and the large clinics have their own in house resources and so their reticent to pay an outside EMR consultant to come into their practice. Where does that leave the EMR consultants that heard there’s this amazing need for help with EMR selection and implementation?

Not an easy problem to solve. Plus, there’s an even larger group of providers that still haven’t made the decision and committed the resources needed to implement an EMR. This means that the EMR consultant ends up having to not only sale their EMR consulting services, but also have to sale doctors on EMR.

This doesn’t mean that there aren’t a number of opportunities for people wanting to consult on EMR selection and implementation. It just means that EMR consultants are going to have to be really creative in how they find new customers.

From my experience, it’s going to be all about the relationships and trust that these consultants create with the doctors. As in most business, but particularly in healthcare relationships matter a lot.

Anybody have advice they can give these EMR consultants? It always amazes me how every job is basically a sales job. It’s just what you’re trying to “sale” that changes.

Note: Let’s also not confuse true EMR consultants with EMR salespeople dressed in consultant clothing.

I’m very happy to finally publish my first e-Book on EMR selection called “Selecting the Right EMR.” It’s 35 pages which I believe will help doctors and practice managers select the right EMR. This EMR selection e-Book is a good mix of education about the various types of EMR software and the advantages and disadvantages of those differences.

Selecting the Right EMR – $49.99

To give you an idea of the content, here’s the Table of Contents for the EMR selection book:
Table of Contents:
Introduction
EMR vs. EHR
Gaining EMR Implementation Buy-In
Narrowing the Field of EMR Vendors
Tools for Narrowing the Field of EMR Vendors
Details to Consider When Evaluating EMR Vendors
EMR Demos
EMR Site Visits
EMR Vendor Background Check
Selecting the EMR
Contract Negotiation
Managing Expectations
Resources

Since this is the launch of my EMR selection e-Book, I’m making a special offer to those who purchase the book. If you purchase the book and find a topic missing that would be valuable in your EMR selection process, drop me a note and I’ll do my best to provide you more content on that topic.

Selecting the Right EMR
$49.99

Bulk Sales – I’ve had a number of inquiries about being able to buy this e-Book in bulk so that vendors can give this away to their customers. For example, a number of Managed IT service providers have expressed interest in purchasing in bulk. Let me know your needs on my Contact Us page and we’ll be happy to work with you on it.

Affiliates – I’ve also setup the ability for other websites and bloggers to make affiliate sales of the EMR Selection e-Book. You can sign up and find out more details here. I’m currently offering a 40% commission for affiliates. Let me know if you have any questions.

Everyone and their dog seems to be telling people that “Now is the time to purchase an EMR system.” Well, maybe not everyone, but a lot of highly visible people in HIT and many bloggers. I previously posted some of my thoughts about when to implement an EMR. However, I think many people missed the point of what I was trying to say.

Now is the time for every doctor to select an EMR software. This is not a simple process (see this 300+ EMR vendor list) and every clinic should be participating in this process. Now is a GREAT time to select an EMR software.

Plus, many, many, many clinics should even buy an EMR now. A large number of clinics aren’t going to have access to any of the EMR stimulus money no matter what they do. I work for one clinic that is in this exact situation (and you’ll love the irony that this clinic uses a CCHIT Certified EHR). At my EMR stimulus presentation, I had one guy come up and ask “So, if I don’t take Medicare or Medicaid, then there’s no money for me, right?” My answer was, “No.” (Yes, I did say there could be grants or something, but you get the point). If you’re in this position, then what’s holding you back from implementing an EMR? Go look through this list of EMR benefits and you can easily make the case to implement now. Not implementing an EMR in this case is still a mistake.

Many other clinics can easily “ignore” the EMR stimulus money and focus on the other EMR benefits. By focusing on selecting an EMR that will maximize these benefits, you can create your own EMR stimulus package. Not to mention you’ll select a better piece of EMR software. EMR software that can’t provide you those other EMR benefits is not one you want in your office even if they can get you access to the EMR stimulus money. Plus, I’ve talked a number of times about the risks in relying too much on the EMR stimulus money. There’s a lot of reasons why you might want it and try to get it but end up with nothing. Essentially these doctors are ones that can treat the EMR stimulus like bonus money. If they get it, great. If they don’t, well they’ve still gleaned the benefits of having an EMR.

Now back to my original post about waiting to purchase (note I said purchase and not select) an EMR. There are a number of clinics where the EMR stimulus money could make a huge difference in the purchase of an EMR. Many of the doctors with lower reimbursements, for example, could use the EMR stimulus money. In these cases, I think people shouldn’t be rushing things. They should ignore the calls from all angles telling them to purchase an EMR NOW.

However, even in these cases, I think it’s reasonable to finish demoing and selecting an EMR right now. If you do that, once CMS finalizes the guidelines for meaningful use and certified EHR you’ll be ready to purchase an EMR and implement. If you don’t, then it’s correct that you won’t likely have time to implement an EMR and receive the EMR stimulus money. Adopting an EMR fully takes time.

No one reading this blog should think that I’m a critic of EMR software. I am a critic of hype in the EMR industry. I’m also a critic of useless certifications and other methods that don’t provide value to doctors. I am not a critic of EMR. In fact, I’m a huge proponent of EMR software use. Done well, EMR software can be a wonderful asset to any clinic. Were it not the case, I’d have stopped blogging about EMR long ago.

In a recent EMR vendor demo I did, they talked about strongly encouraging purchasers of their EMR software to do what they called a “clinical process review” before implementing their EMR. They had a contract with a third party group that would do the analysis and give the organization an idea of their current processes and what the future processes would be with an EMR. It highlighted things that would need to change, additional processes that would be added and processes that would be removed.

I’ve talked about this a lot in the past and I think it’s essential to a successful EMR implementation. I called it mapping your workflows, but clinical process review sounds prettier.

Certainly if you’re a large organization it can sometimes pay off to get someone else to do this for you. However, if you’re a small organization you can often do this yourself. Many EMR vendors will work with you on your current workflow and help you work that into their EMR software. I believe it’s absolutely essential.

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 received the following email from a reader of this blog:

I am the manager of a 2 physician, 2 nurse practitioner practice with an 11 bed sleep lab. We purchased our EMR in 2006, without much research, because it was compatible with our billing/scheduling program. It is grossly time consuming. Just entering a problem list takes 5 steps (for each disorder we are entering). It will not create notes as many EMRs do. We dictate notes to a transcription service and they are uploaded as documents. Basically it is a non-interactive storage unit, much like our paper charts were, except more time consuming. The company has basically told us that they will not be changing the system. The doctors and NPs are nearing revolt at this point because of the time that they spend trying to use this system.

What is your point of view on finding a new EMR? What would the time and mental repercussions be? Is it possible to coordinate billing systems and EMRs from different companies?

My reply was something I thought many on this blog would benefit from:
Thanks for sharing your experience. Unfortunately, it’s a common one.

The good news for you is it sounds like the notes in your current system is basically a document management system that stores your transcriptions electronically. This bodes well for you if you decide you’d like to move to a new EMR system. I say that because it is likely that you’ll be able to get these documents out of your old system and import them into a new EMR system so that your old EMR records are still available in the new EMR. Many EMR companies will work with you on doing just this.

If your current EMR system is worse than paper, then it sounds like change is likely a good choice. What I think you’ll find is the lessons you’ve learned from this first implementation will help you in your next EMR selection and implementation. It’s unfortunate you had to pay that price, but now that you’ve learned you might as well use it to your full advantage, right? In business they call it a sunk cost. It’s time and money already spent. You should base your decisions on changing your EMR on the time and money you’ll have to spend going forward and not costs which you’ll never get back.

It will take some time and money to fix it. However, those people who dislike your current EMR might be ready to commit the time and money needed to find a good EMR to replace what you’re using now. I will also say that I think unhappy workers is worth spending a lot of time and money to fix. An EMR should not start a revolt.

My only caution for you is that you need to take a real serious look at your clinic and ask an important question: Is it the EMR that’s the problem or is it something about our workflow/clinical environment/policies/culture that is the real problem with the system? Obviously, if it’s the former a change of EMR would be good. If it’s the later, then you might as well not change EMR software until you fix those other issues. I’ve often said that implementing an EMR just exacerbates any problems or weaknesses that exist in a clinical environment. It brings them to the surface and makes them hard to ignore.

Yes, there are a number of EMR companies that will work with your current Practice Management System (PMS). I’m someone who believes that if you’re very happy with your current PMS and the reimbursement that you’re getting from it, then it’s certainly a reasonable option to stick with your current PMS and interface it with an EMR company. In fact, there are some companies that are only EMR companies and then interface with various PMS systems. Their philosophy is that they should just focus their time on making an excellent EMR and not divide themselves between EMR and PMS software creation. Basically, they let another company focus on making an excellent PMS (or they’re are already excellent PMS systems out there). One example of this is Medtuity which is where I learned some of these principles. As I look at their product, I can see the advantages of focusing on being the best EMR and not being distracted.

Just know that there are costs associated with managing/supporting an interface between your EMR and PMS. Plus, there are some advantages to having the two integrated. You should weigh those out as you select a new EMR.

This was kind of fun. If you have a question you’d like me to answer, send it to me on my contact form and I’ll see about making it a future blog post.

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.