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.

A reader posed the following question: What happens if a physician receives a Medicaid EHR incentive in 2011, no longer meets the 30% eligibility threshold for Medicaid in 2012 and therefore elects not to apply for any incentive that year, and then has to switch to the Medicare program in 2013 because his Medicaid volume is still too low to qualify under Medicaid? Below is a follow-up to a prior post, (“Switching Between Medicare and Medicaid Incentive Programs”), that provides the additional information needed to not only answer this particular question, but also to evaluate the financial impact of other scenarios in which a provider might skip years and/or switch between programs. 

Here are the rules regarding switching programs and skipping years:

• An EP can switch between programs only once after receiving his first incentive payment, and the switch must occur in 2014 or earlier.
• When an EP switches programs, he is “placed in the payment year he would have been in had he begun in—and remained in—the program to which he has switched.”
• Medicare and Medicaid treat skipping years differently. Medicare incentives require that payment years be consecutive—so while an EP can skip a year, if he does, he forfeits that year’s incentive permanently. Medicaid incentive payments, on the other hand, can be non-consecutive with no adverse impact on total available revenue.
• The last year that payments will be available also differs between the two programs. Under Medicare, no payments will be made after 2016, whereas EPs have until 2021 to earn incentives under Medicaid.
• Although an EP who switches to or from the Medicare program could—under certain circumstances—earn more than the total Medicare incentives ($44,000), in no cases would any EP be paid more than the maximum available under Medicaid ($63,750). 

To get back to the physician in the reader’s question, when he switches to the Medicare program after skipping 2012, 2013 would be considered (and paid as) his third payment year. 

Confused? To analyze the financial implications of switching programs and/or skipping a year under scenarios that might apply to your practice, make a chart and do the math—taking into account the above rules and the schedules of annual incentives.

I’m sure many of you are recovering from the Super Bowl right now. I got exactly what I wanted from the Super Bowl: a great game. I didn’t care too much either way, but I am glad that I predicted the Giants to be the winners. Too bad I’m not a betting man. Although, I guess that’s the trick with betting….but I digress.

Time for my regular weekend round up of interesting things happening in the healthcare IT and EMR twittersphere. We’ve got some really interesting tweets this week. Here we go.

@NateOsit We also have a webinar of @eCollab12 for those that wont’ be able to make it to #HIMSS12.ecollab12.eventbrite.com #hitsm

— Leonard Kish (@leonardkish) February 3, 2012

When I created and posted my list of HIMSS 12 sessions, they hadn’t created the agenda for the eCollaboration Forum at HIMSS and so I couldn’t add any sessions. However, the eCollaboration Forum at HIMSS 12 agenda is up now, so check it out. I know there are a number of sessions I’m going to add from the forum. I also love that they have the online option linked in this tweet for those not attending HIMSS 2012.

Yes, stage 2 #meaningfuluse NPRM will be out before #HIMSS12. meaningfulhitnews.com/2012/01/30/yes… #healthIT #ONC #CMS #hitpol #EHR #EMR

— Neil Versel (@nversel) January 31, 2012

This is really important news. I think a lot of us are REALLY interested to see the final meaningful use stage 2 details. Good find by Neil Versel.

Speaking doctor-to-doctor(s) using healthcare social media bit.ly/wiqbyu #hcsm #hcsmeu

— H2Online (@H2Ohu) January 30, 2012

I’m sure we’re going to continue seeing the trend of more and more doctors gleaning value from engaging in social media. At a minimum doctors are going to start finding more and more new patients using social media including things like physician blogging. A well done practice website and social media effort is going to be really valuable for the doctor of the future.

3 reasons why you should start a blog for your hospital bit.ly/ypCE78 #hcsm #blogging

— Mark Ragan (@MarkRaganCEO) January 30, 2012

Yes, blogging will also help hospitals in a number of ways too. Social media can benefit hospitals, doctors, practices, etc.

@DonRosenthal Tablets are for content consumption. PCs are for content creation. Much more intellectual flexibility w/ PCs. #HITsm

— Erica V. Olenski (@TheGr8Chalupa) February 3, 2012

I was fascinated by this tweet. First because I wonder what changes will make tablets more than just great for content consumption. Second, the idea of PCs being more intellectually flexible.

RT @patientslikeme: “my healthcare data is not nearly as portable/accessible as my financial data.” @jeff_cole #hcsm

— Jacqueline Thong (@jacthong) January 30, 2012

I know there are reasons why financial data is more portable and accessible than healthcare data, but it still irks me that we haven’t overcome those reasons…yet!

In a previous Meaningful Use Monday we wrote about a bunch of the Meaningful Use 2011 statistics that were put out by ONC and CMS. I know that my readers love statistics and information about Meaningful Use. Carl Bergman sent me a PDF file that contained some really interesting data on Meaningful Use stage 1 in 2011. The first pages we basically covered in the previous post, but starting on about page 10 or so there are some more detailed numbers.

Take a look at let us know which numbers you find interesting and/or unique.

If you are on of the 355 Eligible Providers who unsuccessfully attested to MU last year, CMS now offers an appeals process for both the Medicare and Medicaid programs. Here’s the section on appeals for EHR Incentive programs:

Starting December 1, 2011, CMS is accepting appeals for eligible professionals and eligible hospitals.

For general questions and for information on how to file an appeal, eligible professionals (EPs), eligible hospitals, critical access hospitals, Medicare Advantage Organizations, and Medicaid eligible hospitals may contact OCSQ’s designated appeal support contractor via the toll free number between 9 a.m. and 5 p.m. EST, Monday through Friday or via email.

1. Toll-free number: 855-796-1515
2. Email: OCSQAppeals@provider-resources.com

The Centers for Medicare & Medicaid Services (CMS), Office of Clinical Standards and Quality (OCSQ) is providing guidance on how to file an appeal.

If you click through to the How to File an Appeal link, it says that the final rule provides guidance and requirements for a Medicaid appeals process, but does not provide an appeals process for the Medicare EHR Incentive program. Although it also says that “CMS is currently implementing an appeals process for the EHR Incentive Program.”

It does also say that Provider Resources, Inc. (PRI) located in Erie, Pennsylvania was awarded the contract to handle the appeals process with the Office of Clinical Standards and Quality (OCSQ) overseeing the EHR incentive appeals process. Otherwise, it’s still pretty vague on the exact details of the appeals process other than the contact info.

I’ve read that beginning in February, appeal decisions will be posted on CMS’s Website under the Office of Clinical Standards and Quality. I hope that there’s some really good transparency in these postings so that those attesting to meaningful use in the future will be able to learn from people’s past mistakes.

If you’re someone that was denied and is going through the appeals process, I’d be interested to hear about your experience so we can share it with others that will need to do the same.

HITECH Answers recently posted a great post that gives a run down of the EHR Incentive program’s progress in 2011. Here’s their list with my own analysis and commentary of each point.

123,921 Eligible Professionals have registered for EHR Incentives, 15,255 have successfully attested to meaningful use in the Medicare program.
This seems like such a HUGE difference in numbers. That’s just over 12% of Eligible Professionals that registered attested to meaningful use. Does this mean that we’re going to see a tidal wave of meaningful use attestation in 2012? Possibly.

I believe that we’ll see more eligible professionals attesting to meaningful use in 2012. However, the question is how many of those other 108,666 will attest to meaningful use in 2012 and how many are like the Happy EMR Doctor who just registered to see the MU process. I wonder how many first hand meaningful use experiences by doctors will scare doctors away from MU attestation.

3.077 Eligible Hospitals have registered EHR Incentives and 604 of those have successfully attested to meaningful use.
This is almost 20% of hospitals that have registered that have attested to meaningful use. It’s not surprising that this number is a lot higher than eligible professionals. I still believe that the wave of meaningful use attestation will come from these other 2473 hospitals and probably many more that still haven’t registered. I haven’t seen a good number of how many hospitals are in the US. Does anyone know that number? The EHR incentive money that goes to hospitals will dwarf those of eligible professionals.

$2,533,689,145 has been paid out in Medicare and Medicaid Incentives.
$2.5 billion sent out in 2011. I just went back to the first time I tagged meaningful use on this site on April 3, 2009 (coincidentally I have 19 pages of 10 posts each tagged with Meaningful Use). Amazing to think that it’s taken basically 3 years to spend $2.5 billion on EHR.

277 hospitals have received payments under both Medicare and Medicaid and of those 12 were CAHs.
That’s about half of the hospitals that have attested to meaningful use under Medicare are also getting the Medicaid EHR incentive money as well.

22% of eligible professionals that have been paid EHR incentives are Family Practitioners and 20% are Internal Medicine.
I must admit that I would have thought that the percentage of family doctors that got paid EHR incentive money would have been a lot higher. I guess when you have so many other specialty areas I shouldn’t be that surprised. I also wonder why the internal medicine number is so high. These numbers actually make me believe that a lot of family practice doctors are sitting out when it comes to meaningful use.

41 States Medicaid programs were open for registration. Two additional States launched in January of 2012.
I wonder what’s holding back the other 7 states. From what I’ve seen all the states will eventually get there.

More than 1500 EHR products have been certified by ONC-ATCBs.
That’s a lot of EHR software. I still put the EHR company list at about 300 EHR vendors. 1500 includes multiple versions of the same software, partial EHR certification for products like data warehouses, ePrescribing, etc. The best thing that’s come from the ONC-ATCB program is that it has made EHR certification basically irrelevant in the EHR selection process. Every EHR vendor is certified now. This is much better than the false assurances that EHR certification provided before. I still dislike what EHR certification has done to the industry, but at least it’s not misleading doctors the same way it was before.

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.

Having just experienced the attestation process firsthand as I watched an SRS client successfully attest to meaningful use, I am happy to report that this part of demonstrating meaningful use is relatively easy—a bit tedious if you are attesting for multiple providers, but not at all difficult. CMS has created a user-friendly, web-based attestation system. Assuming that your EHR provides the information you need in a useful format, you have successfully met all the required measures, and you come prepared, there should be no reason to have an unsuccessful attestation.

Here are some tips that will ensure your success:

• Register in advance: Even though you can register as late as at the time of attestation, the combined task would be overwhelming—particularly if you are attesting “on behalf of” a provider. Registering in advance ensures that everything is up-to-date in NPPES and PECOS and that you have all the necessary information.
• Make sure that all measures have been met: If your EHR does not show the percentages for measures that have thresholds, do the math yourself to verify your success on each one. CMS offers a worksheet that you might find helpful for this purpose. Verify that you have also met all other (non-numerical) measures. If you fail to satisfy even one measure, do not attest now—go back and try another reporting period.
• Have documentation for each provider:
  - Registration confirmation page with registration ID#

  - Password

  - EHR certification number

  - Reporting period dates (make sure it covers at least 90 days)

  - Printout of all meaningful use measures: numerators and denominators, exclusions and reasons

    (when there is more than one possible reason)

  - Clinical Quality Measure report: numerators, denominators, exclusions

• Do not hit “Submit” until you have reviewed the “Attestation Summary” page: Double check your data. Make sure that you have said “yes” to all yes/no measures and that your numbers are entered accurately. The summary page does not display percentages, so you have to do the math yourself to be sure that you meet the thresholds.
• Submit attestation and print the “Submission Receipt” as confirmation: If you have done everything correctly it will state that “all measures are accepted and meet MU minimum standards.”

While not necessary, I highly recommend having a second person help you attest. A second set of eyes will shorten the time the process takes and will reduce the potential for errors in posting your data.

A couple quick tweets to welcome your new week. Both tweets stand on their own and link to some good reads for those interested in the topics. The second one is particularly good since it’s John Halamka’s 2011 wrap up across all the various parts of John Halamka’s life. Let me know what you think of both reads.

Very good guidance on accounting and reporting for #EHR incentive payments bit.ly/xuX9Un

— Brian Ahier (@ahier) January 7, 2012

Healthcare CIO on 2011: #EHRs…added features for certification resulting in…lack of #usability & #workflow integration ehr.bz/lv

— Charles Webster, MD (@c_wb) January 2, 2012

I have to admit, I’ve really enjoyed going through and making lists looking back on EMR and Health IT in 2011 and thinking about what is going to happen in EMR and Health IT in 2012. Thanks for everyone who has joined and added to the discussion. It’s been really great!

This next list might actually be the hardest one for me to create. I call it the 2012 EHR and Health IT Noise. You know what I’m talking about. The topics that are going to get talked to death, tweeted everywhere, but won’t really have any major impact on healthcare (at least in 2012). Some would call these distractions.

HIE – Yes, we’re going to hear more and more about HIE’s and their potential. 2012 will still enjoy all that federal grant money that was given to HIE’s. What will we see from it? Maybe a couple books describing lessons learned from all the money spent on trying to set up an HIE. If one or two HIE’s are successful and start sharing patient data with doctors I’ll be really impressed.

EHR Usability – In 2012 I predict we’re going to hear story after story about the lack of usability with EHR software. The complaints will start to pile up, but I don’t think any of that noise will do much to shift the usability of EHR software. It’s a really hard task to dramatically shift the usability of EHR software after the fact. I can’t see many of the legacy EHR accomplishing that shift.

Some new EMR startups may start to come into their own in 2012 with usable EHR software, but they likely won’t be heard above the noise of the other legacy EHR software that’s practically unusable. We’re in a selling spree cycle for EHR software, maybe 2013 will change that.

Mobile Health Apps – This is a little different noise than the others above. This will be noise because there will be so many mobile health apps out there in 2012 and none of them will really consolidate market share yet. I believe that a number of mobile health apps will start to differentiate themselves in 2012, but most people won’t know the difference. They’ll just hear all the noise and try and ignore it.

Meaningful Use – Oh wait, I already wrote about that one here. If you haven’t read the comments of that post, you should. Some good discussion.

Any other things you think will make noise in EMR and Health IT in 2012? I’d love to hear your additions.

As I said in my previous EMR and Health IT in 2012 post, I’m going to create some of my own lists for 2012. I decided to tackle the first one on the list: My 2012 EMR and Health IT Wish List. This was kind of fun to think about. I’m also sure that I’ll come up with other ideas once this is posted, so don’t be surprised if I add things to this list in a future post.

I should also note that I’m not sure any of these things are going to happen in 2012. In fact, I bet that many of them aren’t, but this list isn’t about what is going to happen. This list is about what I wish would happen.

EHR Companies Would Embrace Interoperability – It’s an incredible shame that in 2012 we still don’t have interoperable health records. EHR companies need to get off the stump and make this a reality. The technology is already there and has been there for a while. EHR companies need to start making this dead simple because it’s the right thing to do. Sometimes doing the right thing is more important than the bottom line. Plus, doing the right thing ends up often being the best long term strategy for your bottom line as well.

Start doing what’s right and making your EHR interoperable!

Meaningful Use Would Go Away – I’m actually certain that this one won’t be happening in 2012, but I wish it would. I guess there’s a small chance that it could go away if Republicans take control of Washington and start slashing everything Obama related. However, I have a feeling that even then meaningful use will find its way back into Washington. There’s too much invested in it.

My reasoning for wanting meaningful use gone is clear. It provides a perverse incentive to providers and often incentivizes them to choose an EHR software that doesn’t work well for their practice. As I’ve mentioned in some recent posts, far too many clinics are so focused on meaningful use and EHR incentive money that they’re ignoring the real and tangible business cases for implementing an EHR in their clinic. I think this is a bad thing for healthcare and EHR software in general. The short term bump in EHR adoption won’t be worth the cost of EHR implementations focused on the wrong criteria.

I also really hate how meaningful use has hijacked the software development cycle of pretty much every EHR vendor out there. This is a real travesty since rather than developing for user/customer requirements EHR vendors are developing for a criteria. Talk about a perfect method for destroying innovation. This is a real travesty in my opinion.

Of course, I’m a realist and realize that meaningful use isn’t going away. We have to make the most with what we’re given and live with the realities that exist. However, in this New Year Wish list, I wish that meaningful use would be a past memory.

New Healthcare Model that Provides Care, Not Reimbursement – I’m sure many of you might be thinking that I’m calling for ACO’s in this wish list item. We’ll see how ACO’s evolve, but my gut tells me that the ACO model still won’t make the fundamental change that I wish would happen in healthcare. There’s far too much focus on reimbursement the way our healthcare is structured today. I’m not arguing that doctors and other healthcare professionals not get paid what they deserve. I’m just wishing that there was more focus on care for patients and less worry on maximizing the reimbursement.

How does this have to do with health IT and EHR? I’ve long argued that the biggest bane to EHR systems is the onerous reimbursement requirements. I can’t imagine how much healthcare could benefit from fabulous EHR systems if the energy spent on maximizing reimbursement were spent on improving patient care.

Diabetes Prevention App – I’ll admit that this is a little personal. I come from a long line of diabetes in the genes and I love sweets far too much. I’m pretty much destine to be a diabetic. I think that mHealth apps can have amazing power if done correctly. My wish is for someone to create a Diabetes app that will help me overcome the seeming destiny I have in this regard. The key will probably be illustrating in a profound way the impact of the choices I’m making.

Of course, you could insert hundreds of other chronic illnesses into this wish list too. I’d love to see mobile health work to solve those as well.

A True Patient Identifier – I realize that America is a large place, but we’re also a really creative country that can figure out creative solutions to problems. The lack of a true patient identifier is a challenge and a problem in healthcare. I’d love to see this problem finally resolved. I think every EHR company would rejoice at this as well.

Real EMR Differentiation – My heart absolutely goes out to doctors, practice managers and others who have the unenviable job of trying to sift through the 300+ EMR companies. I’d love for some EMR companies to really do something so innovative to differentiate themselves from the rest of the pack.

No doubt part of this problem is what I stated above about meaningful use. Hard to create innovation and differentiation in EHR when you have to develop for a government list of requirements.

EHR Data Liberation – I’ve wanted EHR data Liberation for a long time, but I think in 2012 this is one thing on the list that could become a reality. It’s a bit of a long shot, but I think there’s potential for this to happen.

My gut tells me that if we can find a way to liberate the data that’s stored in EHR software, then we’d see a dramatic increase in adoption of EHR. One of the major concerns doctors have with selecting an EHR is that once they select an EHR they know they’re locked in with that EHR for the long run. If a doctor knew that they could switch EHR software if they made a bad choice, then they’d be much more likely to pull the trigger on EHR adoption.

We need a wave of EHR vendors that aren’t afraid of liberating their EHR data, because they:
1. Know that their EHR software is so good users won’t leave
2. Know that if someone wants to leave their EHR software it’s better that they find one that’s good for them than the few extra dollars the EHR company will make off an unhappy user.

How’s that for a wish list? I think achieving these things would do an amazing amount of good in healthcare and EHR. Of course, I won’t be holding my breathe on any of them happening any time soon. That doesn’t mean I won’t keep holding out hope.

As I mentioned in my last post, I’m going to take some time over the next week or so to look ahead to 2012 and discuss what I think is going to happen in the world of EMR and health IT. Since today is the regularly scheduled Meaningful Use Monday, I decided that it would be appropriate to take a look forward at Meaningful Use in 2012.

In many ways, 2012 is not going to see any major public shifts in meaningful use. Sure, we’re going to learn more about meaningful use stage 2, we’re also going to finally get out of the temporary EHR certification to the permanent EHR certification (unless something crazy happens). Although, I don’t think either of those things are going to make much real difference in the lives of doctors. Instead, there’s going to be an undercurrent of other trends that shape the future of EHR incentives and meaningful use.

Here we go:

Doctors First Hand Experiences – As Dr. Koriwchak notes in his physician perspective on meaningful use, there aren’t that many first hand experiences out there from physicians discussing their experience with meaningful use. Most of what you find out there are physicians that have been asked by their EHR vendor to be the face of that EHR vendor’s meaningful use efforts.

In 2012, whether published publicly or heard through the grapevine, doctors first hand experience with EMR implementations, EHR incentive and meaningful use are going to start filtering through the medical community. I bet Dr. Koriwchak isn’t going to be alone in his assessment that basically, I survived meaningful use, but recommend staying away. If this is the message about meaningful use that spreads, then expect more people like Dr. West opting out of Medicare or just accepting the possible EHR penalties.

Meaningful Use Audits – We know that audits of those who took EHR incentive money are coming. I think that CMS (I think they have authority over this, right?) will be generous with their audits. They won’t make it easy and fun for the person who gets audited and fails. However, I don’t think they’re going to try and make a public disgrace of those that have their meaningful use attestation audited. Doing so would set back the entire program. Instead I think CMS will try and spread the message that they’re serious about honest meaningful use attestation, but that they’ll be reasonable in their approach.

Checks Flowing Ok, so it won’t really be checks since most of the payments are going to be wired into doctors bank accounts, but you get the idea. Either way, there’s going to be a lot of doctors that are finally going to get paid for their EHR effort in 2012. This will no doubt invoke some portion of envy in their physician peers. I know I’d hate having my doctor friend getting a check and me not getting it. I felt this same way when people were buying houses and getting the government money for buying a house a couple years ago. Doctors won’t be immune to this sort of “jealousy” of their peers.

The real question is whether the money flowing will be a stronger force on EHR adoption or whether the above mentioned meaningful use pains will be stronger. As you see in my next two predictions, I think it is a split verdict.

Hospitals Capitalize – My best prediction is that hospitals will see the money flowing and be unable to resist following the money line. We’ve already largely seen this shift in hospitals IT projects. I know a number of healthcare entrepreneurs who have said that hospitals aren’t really doing any major IT projects outside of meaningful use. Hospitals will continue this trend and will likely end up taking the majority of the EHR stimulus money that’s being paid out.

Small Doctors Offices Stay Away – As I wrote about previously, most EHR incentive money is being paid to existing EHR users. In 2012 we’ll be moving past those existing EHR users and I predict that most small doctors offices will continue to sit on the sideline of EHR. The money isn’t large enough for small doctors to overcome all the work required for them to implement an EHR and the EHR penalties are a drop in the bucket for most of these doctors.

I imagine that many will be thinking, “What about the other EHR benefits beyond EHR stimulus money?” To that I’d say, you’re absolutely right. There are plenty of other benefits to having an EHR that don’t include government money for EHR. Unfortunately, the free government money has created this myopic view of the world where those other benefits have lost all their appeal.

Ok, you’re turn. Any other things you see happening with meaningful use in 2012? Any of my meaningful use predictions that you disagree with?