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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 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

This Geek Girl’s Singing: HIMSS 14 Social Media Finale

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As one of the inaugural crop of HIMSS Social Media Ambassadors, a second-generation native Floridian, and a former Orlando resident, it is my sworn duty to summarize, recap, and perhaps satirize the last group of Blog Carnival posts, to metaphorically sing the HIMSS opera finale. And you folks submitted some doozies! I’m very grateful to the HIMSS (@HIMSS) and SHIFT Communications (@SHIFTComm) team for providing me with links to all entries. Y’all have been BUSY!

A man after my own heart, and a frequent #HITsm participant who weathers harsh criticism with witty aplomb: Dan Haley’s (from athenahealth, @DanHaley5) piece on 3 Takeaways From HIMSS – Policy And Otherwise caught my attention with the line, “Regulators are from Mars…” He stole my favorite blog entry prize with the line: “Orlando is magical when you are a kid. Kids don’t attend HIMSS.”

First-time attendee Jeffrey Ting (from Systems Made Simple) outlined his experiences with some of my favorite topics in his piece, HIMSS Reflections By A First-Time Attendee: HIEs and interoperability. I agree with him: the Interoperability Showcase’s “Health Story” exhibit was one of the best presentations of the whole conference.

Dr. Geeta Nayyar’s perspective as a board member of HIMSS and CMIO for PatientPoint gave her a unique vantage point for her post, HIMSS 14: A Truly Inspiring Event. Take note, HIMSS conference planners – your monumental efforts were recognized, as was the monumental spirit of the closing keynote speaker, Erik Weihenmayer.

HIMSS Twitter recaps permeated the blogosphere, with my favorite being the inimitable Chuck Webster’s (@wareflo) HIMSS14 Turned It Up To 11 On And Off-Line!. Chuck also periodically provided trend analysis results of year-over-year #HIMSS hashtag traffic for each period of the conference, complete with memes for particular shapes: Loch Ness monster humped-back, familiar faces of frequent tweeters.

Health IT guru Brian Ahier’s (@ahier) wrapped up the “Best In Show” of HIMSS Blog Carnival , complete with Slideshare visuals awarding Ed Parks of Athenahealth “Best Presentation” and providing an excellent summation of must-read posts.

Interoperability was one of the most prevalent themes of HIMSS, and a plethora of posts discussing the healthcare industry’s progress on the path to Dr. Doug Fridsma’s (@Fridsma) High Jump Of Interoperability (Semantic-Level) were submitted to the Blog Carnival. Notable standouts included: Shifting to a Culture of Interoperability by Rick Swanson from Deloitte, and Dr. Summarlan Kahlon’s (of Relay Health), Diagnosis: A Productive HIMSS 2014, which posited that, “this year’s conference was the first one which convinced me that real, seamless patient-level interoperability is beginning to happen at scale.”

And who could forget about patient engagement, the belle of the HIMSS ball? Telehealth encounters, mobile health apps and implications, patient portals, and the Connected Patient Gallery dominated the social media conversation. Carolyn Fishman from DICOM Grid called it, HIMSS 2014: The Year of the Patient, and discussed trepidation patients feel about portal technologies infringing on face-time.

Quantified-self wearable-tech offered engagement opportunities, as well. Having won one such gadget herself, Jennifer Dennard (@SmyrnaGirl) gave props to organizations like Patientco and Nuance for their use (and planned use) of wearable tech in support of employee wellness programs, and posited on the applications of such tech in the monitoring and treatment of chronic disease in her piece, Watching for Wearables at HIMSS14.

Finally, if you’re able to read Lisa Reichard’s (from Billians Health Data) @billians) highlights piece,Top 10 Tales and Takeaways, without busting out into Beatles tunes, you probably wouldn’t have had nearly as much fun as she and I did at HISTalkapalooza, dancing to Ross Martin’s smooth parodies. You also probably don’t have your co-workers frantically purchasing noise-canceling headphones.

I did say I’d be singing to bring HIMSS to a virtual close.

Can’t wait to get back to the metaphorical microphone for HIMSS 2015 in Chicago!

March 14, 2014 I Written By

Mandi Bishop is a healthcare IT consultant and a hardcore data geek with a Master's in English and a passion for big data analytics, who fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

Meaningful Use Playbook 2014: Overcoming Adversity – Breakaway Thinking

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The following is a guest blog post by Carrie Yasemin Paykoc, Senior Instructional Designer at The Breakaway Group (A Xerox Company). Check out all of the blog posts in the Breakaway Thinking series.
broncos
I apologize in advance, but I am still mourning the Super Bowl loss of the Denver Broncos. I can’t stop replaying each moment and thinking of alternative scenarios. What if Peyton Manning utilized a quick huddle instead of audibles and hand-signals? What if Denver’s defense had better protected Peyton? What if the Broncos had scored more than eight points?

Regardless of the what-ifs and wounds resulting from the loss, the team has to step up and prepare for the next season, if they want to finish at the top. In the healthcare world, providers must also change their playbook and approach, if they wish to capitalize on the next phase of Meaningful Use.

For the past year, providers have been scrambling to select, implement or optimize a new electronic health record system to meet federal requirements for Meaningful Use Stage 1. Adding to providers’ challenges is the evolving nature of the rules for achieving meaningful use incentives; federal agency Centers for Medicare and Medicaid Services (CMS) is constantly updating the Meaningful Use Playbook. Similar to football players at the end of the season, providers are tired and wounded. However, they must be aware of and prepare to take on the new requirements for 2014. Otherwise, they risk future penalties and foregoing funds. To help healthcare providers prepare for this new season, here is a summary of changes taking effect this year.

  • Three-month reporting period
    All providers are now required, regardless of their stage of meaningful use, to demonstrate meaningful use for a three-month EHR reporting period. Medicare providers may elect to report clinical quality measures (CQM) for the entire year or select an optional, three-month reporting period for CQMs that is identical to their meaningful use reporting.
  • Exclusions and vital sign objectives
    All eligible professionals, eligible hospitals and critical access hospitals are now responsible for adhering to the latest changes in Meaningful Use Stage 1. This includes new requirements for electing exclusions toward menu objectives, age limits for recording and charting changes to vital signs, and new exclusions toward reporting height, weight and blood pressure.
  • View, download and transmit all health information or admissions online
    To better align with the new capabilities of certified EHR technology, CMS is replacing Meaningful Use Stage 1 objectives for accessing information online with the capacity to view, download and transmit this information.
  • Reporting of clinical quality measures
    All providers, regardless of their stage of meaningful use, must report on clinical quality measures to CMS. Eligible hospitals must report 16 of the 29 CQMs and eligible providers must report 9 of the 64 CQMs.(Source)

For providers making the leap to Stage 2 of meaningful use, this is only the beginning. Not only must they abide to the changes mentioned above, but they also need to plan and execute a strategy for integrating diverse IT systems and engaging patients. Neither are simple tasks. However, just as I believe that Peyton can shake this last performance and finish strong next year, I believe in the resiliency of providers too. With the right leadership and planning, they will take patient care to the next level.

Omaha! Omaha! Omaha!
Carrie Yasemin Paykoc
Xerox is a sponsor of the Breakaway Thinking series of blog posts.

February 19, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

A Hospital Perspective on Meaningful Use from Encore Health Resources

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The following is a guest blog post by Karen Knecht in response to the question I posed in my “State of the Meaningful Use” call to action.

If MU were gone (ie. no more EHR incentive money or penalties), which parts of MU would you remove from your EHR immediately and which parts would you keep?

Karen Knecht
Karen Knecht
Chief Innovation Officer at Encore Health Resources

It’s an interesting question you’ve posed on MU, and I think you have generated some great discussion on this topic, such as last week’s response by Dr. Sherling from the perspective of an eligible provider.

My colleagues and I would like to provide an eligible hospital perspective.  The industry is now three-plus years down the path of implementing “certified EHRs.”  There was a need to kick-start the digitization of healthcare in this country and create a common infrastructure to drive change, and MU has done that.  For example, establishing standards for data capture is critical for unified reporting and analysis.  Would the industry establish and adopt these standards without a program like MU?

But working with many large healthcare organizations representing several hundred individual hospitals in their MU programs, there are clearly many lessons learned and opportunities to improve for the future, even if the MU program were to go away.

Overall, there are no MU objectives that we would discount as having no value.  However, there are some that have served their time and others that are ahead of their time.

For the parts to continue, we see a high level of value in the CPOE, Barcoded Medication Administration, Medication Reconciliation and Clinical Decision Support objectives, as they are making tangible contributions to patient care.  However, we would recommend timeline delay due to additional capital outlay as well as complexity of workflow.  This would give more time for deeper and broader adoption.

For the parts to no longer measure in the same way, we would start by simplifying and removing the objectives that are topped out: the ones that are already hardwired in most organizations such as Vital Signs, Demographics, and Smoking Status.  This is no different than the current process for removing quality measures from reporting requirements once they have been well adopted — and HITPC is in agreement about this.  In their meeting last week where they discussed proposed Stage 3 measures, they were saying much the same thing.  Even if you stop measuring these things explicitly, they will continue to be electronically documented.

Second, we could see removing objectives that are now standard for “certified” EHRs.  For example, the time and effort to document the Drug Formulary, Drug-Drug, and Drug-Allergy checking functionality, for the sole purpose of meeting the MU objective, is not well spent.  Another example is the lab results stored as discrete values, which are part and parcel of any lab system in existence.

Other objectives that are causing great concern among many hospitals are the ones dealing with providing and exchanging information electronically.  It would be helpful to reconsider the expectations for these objectives, since many are finding out that implementing a patient portal without a sound patient engagement strategy is not going to be enough to ensure that 5% of patients will actually access their records.  Hospitals should have a portal and secure messaging capability, but it doesn’t seem realistic to put thresholds on patient utilization.  As the old saying goes, “You can lead a horse to water, but you can’t make it drink.”

Additionally, the requirement for Direct exchange to transmit summary of care is cumbersome and actually a step backwards for those entities who are part of an HIE and are currently exchanging data among members.  For most others, it is really only practical to implement with a physician ambulatory partner.  The sad fact is that nursing homes, SNF’s, and other entities where hospitals commonly transfer patients are not included in the EHR incentive program and do not have the technology necessary to participate in a direct exchange in a meaningful way.

And finally, we think all aspects of electronic quality measures should be rethought.  We love the idea of calculating these measures electronically, but they need to be appropriately validated and re-addressed in the context of the poor data collection that is occurring.  Perhaps CMS should consider another voluntary incentive program for facilities that have fully implemented all their clinical documentation.  Given the change that is proposed to the physician quality reporting programs as a result of the SGR fix, perhaps a similar refinement of the IQR and VBP programs along with MU should be considered.

See other responses to this question here and please reach out to us if you’re interested in providing a response to the question.

February 18, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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 Meaningful Use Try to Do Too Much?

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When I was reading Michael Brozino’s post on EMR and EHR about the Value of Meaningful Use, I was hooked in by his comment that meaningful use standards only went halfway. I’m not sure if this was the intent of his comment, but I couldn’t help but sick back and consider if meaningful use missed the mark because it only went half way.

When I think about all of the various features of meaningful use, it really feels to me like ONC and CMS tried to bite off more than they could chew. They tried to be all things to everyone and they ended up being nothing to no one. Ok, that’s not perfectly correct, but is likely pretty close.

Think about all of the meaningful use measures. Which ones go deep enough to really have a deep and lasting impact on healthcare? By having so many measures, they had to water them all down so it wasn’t too much for an organization to adopt. I’m afraid these watered down measures and standards render meaningful use generally meaningless.

Certainly the EHR incentive money has stimulated EHR adoption. However, could this EHR adoption have had even more impact if it would have just focused on two or three major areas instead of dozens of measures with good intentions but little impact?

In many ways, this is just a variation on my wish that EHR incentive money would have focused on EHR interoeprability. As meaningful use stands today, we’ve made steps towards interoperability, but we’re still not there. Could we have achieved interoperability of health records if it had been our sole focus? Instead, we’re collecting smoking status and vital signs which get stored in an EHR and never used by anyone outside of that EHR (and some would argue rarely inside of the EHR).

The good news is we could remedy this situation. ONC and CMS have something called meaningful use stage 3. How amazing would it be if they essentially through out the previous stages and built MU stage 3 on 2-3 major goals? The foundation is there for MU stage 3 to have an enormous impact for good on healthcare, but I don’t think it will have that impact if we keep down the path we’re currently on.

Yes, I realize that a change like this won’t be easy. Yes, I realize that this means that someone’s pet project (or should I say pet measure) is going to get cut. However, wouldn’t we rather have 2-3 really powerful, healthcare changing things implemented than 24 measures that have no little lasting impact? I know I would.

Side Note: Think how we could simplify EHR Certification if there were only 2-3 measures.

February 12, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

Meaningful Use Audits and Appeals

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Meaningful Use Expert, Jim Tate, has a really interesting post up on his Meaningful Use Audits website that shares some of the details CMS offered on the EHR incentive audits and appeals process. I know many of my readers are worried about the meaningful use audits and are interested in these details.

You can go and read Jim’s full post for all the details, but I wanted to highlight a few of the items he mentions.

First, CMS said that 5-10% of providers will be subject to pre/post-payment EHR incentive audits. Jim calls this casting a “wide net” for the MU audits. Considering meaningful use stage 1, it makes some sense why the MU audit net would be cast wide. I’m sure many who read this have a friend who’s been through the audit.

I was really intrigued that CMS said “If a provider continues to exhibit suspicious/anomalous data, could be subject to successive audits.” This reminded me of something my brother said about the military. He said that if you got your uniform inspection right the first couple times, then the officers would stop looking at you quite as much. However, if you had something wrong at first, be ready to be scrutinized. It seems like CMS is taking a similar approach. As in most things in life, it’s just better to be honest and accurate. Then, you don’t have to look over your shoulder.

Jim also notes that CMS said that no risk profile will be made public. Basically, we aren’t going to get any clue into how they chose who to audit. Plus, Jim notes that the only next step if you fail an meaningful use audit is to file an appeal.

As long as we have meaningful use tied to EHR incentive money and payment adjustments, I don’t see these MU audits going anywhere. So, if you’re attesting to meaningful use, make sure you’re prepared for an MU audit if it comes.

February 11, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

Of Meaningful Use – I wouldn’t remove anything!

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The following is a guest blog post by Joel Kanick in response to the question I posed in my “State of the Meaningful Use” call to action.

If MU were gone (ie. no more EHR incentive money or penalties), which parts of MU would you remove from your EHR immediately and which parts would you keep?

Joel Kanick
Joel Kanick
President and CEO of Kanick And Company and Lead Developer and Chief Architect of interfaceMD

In fact, the pursuit of Meaningful Use (MU) certification has given our company many new ideas that allowed us to go above and beyond the bar MU already set.

Initially, doctors bought into EMRs for the financial incentive. Now that they are educated consumers, they want everything that was promised to them to work for them. Doctors have learned that EMRs are only one small part of the Healthcare Information Technology (HIT) puzzle. They need help putting the rest of the puzzle together.

No one is complaining about MU regarding the direction it is taking healthcare or HIT industries.

Any complaining that comes from a vendor is usually because their technology is outdated and behind the technology curve. They are angry because MU is calling them out. So, shame on vendors for becoming rich, fat and lazy, and not keeping with current technology.

Of the complaints I hear from providers, there are two scenarios:

First scenario: the providers who resent the government telling them how to practice medicine. However and upon deeper review, these providers already ask and track most of all these data points. They just don’t like the way it has been required and thus crammed into their current systems. I understand their anger, they were not consulted as to how to fit all this into their workflow and so it is cumbersome to use.

Second scenario, the providers’ office is still using fax machines, some required by their EMR vendor. They are still dictating (PCs, iPhone apps, phone recorders) all their exam data and still relying on paper charts. In practices of all sizes, providers complain of MU because they don’t want to change how they operate their business. After all, they have been doing it this way for many years, successfully. They complain of this change because they fear the unknown.

They are doctors; highly skilled and highly educated in medicine but not in business or technology. I see so many doctors closing their privately held medical practices to join a group practice or a hospital setting. Most will freely admit that it’s because they don’t want to address the fear and go through the anticipated pain of migrating to a paperless environment. They don’t know how to choose or maintain the system, with or without MU.

What I know MU is positively doing:

  • Setting a standard language (ie: XML)
  • Setting a standard format (ie: HL7)
  • Setting a secure communication channel (ie: Direct Protocol)
  • Requiring patient portals to potentially aid in convenience to the patient and lower the workload on office staff
  • Creating a standard method to share data electronically (ie: CCDA)
  • Demanding security and encryption and planning for emergency scenarios
  • Utilizing eRx to reduce fraud, abuse and increase safety in drugs that are prescribed
  • Reducing paperwork (eg: lab requests), speeding-up information delivery (eg: lab results electronically instead of by paper delivery)
  • Promoting communication to educate patients
  • Demanding reconciliation of data when exchanged between two organizations to make certain correct information is gained

Selfishly, from my point of view, the largest complaint regarding MU2 is that it requires all pertinent health information be exported and imported in a standard format allowing providers to easily change EMR vendors. This MU requirement should scare some EMR vendors!

Effectually, MU is pushing change and as a result it is getting a bad rap.

See other responses to this question here.

February 5, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.

CCHIT to Leave the ONC Certification Business

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Update: Multiple people sent me the email that was sent to CCHIT certified EHR vendors that details this decision. In the email, along with what’s detailed below, CCHIT suggests a transition to ICSA Labs for EHR certification and talks about a new allegiance with HIMSS to provide new programs and policy guidance including a series of summits and events to support that work. I’m still waiting for an official response from CCHIT and will update the post if they respond.

Update 2: Here is CCHIT and HIMSS press release about the change and also ICSA Labs comments on the change. Drummond Group also issued this response.

I recently got word from a source close to the EHR certification world (yes, that could be just about any EHR vendor or EHR consultant) that CCHIT is about to announce they are leaving the ONC Certification business. I was told that CCHIT will test those that are already in the pipeline, but will not continue as an ONC EHR certifying body. I’d still classify this as a solid rumor for now (I emailed them for comment, but still haven’t gotten a response. I’ll update the post if I do.), but it comes from a reliable source. Plus, CCHIT did just cancel their weekly webinar series. No point in doing the webinar series if you’re not going to be certifying EHR anymore.

Whether the rumor is true or not, it’s worth considering the EHR Certification bodies and what would happen if any of them decide to not go forward with EHR certification. It will likely have a major impact on the meaningful use program.

I don’t think we should be surprised by this decision if indeed it is the case. CCHIT was started years before ARRA and meaningful use. They were created with a cost structure that was higher because they were charging a lot more for their EHR certification when they started. Once ARRA hit, CCHIT was marginalized and as EHR certification was commoditized and codified, CCHIT became irrelevant. Plus, with three new competitors certifying EHR, the prices for EHR certification dropped dramatically.

Furthermore, I think that all of the EHR certifying bodies are finding that 2014 EHR Certification is much more complex and time consuming than the 2011 certification. Yet the price to certify is basically the same. To me, the economics of the EHR certification business were never good.

Think about the business. Let’s say you get paid about $30,000 per EHR certification. There are only 600 customers (at the time we thought it was closer to 300) for your entire business and many of those don’t even pay the full $30k. Enter in 3 competitors and you’re now sharing a market of less than $18 million or $4.5 million per certifying body. Not to mention the stimulus is for only 5 years with many of the EHR vendors likely to consolidate, stop certifying, or go out of business. Plus, EHR certification is not a high margin business and requires expensive government certification. The economics just aren’t that exciting as an entire business.

This rumor is also interesting when paired with the comments I’ve heard that the EHR certification bodies have a backlog of EHR vendors that are trying to get 2014 certified. They’re having to schedule their testing day months out. If CCHIT gets out of the EHR certification business, then that will only increase the delay in 2014 EHR certifications. I wonder if this will lead to another call for a delay in meaningful use stage 2. Can it be delayed now that some have already started MU stage 2?

I’ve never been a fan of EHR certification. I think it represented a lot of cost and very little value to the EHR industry, doctors and patients. I’ll never forget when I asked Marc Probst, Intermountain CIO and member of the ONC committee that worked on EHR certification, why we needed EHR Certification if people had to show meaningful use of the requirements. If you can show meaningful use of a requirement, then the software can certainly do that requirement, no? He answered, “I lost that battle.”

Whether this rumor is true or not, the next couple months are going to be really interesting months for EHR vendors. How many will get across the 2014 EHR Certification line in time? How many will fail in the process? Will the ONC-CHPL be able to keep up? If CCHIT does leave ONC EHR certification behind, what will they do next? Can CCHIT do something to make themselves relevant again?

January 28, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently 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.