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Unfinished Business: More HIPAA Guidelines to Come

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The following is a guest blog post by Rita Bowen, Sr. Vice President of HIM and Privacy Officer at HealthPort.

After all of the hullabaloo since the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) release of the HIPAA Omnibus, it’s humbling to realize that the work is not complete. While the Omnibus covered a lot of territory in providing new guidelines for the privacy and security of electronic health records, the Final Rule failed to address three key pieces of legislation that are of great relevance to healthcare providers.

The three areas include the “minimum necessary” standard; whistleblower compensation; and revised parameters for electronic health information (EHI) access logs. No specific timetable has been provided for the release of revised legislation.

Minimum Necessary

The minimum necessary standard requires providers to “take reasonable steps to limit the use or disclosure of, and requests for, protected health information to the minimum necessary to accomplish the intended purpose.”

This requires that the intent of the request and the review of the health information be matched to assure that only the minimum information intended for the authorized release be provided. To date, HHS has conducted a variety of evaluations and is in the process of assessing that data.

Whistleblower Compensation

The second bit of unfinished legislation is a proposed rule being considered by HHS that would dramatically increase the payment to Medicare fraud whistleblowers. If adopted, the program, called the Medicare Incentive Reward Program (IRP), will raise payments from a current maximum of $1,000 to nearly $10 million.

I believe that the added incentive will create heightened sensitivity to fraud and that more individuals will be motivated to act. People are cognizant of fraudulent situations but they have lacked the incentive to report, unless they are deeply disgruntled.

Per the proposed plan, reports of fraud can be made by simply making a phone call to the correct reporting agency which should facilitate whistleblowing.

Access Logs

The third, and most contentious, area of concern is with EHI access logs. The proposed legislation calls for a single log to be created and provided to the patient, that would contain all instances of access to the patient’s EHI, no matter the system or situation.

From a patient perspective, the log would be unwieldy, cumbersome and extremely difficult to decipher for the patient’s needs. An even more worrisome aspect is that of the privacy of healthcare workers.

Employees sense that their own privacy would be invaded if regulations require that their information, including their names and other personal identifiers, are shared as part of the accessed record.  Many healthcare workers have raised concern regarding their own safety if this information is openly made available. This topic has received a tremendous amount of attention.

In discussion are alternate plans that would negotiate the content of access logs, tailoring them to contain appropriate data regarding the person in question by the patient while still satisfying patients and protecting the privacy of providers.

The Value of Data Governance

Most of my conversations circle back to the value of information (or data) governance. This situation of unfinished EHI design and management is no different. Once released the new legislation for the “minimum necessary” standard, whistleblower compensation and revised parameters for medical access logs must be woven into your existing information governance plan.

Information governance is authority and control—the planning, monitoring and enforcement—of your data assets, which could be compromised if all of the dots are not connected. Organizations should be using this time to build the appropriate foundation to their EHI.

About the Author:
Rita Bowen, MA, RHIA, CHPS, SSGB

Ms. Bowen is a distinguished professional with 20+ years of experience in the health information management industry.  She serves as the Sr. Vice President of HIM and Privacy Officer of HealthPort where she is responsible for acting as an internal customer advocate.  Most recently, Ms. Bowen served as the Enterprise Director of HIM Services for Erlanger Health System for 13 years, where she received commendation from the hospital county authority for outstanding leadership.  Ms. Bowen is the recipient of Mentor FORE Triumph Award and Distinguished Member of AHIMA’s Quality Management Section.  She has served as the AHIMA President and Board Chair in 2010, a member of AHIMA’s Board of Directors (2006-2011), the Council on Certification (2003-2005) and various task groups including CHP exam and AHIMA’s liaison to HIMSS for the CHS exam construction (2002).

Ms. Bowen is an established speaker on diverse HIM topics and an active author on privacy and legal health records.  She served on the CCHIT security and reliability workgroup and as Chair of Regional Committees East-Tennessee HIMSS and co-chair of Tennessee’s e-HIM group.  She is an adjunct faculty member of the Chattanooga State HIM program and UT Memphis HIM Master’s program.  She also serves on the advisory board for Care Communications based in Chicago, Illinois.

August 4, 2014 I Written By

EHR Incentive Market Share Charts Worth A Thousand Words

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One thing I really love about the government lately is their goal to be as transparent as possible. Certainly they still have a ways to go, but I think healthcare has done some significant things when it comes to transparency into the government health programs. A great example of this is the Health IT Dashboard which has all of the data for the various health IT programs.

I don’t want to steal Carl Bergman’s thunder, because he’s already posted some really interesting Hospital EHR market share data and his previous EHR market share data. Plus, he’s planning to dive into the meaningful use market share data next. I love the approach of multiple sources when it comes to evaluating EHR market share and so I look forward to his analysis of EHR incentive market share against the EHR adoption market share from Definitive Healthcare and SK&A.

Until then, I thought I’d give you a taste of the EHR vendor participation in the EHR incentive program. This data comes from the ONC dashboards listed above and are put into some really nice snapshots of the data by ONC.

First up is the data for EHR vendor attestations by eligible professionals (ie. ambulatory doctors):
EHR Incentive Market Share - Eligible Professionals

And the EHR vendor attestations by hospitals:
EHR Incentive Market Share - Hospitals

It’s worth noting that the above data is just the EHR incentive money data. No doubt the actual EHR adoption data would have a few differences and include some companies in specialties that don’t qualify for EHR incentive money. Not to mention specialty specific EHR vendors who likely don’t make the chart even if they dominate their specialty. These charts do serve as an interesting proxy for EHR market share that’s worthy of discussion even if it doesn’t paint the full picture. Plus, even more important will be to watch the change in these numbers over time.

With that disclaimer, we could analyze this data a lot of ways. I’ll just offer a few interesting insights I noticed. First, 711 vendors have been used in the ambulatory EHR incentive program. That’s a lot of vendors. Only 78 of those 711 supply secondary EHRs as opposed to the primary EHR. 452 EHR vendors supply a primary EHR to less than 100 eligible professionals. 200 EHR vendors supply a primary EHR to fewer than 10 eligible professionals. These observations and a comparison of the ambulatory versus hospital EHR incentive charts’ “Other Vendors” shows how fragmented the ambulatory EHR market share is right now.

I was also intrigued that Mitochon Systems, Inc. was on the list even though they shut down their Free EHR software in May 2013. They had white labeled their EHR software to a number of other companies and so it will be interesting to see how that number evolves. I assume they sold the software to those companies, but I hadn’t heard an update.

On the hospital side of things, MEDITECH certainly doesn’t get the credit they deserve for the size of their install base. The same goes for CPSI, MEDHOST and Healthland. I think their problem is that people only want to read about the Mayo, Cleveland Clinic, and Kaiser’s of the world and so the articles about Billings Montana Hospital (I made that hospital up) rarely happen. I should find more ways to solve that since the small hospital market is huge.

I do wish that there was a way to divide the ambulatory chart into hospital owned ambulatory practices and independent ambulatory practices. That would paint an even clearer picture of that market.

What do you think of these charts? What can we learn from them?

July 8, 2014 I Written By

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

Your EHR Vendor Isn’t Certified: Remove Barriers and Conquer Meaningful Use Stage 2

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I wrote previously about the “Triple Aim” of healthcare and even questioned if doctors really cared about the triple aim. For those not familiar with the triple aim, it includes: improving the health of our country, enabling less expensive care, and increasing patient engagement with their healthcare. All of these are noble goals and worthy of effort. Plus, even if providers aren’t moved by this goal, that doesn’t mean that much of the legislation and regulation that hits healthcare won’t be guided by this triple aim.

I was reading through this Allscripts whitepaper titled “Your EHR Vendor Isn’t Certified: Remove Barriers and Conquer Meaningful Use Stage 2” when I thought about how the triple aim is going to impact an organization’s decisions moving forward whether they like it or not.

The whitepaper underscores the shift towards more patient engagement, smart EHR tools, and population health. I think that generally summarizes meaningful use and is why it’s going to be really important that everyone in healthcare is involved in it.

Even if you don’t want to participate in the meaningful use program specifically, the overall trends that meaningful use represent are likely going to be with us for the foreseeable future. No doubt the government’s focus will continue this direction and I think payers are heading the same direction as well. They probably won’t adopt meaningful use entirely, but elements from it and other programs will likely be adopted by payers.

Check out the full whitepaper for more details on these trends and making sure your EHR is ready for them.

July 2, 2014 I Written By

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

Patient Engagement vs. Patient Education: What’s the Difference?

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The following is a guest blog post by Jamie Verkamp, Chief Speaking Officer at (e)Merge.
Jamie Verkamp
Healthcare organizations often see attesting to the Measures included in Meaningful Use Stage 2 as a burdensome checklist which results in a massive resource drain in exchange for inadequate financial compensation. MU Stage 2 Measure 7 is one such oft-maligned requirement for attestation. This Measure requires that online access to records is provided to 50% of patients and that 5% of patients execute the viewing, download, or transmission of their online health information.  Organizations should not see Measures regarding patient engagement as intimidating or inconvenient. Instead, these Measures seeking to improve patient engagement should be seen as an opportunity to create more loyal, involved, and empowered patients.  The importance of engaging our patients in their own health shows itself in current statistics relating to personal health.  According to a study by TeleVox, roughly 83% of Americans don’t follow treatment plans as prescribed by their physicians.  Adding to that, 42% of Americans feel they would be more likely to follow their care plan if they received some form of motivation to participate.  By giving patients a channel to monitor and participate in their own health, organizations can develop a more educated population capable of producing greater outcomes.

Understanding the reasoning behind the Measures driving patient engagement is the first step; now, we must educate our patient population on the value of logging in and connecting with their information. While the frequency of patients physically visiting their provider’s office is somewhat inconsistent, this is often the most successful way to encourage electronic patient access. Patient facing staff members should be well educated on electronic patient access and be prepared to answer questions as they arise. Physically walking patients through the engagement process of maneuvering their electronic access, or providing video tutorials with simple instructions in the office lobby can increase patient engagement substantially. Consider setting up a station in the waiting room to allow patients to sign up for the service, thus solving the issue of forgotten motivation.

However, organizations must seek to include in their engagement plan the younger and healthier population who may not enter the physical office space outside of unforeseen emergency visits or more often than their annual checkup requires. Looking online to relate with these patients can be beneficial, as this has been found to be where this demographic spends the majority of their time and communication engaging with brands and services.  Providing information and education on an organization’s website, Facebook, Twitter, or even YouTube page through video promotion can assist in sparking an interest with this patient population.  Many times, those likely to engage in a patient engagement offering remain unaware of its availability due to a lack of communication from the healthcare organization.  From the practice standpoint, we must understand our work is not done once the portal is merely completed; rather this is when the real challenge presents itself.

In today’s society, consumers are bombarded with promotional emails and routinely asked for their contact information so further communication can be established.  With this in mind, consumers are more cautious as to what and how much information they provide to companies.  Unfortunately, for the healthcare industry, this includes a cautious nature toward information shared with healthcare organizations.   With this barrier in place, administrators must actively engage with their patients to educate them on the benefits of becoming involved in electronically managing their care.  Before consumers choose to willingly hand over their personal contact information, they will likely need to understand the reasons for doing so and what advantages they will receive.

Convenience has become one of the most desired aspects of communication and buying behaviors in consumers today.  As a society, we have adopted a “need it now” expectation.  With the ease portable technology has brought to our information search, patients and consumers count on service when they desire it.   This is especially true when it comes to customer service; consumers are becoming less patient and beginning to expect service when they desire.  In a recent study, it was found businesses offering a “Live Chat” option online saw a 15% increase in conversions. Explaining to patients the ease of communication with physicians and key staff members through the portal can be a helpful start in creating buy in.  Communication via the portal includes direct messaging, appointment reminders, and more. Informing patients of potential time saving factors in appointments down the road and quicker access to lab results can also establish and pique interest.  In many instances, finding the optimal moment to address the patient portal can create successful outcomes.  Patients burdened by numerous prescription refill requirements or those frustrated with waiting in line to pay a bill can be directed back to the convenience of a patient portal to handle all of these items at their own computer at home.

As a whole, those looking to meet this Stage 2 requirement must focus their attention on creating personalized communication with patients.  Standardized information will not entice patients and may easily be looked over.  Begin to examine which staff members may be the best fit for providing patient education and focus on educating patients on what they will get out of participating, not just simply meeting your Measure 7 requirements.   Potential touch points can be found within your signage, billing communications, appointment reminders and especially on your practice website and social sites.

According to HealthIT.gov, Meaningful Use Stage 3 will continue with the goal of driving patient engagement and improving outcomes.  This will include, “patient access to self-management tools”. The options for healthcare organizations are clear:

1. An organization can meet the bare minimum for the Stage 2 requirements using a patchwork of initiatives which produce minimally satisfying results while have no significant effect on the patient experience. Then repeat the entire process for the applicable Measures in Stage 3.

2. An organization can have a well-articulated and executable plan. In doing so, the practice, hospital or healthcare organization can commit to utilizing technology for the optimization of patient care, get a full return on investment from the Patient Portal, and simultaneously grow their business through the competitive advantage of a successful online presence. Initiating this push now will further develop readiness for Stage 3 as the implementation date approaches and with productive workflows in place, administrators can free themselves to focus on other Measures for attestation.

So which option will your organization choose? It’s not going to be easy, but change seldom is. Every industry experiences social and digital evolution, now it is healthcare’s turn.

About Jamie Verkamp
This article is a result of a partnership between (e)Merge, a medical growth consulting firm and DataFile Technologies, an outsourced medical records management and compliance company. Jamie Verkamp leads (e)Merge as Managing Partner and Chief Speaking Officer, she works shoulder to shoulder with medical professionals the healthcare industry to improve the patient experience and see measurable growth in clients‘ customer service efforts, referral volumes and bottom lines. DataFile Technologies is led by Janine Akers, CEO. DataFile’s passion for compliance allows them to be thought leaders in HIPAA interpretation while executing innovative medical records workflow solutions on behalf of their clients. Our companies produce white papers, speaking engagements, and videos to keep health professionals up to date on the latest industry topics.

June 3, 2014 I Written By

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

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

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

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

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

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

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

May 21, 2014 I Written By

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

Your EHR Vendor Isn’t Certified – How Should You Approach MU Stage 2?

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A recent study conducted by Wells Fargo Securities stated “Over 700 EHR vendors had solutions certified for Stage 1, but at this point about 40 have been certified for Stage 2. While there is still time, we believe 300-500 vendors will ultimately disappear from the government program.”

We talked about the possibility of many EHR vendors not being 2014 certified in our interview with John Squire. This is a real possibility for many EHR vendors. It will be interesting to see which ones choose not to tell their customers that they won’t be ready until it’s too late to switch EHR. I think that will say something about the company.

Allscripts has put out a whitepaper that looks at some of the meaningful use stage 2 challenges and what you should do to make sure you’re ready.

  • Where to begin with Meaningful Use Stage 2
  • The new requirements for Stage 2 attestation
  • Technology upgrade and replacement considerations
  • Meaningful Use reporting
  • Transitioning to population health management

I find the idea of using MU stage 2 as a way to get ready for population health pretty interesting. I know this is a challenge when an organization is overwhelmed by the day to day life of someone in healthcare.

Considering the abysmal meaningful use stage 2 numbers that were released, it seems that many organizations could benefit from some meaningful use stage 2 help this whitepaper provides. I’d be interested to hear if people think that MU stage 2 does help their organization move towards population health management. Is that a reasonable goal you can work on as you work on MU stage 2? Reminds me of those who are doing CDI (clinical documentation improvement) projects alongside their ICD-10 work.

May 12, 2014 I Written By

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

Did We Miss the Patient Engagement Opportunity with Meaningful Use?

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

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

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

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

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

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

May 2, 2014 I Written By

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

Six Reality Checks of HIPAA Compliance

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Between Windows XP causing HIPAA compliance issues and the risk associated with the risk assessment required by meaningful use, many in healthcare are really waking up to the HIPAA compliance requirements. Certainly there’s always been an overtone of HIPAA compliance in the industry, but its one thing to think about HIPAA compliance and another to be HIPAA compliant.

This whitepaper called HIPAA Compliance: 6 Reality Checks is a great wake up call to those that feel they have nothing to worry about when it comes to HIPAA. While many are getting ready, there are still plenty that need a reality check when it comes to HIPAA compliance.

Here’s a look at why everyone could likely benefit from a HIPAA reality check:
(1) Data breaches are a constant threat
(2) OCR audits reveal health care providers are not in compliance
(3) Workforce members pose a significant risk for HIPAA liability
(4) Patients are aware of their right to file a complaint
(5) OCR is increasing its focus on HIPAA enforcement
(6) HIPAA Compliance is not an option, it’s LAW

Obviously, the whitepaper goes into a lot more detail on each of these areas. As I look through the list, what seems clear to me is that HIPAA compliance is a problem. Every organization should ask themselves the following questions:

Are we HIPAA compliant?

What are you doing to mitigate the risk of a breach or HIPAA violation?

When I look at the 6 Reality Checks details in the whitepaper, I realize that everyone could benefit from a harder look at their HIPAA compliance. A little bit of investment now, could save a lot of heartache later.

April 23, 2014 I Written By

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

Breaking News: Meaningful Use is Not Covering Costs

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In one of my recent interviews with a healthcare IT consulting company, they revealed some breaking news for those of us in the EHR world. They told me point blank that:

Meaningful Use is Not Covering Costs

Ok, so that’s not really breaking news. Although, it seems that very few people want to actually articulate this point. It almost feels like heresy that someone would “complain” about the fact that the government is spending $36 billion on EHR incentives and that the money isn’t enough to cover the implementation of these EHR systems.

Actually, I should clarify that last point. The EHR incentive money is covering the costs to purchase the systems. It’s not covering the costs of implementing those EHR systems and then poking, prodding and otherwise cajoling end users to show meaningful use of that system (not to be confused with meaningfully using the system).

Let me also be clear that I’m not complaining about the EHR incentive money. I’ve done enough of that previously. What I’m just trying to acknowledge is something that everyone who deals with the EHR budget already realizes, but no one seems to want to say it. Organizations are spending more money on EHR and meaningful use than they’re getting from the government.

I think this is important for a couple reasons. First, many organizations didn’t budget any EHR money beyond what the EHR incentive money. You can certainly argue this was a mistake on their part, but that’s going to leave a bunch of organizations in a lurch. We’re already seeing the fall out of this as news reports keep coming out about hospitals systems in financial trouble due to the costs of their EHR system. Plus, in each of these cases, it seems their costs continue to balloon out of control with no end in sight. It makes me wonder if the compressed meaningful use timeline is partially to blame for a rushed implementation and poor EHR implementation and cost planning.

Second, there is still a swash of providers and organizations that haven’t yet implemented their EHR. If you can’t support the cost of EHR with government money, how does that bode for those who won’t be getting any EHR incentive money? One could make the argument that they’ll actually be in a better position since they won’t have to worry about meaningful use and can just focus on getting value out of their EHR. Hopefully that’s the case, but many of the meaningful use functions are now hardcoded into the EHR systems. Even if an organization isn’t planning on attesting to meaningful use, that doesn’t mean they won’t be forced by their EHR software to do a bunch of things they wouldn’t have done otherwise.

What are you seeing from your perspective? Is the EHR incentive money covering the costs of an EHR implementation? What are the impacts if it doesn’t?

April 21, 2014 I Written By

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

Lack of 2014 Certified EHRs

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

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

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

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

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

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

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

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

April 11, 2014 I Written By

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