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MU Stage 2 Delayed: Should You Rush to Attest? – Meaningful Use Monday

Posted on December 12, 2011 I Written By

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

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

HHS recently announced the postponement of Stage 2 Meaningful Use to 2014. The only providers who are in a position to act on this “opportunity” are those who have not yet, but still could, attest to meaningful use in 2011—but, a word of caution before you rush to attest in 2011. 

The HHS announcement “encourages any providers who have been waiting until 2012 to attest to Stage 1 meaningful use now. ….Those providers who first attest in 2011 can get three payment years for meeting the Stage 1 expectations, while those first attesting in 2012 can only get two payment years under Stage 1 criteria.” 

True. However, you must carefully weigh the benefit, (earning the $8,000 third incentive payment under the rules of Stage 1 instead of those of Stage 2), against the cost, (the permanent loss of your 2011 Medicare ePrescribing bonus money). Remember, you cannot receive incentive payments under both programs during the same year, so you maximize your total reimbursement by collecting the 1% ePrescribing bonus this year and waiting just 3 months to begin earning the $44,000 in EHR incentives over the next 5 years. There is no universally right or wrong strategy—just do the math and analyze the trade-off before making a decision.

Riskiness of Pharma Ads in EHR

Posted on November 23, 2011 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.

I’ve been having a number of really interesting conversations with people about Pharma ads appearing in EHR and other clinical software. Most people’s gut reaction is that they don’t want their doctor seeing a pharma ad while he’s ePrescribing. However, most people also agree that there’s too much Pharma money for it not to happen.

In an article at Lab Soft News a few months back, they discuss the challenge and issues surrounding Pharma ads in an EHR:

Very distressing to me, however, is the clear link of the company, and its software, to the pharmaceutical industry. I have blogged on numerous occasions about some of the ethical and legal lapses of some of these companies (see, for example: On the Corrosive Influence of Big Pharma on Academic PhysiciansMerck Creates Phony Peer-Reviewed Medical Journal to Dupe PhysiciansDetails Emerge About Ghost-Written Medical Articles for Wyeth). I have also reluctantly come to the conclusion that even apparently trivial advertising connections to Big Pharma can lead to mischief. I had previously thought that inconspicuous advertisements in EMRs by drug companies might be tolerated if the companies were to bear the costs of these systems. I now believe that allowing these companies even a tangential relationship to physician-office electronic medical records is too risky.

Certainly there are some really great points made. Absolutely there’s a risk that a doctor could be influenced by a pharma ad in an EHR. Will it make them provide a lower quality care because of the ad? I’m not sure it would. Could the care cost more because of the pharma ad? Possibly so. Do we not trust our doctors to do what’s best for us regardless of the other outside influences?

Back to the initial premise, many are concerned with Pharma ads, but they’re bound to happen anyway. So, I ask you the question, is there any way to have Pharma ads without compromising the integrity of the visit? Is there a way to minimize the influence of Pharma while still allowing them a way to talk with the doctor?

No doubt this discussion is going to come up again and again. With Pharma unable to even give a doctor a pen we’re going to see new creative ways for Pharma to be seen by doctors. Advertising Pharma products to patients won’t be enough.

Dymo Prescription Printer – DYMO LabelWriter 4XL

Posted on November 9, 2011 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.

I always love when people talk about the paperless medical office. It’s as if they believe that after implementing an EMR they will no longer have to have paper in the office. Turns out, EMR software can print out a lot of paper if you’re not careful.

While ePrescribing is on the horizon in many places, the harsh reality is that many still have to print out prescriptions. Add in the requirements around prescribing controlled substances and in almost every state doctors using an EMR are still having to print out prescriptions.

In my clinic, it always felt wrong to print out an entire sheet of paper for one prescription. Eventually we got our vendor to support printing out multiple prescriptions on one sheet of paper. That helped, but many patients only need one prescription so that’s a lot of wasted paper. Beyond the green movement, wasted paper = wasted money.

With this background, that’s why I was intrigued by the DYMO Prescription Printer that I saw at MGMA. I’d worked with DYMO label printers before since the lab I worked with printed off lab labels directly from our EMR software. It makes sense that they could use a little bit larger printer and do the same thing with prescriptions.

It’s pretty obvious to see the paper saving benefits of using a DYMO printer like this, but I think the other advantage to this printer is its size. The printer has such a small footprint that you could easily put it a lot of places that a standard printer just won’t fit.

I admit that I haven’t done a full analysis of the savings using this printer compared with a standard printer. However, the nice thing about the DYMO printers is that they’re thermal printers which means that you’ll never have to spend money on ink or toner to print prescriptions. That’s pretty nice.

I’d love to have some of my readers try out the DYMO Prescription Printer to let me know what they think and whether they think I should add it to my list of EMR related technology products. Maybe I should see if DYMO will give one away to one of my readers to try out and report back.

I always love when small adjustments to current technology can make a huge difference. Or in other words, did I just write a post about a label printer? Sometimes the best innovations are subtle changes.

Exemption from 2012 eRx penalties: The Process is Now in Place – Meaningful Use Monday

Posted on September 19, 2011 I Written By

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

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

The Final Rule on ePrescribing was published in the Federal Register on September 6. This is the rule that adds new categories under which some providers can request a hardship exemption from the 2012 (1%) ePrescribing penalties, and it eliminates some of the discrepancies between the Medicare ePrescribing rule and ARRA. (See Meaningful Use Monday June 6.)The only change from the Proposed Rule is the deadline for filing a request—it has been extended to November 1, 2011 (from October 1). Providers should file as early as possible, however, to minimize the number of claims that have to be reprocessed. 

Requests will be reviewed on a case-by-case basis. To submit a request for exemption:

  • Access the exemption request form on CMS’ QualityNet website www.qualitynet.org/pqrs
  • In the “Related Links” box on the upper left, click on “Communication Support Page”, which will display the online form
  • Provide identifying info (TIN, NPI, name, address, etc.)
  • Indicate which hardship category applies
  • Submit a justification statement explaining how ePrescribing represents a significant hardship
  • Attest to the accuracy of the information submitted. 

Craft your argument thoughtfully. There is no appeal process—the decision of CMS is final.

How Critical is the October 1, 2011 Deadline? – Meaningful Use Monday

Posted on September 12, 2011 I Written By

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

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

As October approaches, providers who want to apply for the 2011 EHR incentive—and their vendors—are scrambling to implement in time to allow for the 90-day reporting period. An EMR and HIPAA reader submitted the following question: 

Under the EHR Incentive program, in order to receive payment for 2011, the 90- day reporting period must begin no later than 1 October 2011 [Technical point: October 3 is the actual deadline]. Does this mean that the ONC Certified EHR must be in place and operational at that time or can it be installed after 1 October 2011 as long as the pertinent patient data is entered into the EHR once it is installed?

 The EHR must be in use during the entire 90-day period. Data must be reported for the entire 90 days; some measures require something to “be enabled” for the entire period, (e.g., a clinical decision support rule, drug formulary); and other measures have time frames attached, (e.g. provide a clinical summary within 3 business days), which would not be possible to accomplish retroactively. 

My suggestion is that you take the pressure off by postponing meaningful use—and the receipt of your incentive—by just 3 months. If you begin reporting on January 1 instead, you will still have the opportunity to earn the full $44,000 over the 2012-2016 period. You can attest at the end of March and expect your incentive by May. This schedule has the additional advantage of allowing you to earn a 1% ePrescribing bonus for 2011, which you would forego if you earn an EHR incentive since you cannot collect both in the same reporting period. Focus your energy this year on ePrescribing for 25 Medicare encounters and on successfully implementing your new EHR in 2012.

ePrescribing Controlled Substances

Posted on August 3, 2011 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.

Back on September 13, 2009 I wrote a post titled, “FDA Approves Pilot Electronic Prescribing of Controlled Substances.” I’d link to the post, but unfortunately the news got sent to me prematurely and so I had to take the post down. It was unfortunate, since there was and still is a lot of interest in being able to ePrescribe controlled substances. In fact, I’d say that not being able to prescribe controlled substances electronically is the current Achilles heal of ePrescribing.

Fast forward to the recent announcement that DrFirst’s announcement of the Nationwide Launch of their ePrescribing Controlled Substances product. Their latest ePrescribing product for controlled substances is called EPCS Gold and is fully certified to meet the prescription processing requirements for Surescripts, the DEA’s requirements in the Interim final rule, and the Identify Proofing requirements set by NIST.

I’m really glad to see ePrescribing of controlled substances moving forward. This will make ePrescribing much more attractive to physicians. Especially physicians that regularly prescribe controlled substances like surgeons and pain doctors.

However, this controlled substance ePrescribing announcement does of course come with it’s limitations. I think they’re described well in this part of the press release:

Prescribers enrolling for EPCS Gold™ will be able to send controlled substance prescriptions electronically after a simple credentialing and identity-proofing process with DrFirst. After providers are certified, they can begin e-prescribing Schedule II-V drugs based on their individual state laws and the ability of the receiving pharmacy to meet the DEA’s requirements to process these prescriptions. To avoid any confusion and eliminate guesswork by providers, EPCS Gold™ automatically detects which substances can be sent electronically.

The two challenges are quite clear: state laws and pharmacy ability to meet the DEA’s requirements. I haven’t done any in depth research on either subject, but I have a feeling that both of these things will be major issues across the country. I’d like to think it won’t be, but knowing the pace of state legislation and pharmacy adoption of these standards I’m not hopeful that they’re ready to receive controlled substance prescriptions electronically.

However, the above step is an important one. You have to have all sides ready to handle the security required to make ePrescribing controlled substances a reality. This is the first step and a very good one.

Relief May Be in Sight for Some Penalty-Threatened ePrescribers – Meaningful Use Monday

Posted on June 6, 2011 I Written By

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

Some physicians—most notably, surgeons and pain-management specialists—have expressed concern that they will be unfairly subject to the 2012 ePrescribing penalties, based on the fact that their opportunities to ePrescribe are limited by the nature of their practices. The Proposed ePrescribing Rule published in the Federal Register on June 1 offers a potential remedy for these providers.

 The rule, which amends the (MIPPA) 2011 ePrescribing rule, affords providers several new arguments they can use to request a “hardship exemption” from the 2012 penalties. (These are in addition to the already existing reasons, i.e., rural areas that lack high speed internet access and/or rural areas that lack pharmacies that accept ePrescriptions.) The new justifications include:

      1)   Inability to ePrescribe due to local, State, or Federal law, (i.e., providers who predominantly prescribe controlled substances).

      2)   Inability to count the ePrescriptions towards the Medicare incentive program, (i.e., providers who predominantly prescribe post-surgery—visits that are not included in the specified CPT denominator codes.

How does this relate to Meaningful Use Monday? The rule also reconciles the EHR (meaningful use) incentives and the Medicare ePrescribing incentives to some extent, in an attempt to harmonize the differing ePrescribing requirements and eliminate duplicate work for providers. (See “Meaningful Use, ePrescribing, and PQRS: Need for Harmonization” and “Meaningful Use Measures: ePrescribing.”) The Proposed Rule accomplishes this through two provisions:

      1)   Providers who successfully demonstrate meaningful use in 2011, which includes ePrescribing, would be exempt from the 2012 ePrescribing penalties. (Note, however, that these providers will be trading the 1% 2011 ePrescribing bonus for avoidance of the 1% 2012 penalty.)

      2)   ePrescribing software that is ONC-certified would be deemed also certified for the purpose of the Medicare ePrescribing program.

If you’d like to submit a comment to CMS on this proposed rule (file code CMS-3248-P), you can do so by July 25.

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

Weekend Healthcare IT and EMR Twitter Roundup

Posted on April 24, 2011 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.

You know on the weekends I love to through in a little round up of some interesting things said about healthcare IT, EMR and other topics on Twitter. Hopefully, they’ll educate, entertain and inform. If not, tomorrow’s another edition of Meaningful Use Monday.

I’ve been talking about this quite a bit lately on this blog (see my post about social media EMR information). However, I love how the described their shift from newsletters to tweets and blog posts since they’re more current. I obviously agree. Although, if you subscribe to the EMR and HIPAA email you can enjoy the convenience of an email newsletter with the current info of a blog.

I saw this announcement a while ago. I’m really excited to see what Rock Health is able to do. They definitely have a number of big names. I wish that I was some way involved with them since I love their approach. Plus, I’m really excited to have my brother, David, participating with me on the Smart Phone Healthcare website I recently launched. Mobile healthcare is a really hot area of the market and I think together we’re going to bring some interesting perspectives to the mobile area of healthcare.

I usually hate PDF’s and a tweet in a blog post that leads to a PDF is probably even worse. Although, it has an interesting format for considering the multiple e-Prescribing incentive programs. Of course, if you’re a regular reader of the site, then you already have started ePrescribing right?

This just made me laugh and so I had to share it. Although, if you Like EMR and HIPAA on Facebook, then it will be so much better than prison. Well, maybe not much better, but it will make me smile.

Meaningful Use Measures: ePrescribing – Meaningful Use Monday

Posted on April 18, 2011 I Written By

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

I hope that by now, readers have heeded the advice I gave in a previous post, “No Matter What Else You Do in 2011, You’ve Got to ePrescribe” and are covering their bases regarding ePrescribing under MIPPA. Even though providers can’t collect a meaningful use incentive (as a Medicare participant) during the same year that they earn an ePrescribing incentive, having the ePrescribing workflow in place for MIPPA purposes will prepare them well for meaningful use.

Meaningful Use Core Measure: ePrescribing

More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

This is a core, i.e., required, measure that can only be excluded by an EP who writes fewer than 100 prescriptions during the reporting period and attests to that number of prescriptions. A continuing ePrescribing challenge faced by some specialists is the inability to ePrescribe Schedule II-V drugs. CMS took that issue off the table—at least for the purposes of meaningful use—by limiting the calculation to “permissible prescriptions.” (The definition of “permissible” excludes controlled substances because it is based on the rules that were in place in January 2010, when the Final Rule on Meaningful Use was published.)

The good news about the ePrescribing measure is that in the course of satisfying this one measure, providers will be simultaneously addressing 4-5 other measures—CPOE, maintaining a medication list, drug-to-drug and drug-allergy checks, and the menu measure requiring implementation of a drug formulary. Of this list, those that require more than simply “enabling the functionality” will be the topics of future Meaningful Use Monday posts.

Important notes about MIPPA and EHR Incentives:

  • It is possible to be deemed a successful ePrescriber in one program, but not the other, because the two programs have different specifications, so make sure to understand the rules for each.
  • If you choose to pursue the EHR incentives rather than the ePrescribing incentives this year, you must still continue to comply with the MIPPA requirements, (i.e., use the G-Code), to avoid 2012 and 2013 penalties.

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

Meaningful Use Monday – Follow-up on ePrescribing

Posted on February 28, 2011 I Written By

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

The last Meaningful Use Monday post detoured from the EHR incentives to ePrescribing under MIPPA—given its importance based on the impending schedule of penalties. Because I receive ePrescribing questions on a daily basis, I thought a quick recap of ePrescribing basics might be helpful:

  • Incentives and penalties:
Year Incentives* Penalties*
2011 1%
2012 1% 1%**
2013 0.5% 1.5%**
2014 on 2%

*Percent of provider’s total Medicare Part B FFS Allowable Charges. (Incentives assume provider does not receive EHR incentive for that year.)

**Based on 2011 ePrescribing activity

  • Incentives are earned per provider, and each provider must individually meet the requirements. This means that some providers within a practice might qualify for an incentive, while others might incur a penalty. (Group reporting options exist, but they are limited and require qualification.)
  • Reporting is by G-Code and there is only one: Use G-8553 on the Medicare claim to report that “at least one Rx was generated and transmitted using a qualified ePrescribing system during the patient encounter.”
  • Surescripts certification qualifies an ePrescribing system. (This is distinct from the ONC-certification required for meaningful use.)
  • Provider eligibility:
    • MD, NP, or PA with prescribing authority
    • At least 100 encounters with the specified CPT codes
    • Specified CPT codes must constitute at least 10% of the provider’s Medicare charges.
  • To request exemption from penalties, use the following G-Codes on one Medicare claim before June 30, 2011:
    • Hardship Code G-8642: Rural area with limited high-speed internet access
    • Hardship Code G-8643: Limited pharmacies for ePrescribing
    • G-8664: Although an eligible provider, you do not have prescribing privileges

In a future post, Meaningful Use Monday will look at ePrescribing in the context of meaningful use.

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