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Karen DeSalvo and Jacob Reider Leave ONC

Posted on October 24, 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

It’s been a tumultuous few months for ONC and it’s just gotten even more tumultuous. We previously reported about the departures of Doug Fridsma MD, ONC’s Chief Science Officer, Joy Pritts, the first Chief Privacy Officer at ONC, and Lygeia Ricciardi, Director of the Office of Consumer eHealth, and Judy Murphy, Chief Nursing Officer (CNO) from ONC. Yesterday, the news dropped that Karen DeSalvo, ONC’s National Coordinator, and Jacob Reider, ONC’s Deputy National Coordinator, are both leaving ONC as well.

Karen DeSalvo has been tapped by HHS Secretary Sylvia Mathews Burwell to replace Wanda K. Jones as assistant secretary of health which oversees the surgeon general’s office and will be working on Ebola and other pressing health issues. I think DeSalvo’s letter to staff describes it well:

As you know, I have deep roots and a belief in public health and its critical value in assuring the health of everyone, not only in crisis, but every day, and I am honored to be asked to step in to serve.

DeSalvo’s always been a major public health advocate and that’s where her passion lies. Her passion isn’t healthcare technology. So, this change isn’t surprising. Although, it is a little surprising that it comes only 10 months into her time at ONC.

The obvious choice as Acting National Coordinator would have been Jacob Reider who was previously Acting National Coordinator when Farzad Mostashari left. However, Reider also announced his decision to leave ONC:

In light of the events that led to Karen’s announcement today–it’s appropriate now to be clear about my plans, as well. With Jon White and Andy Gettinger on board, and a search for a new Deputy National Coordinator well underway, I am pleased that much of this has now fallen into place–with only a few loose ends yet to be completed. I’ll remain at ONC until late November, working closely with Lisa as she assumes her role as Acting National Coordinator.

As Reider mentions, Lisa Lewis who is currently ONC’s COO will be serving as Acting National Coordinator at ONC.

What’s All This Mean?
There’s a lot of speculation as to why all of these departures are happening at ONC. Many people believe that ONC is a sinking ship and people are doing everything they can to get off the ship before it sinks completely. Others have suggested that these people see an opportunity to make a lot more money working for a company. The government certainly doesn’t pay market wages for the skills these people have. Plus, their connections and experience at ONC give them some unique qualifications that many companies are willing to pay to get. Some have suggested that the meaningful use work is mostly done and so these people want to move on to something new.

My guess is that it’s a mix of all of these things. It’s always hard to make broad generalizations about topics like this. For example, I already alluded to the fact that I think Karen DeSalvo saw an opportunity to move to a position that was more in line with her passions. Hard to fault someone for making that move. We’d all do the same.

What is really unclear is the future of ONC. They still have a few years of meaningful use which they’ll have to administer including the EHR penalties which could carry meaningful use forward for even longer than just a few years. I expect ONC will still have money to work on things like interoperability. We’ll see if ONC can put together the patient safety initiative they started or if that will get shut down because it’s outside their jurisdiction.

Beyond those things, what’s the future of ONC?

CMS’ HIPAA Risk Analysis Myths and Truths

Posted on October 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ve been writing about the need to do a HIPAA Risk Assessment since it was included as part of meaningful use. Many organizations have been really confused by this requirement and no doubt it will be an issue for many organizations that get a meaningful use audit. It’s a little ironic since this really isn’t anything that wasn’t already part of the HIPAA security rule. Although, that illustrates how well we’re doing at complying with the HIPAA security rule.

It seems that CMS has taken note of this confusion around the HIPAA risk assessment as well. Today, they sent out some more guidance, tools and resources to hopefully help organizations better understand the Security Risk Analysis requirement. Here’s a portion of that email that provides some important clarification:

A security risk analysis needs to be conducted or reviewed during each program year for Stage 1 and Stage 2. These steps may be completed outside OR during the EHR reporting period timeframe, but must take place no earlier than the start of the reporting year and no later than the end of the reporting year.

For example, an eligible professional who is reporting for a 90-day EHR reporting period in 2014 may complete the appropriate security risk analysis requirements outside of this 90-day period as long as it is completed between January 1st and December 31st in 2014. Fore more information, read this FAQ.

Please note:
*Conducting a security risk analysis is required when certified EHR technology is adopted in the first reporting year.
*In subsequent reporting years, or when changes to the practice or electronic systems occur, a review must be conducted.

CMS also created this Security Risk Analysis Tipsheet that has a lot of good information including these myths and facts which address many of the issues I’ve seen and heard:
CMS HIPAA Security Risk Analysis Myths and Facts

Finally, it’s worth reminding people that the HIPAA Security Risk Analysis is not just for your tech systems. Check out this overview of security areas and example measures to secure them to see what I mean:
CMS HIPAA Security Risk Analysis Overview

Have you done your HIPAA Risk Assessment for your organization?

Meaningful Use Hardship Exceptions Reopened

Posted on October 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

CMS has announced its intent to reopen the Meaningful Use Hardship Exceptions filing period and set the new deadline for MU hardship exceptions to November 30, 2014. With the new hardship exception extension, providers can now choose from a number of reasons why they were unable to attest in time. Here’s the details from the CMS announcement:

This reopened hardship exception application submission period is for eligible professionals and eligible hospitals that:
* Have been unable to fully implement 2014 Edition CEHRT due to delays in 2014 Edition
CEHRT availability; AND
* Eligible professionals who were unable to attest by October 1, 2014 and eligible hospitals that were unable to attest by July 1, 2014 using the flexibility options provided in the CMS 2014 CEHRT Flexibility Rule.

These are the only circumstances that will be considered for this reopened hardship exception
application submission period.

This is a big move since the meaningful use hardship exceptions deadline for hospitals was April 1, 2014 and July 1, 2014 for eligible professionals. I imagine there are many organizations that will benefit from this extension. Although, there are probably quite a few organizations that wish they’d known about this exception before now or that think the exceptions are too narrow (ie. they can’t benefit from them).

What are your thoughts on this extension?

5 Ways Patient Engagement Can Benefit Your Bottom Line

Posted on October 7, 2014 I Written By

The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
Barry Haitoff

Patient engagement is a popular topic with policy makers and patient advocates. They see the obvious benefits of an involved patient helping to improve their own health and eventually lower costs. Unfortunately, most doctors just see patient engagement as unreimbursed work. The majority of them can see the healthcare benefit of engaging the patient, but they have a much harder time seeing the financial benefits to them for doing so.

With that in mind, let’s take a look at some of the ways engaging your patient can benefit your bottom line:

Meaningful Use Requirements – This was the easy one. Meaningful Use stage 2 requires an organization to engage with at least 5% of their patient population. This is how serious the government is about patient engagement. The 5% requirement means that the $44k-$65k in EHR incentive money is tied to your ability to engage with patients. For those who aren’t interested in the EHR incentive money, you’ll still be subject to the 1-5% EHR Medicare penalties that are quickly approaching (start in 2015).

Get Paid – I’m sure that many doctors don’t think of this as patient engagement, but it’s a very important part of your engagement with the patient. There’s a growing trend towards high deductible plans where the patient is shouldering more of the financial burden for their care. Finding multiple ways where you can engage with the patient and collect their portion of the bill is going to become increasingly important. Many new patients don’t even check their snail mail regularly. This means you’re going to have to find new electronic methods for collecting payments (ie. engaging the patient electronically). We’ve seen significant success with the implementation of automated calls (IVR) and patient payment portals.

Drive New Patient Referrals – In some areas of the country this isn’t an issue, but many doctors live in an area where attracting patients is highly competitive. Since the start of medicine, one of the best ways to get new patients is through patient referrals. Providing great customer service is a fantastic way to increase the number of patient referrals you receive. (yes, patients are a type of customer). Superior patient engagement is one way to demonstrate great customer service. In fact, I believe many patients will start choosing their doctor based on the quality of engagement they get as patients.

Engage Pre-patients – How do you convert a visitor to your website into a patient? The simple answer is that you engage with them on your website (Side Note: your phone number on your website is not engagement). Many practices are afraid of engaging with patients on their website because they think that patients are trying to get a free consult without having to come into the practice. From my experience, this is a minor issue and is far surpassed by the number of new patients you can find on your website. When you engage the visitors to your website, you turn those who were on the fence about scheduling an appointment into actual appointments. Plus, much of this engagement can be done by your office staff. Think of it like a virtual telephone and answering machine for your office.

Increase Adherence – Many of you might be asking how increased patient adherence can benefit a practice’s bottom line. Let’s go back to the patient referral comments above. The best way to ensure someone provides your name as a referral to their friend is for you to help a patient get better. Ensuring adherence and health improvement is the ultimate customer service and a great way to create a true patient ambassador for your office.

ACOs and Value Based Reimbursement – While we’re still currently living in the fee for service world of healthcare, the powers that be are pushing towards value based reimbursement and Accountable Care Organizations (ACOs). As part of this shift, your reimbursement will be tied to how effectively and efficiently you care for your patient population. Engaging the patient in ways that are efficient and improve the quality of care you provide are going to be the bedrock of these initiatives. If you do not engage the patient in a thoughtful way, your future reimbursement will be dramatically less than you’re receiving today.

These are a few examples of why it pays to spend some time and effort engaging with the patient. I’m sure that many of you could add to the list in the comments. What value have you seen in your office from increasing your engagement with patients?

Medical Management Corporation of America, a leading provider of medical billing services, is a proud sponsor of EMR and HIPAA.

What Healthcare Must Plan for in Q4

Posted on September 19, 2014 I Written By

The following is a guest blog post by Ben Quirk, CEO of Quirk Healthcare Solutions.
Ben Quirk
In some ways, 2014 turned out to be not quite as cataclysmic. The early announcement of delaying the adoption of ICD-10 and the more recent announcement to allow hospitals/CAHs and Eligible Professionals participating in CMS’ Meaningful Use programs to attest using their existing Certified Electronic Health Record Technology (CEHRT) took the pressure off healthcare providers scrambling to upgrade their CEHRT to a version that was both ICD-10 and MU-compliant. However, this is only a temporary reprieve through the end of 2014 and there are other priorities that must be addressed before the year ends.

Navigating the ever-evolving healthcare environment will seem much less daunting if you focus on these four areas:

  • Meaningful Use
  • Value-Based Payment Modifiers
  • Transparency
  • Open Enrollment for ACA

Meaningful Use (MU)

If you were not able to upgrade to the 2014 Edition EHR, you will still be able to attest for MU using 2013 criteria. This provides reprieve from the 2014 criteria that requires the implementation of and patient enrollment in a patient portal.

In order to be MU-ready, your organization must proactively:

  • Determine your strategy based on the final rule. Gather data and be prepared to attest for MU by the deadline for the MU program you participate in..
  • Create an audit binder which should include screenshots of required EHR configuration during the reporting period. Should you get an audit 2 years from now, you can refer to this binder for accurate information.
  • Prepare a statement citing why you should be allowed to opt out of those MU measures that you think do not pertain to your practice. Auditors will ask for this on any audit preformed.

All organizations should be prepared to start collecting data for MU 2 by January 1, 2015. This includes having a strategy around the implementation of a patient portal and patient enrollment, sharing data amongst community and other healthcare providers, and radiology interfaces.

Value-Based Payment Modifier

The current Value Based Payment Modifier for providers who serve Medicare beneficiaries is a descendent of the Physician Quality Reporting System (PQRS). It is a way to keep the ACA cost-neutral, but there are some important things you need to know about this newer system. Value-Based Payment Modifier takes claims, Meaningful Use, and physician quality data and rates the quality of care you provide against your peers. Consequently,

  • When you report your Clinical Quality Measures or any clinical data to CMS, make sure your thresholds demonstrate that your practice is providing high quality care.
  • If your practice suffered from vendor problems with data accuracy in the past, this should be fixed.

Transparency

Transparency is something all providers should be aware of. Although available only in a few markets right now, all patients will soon be able to look up information about physicians before deciding where they would like to have their medical procedures done. For instance, if a patient decides to have an ACL repair, s/he can go online to compare exact costs and quality measures (based on the Patient Quality Reporting System) for ACL repair. Practices need to be aware that their prices and quality are being reported publicly. The implications go beyond losing reimbursement. You can actually be delisted from an insurance network. To ensure that your practice remains a viable option for patients:

  • Market your own practice and post your own prices.
  • Make sure you are reporting good quality data.
  • Use sources such as MGMA or OPTUM to see what providers in your area are charging and how you compare.
  • Determine how your reimbursement ranks vs. your competitors on the Medicare website and ensure data accuracy.

Open Enrollment for the ACA

November 15 marks the beginning of the second Open Enrollment period for the Affordable Care Act and there is no indication that this time around will be any easier than the first. Patients will be choosing plans, dealing with things very unfamiliar, and perhaps unaffordable, to them, like deductibles. This directly impacts clinics and the bottom line, especially with those patients who cannot pay their share of the costs. Last year, patients became the number one payor for many practices, even more than insurance companies, because so much revenue came from deductibles. That all resets January 1, but there are things you can do to avoid a possibly painful Q1 of 2015:

  • Check and confirm all patients’ eligibility, what plan they are on, and what their deductible is prior to their scheduled appointment, preferably through an automatic batch eligibility service. Keep this information in the practice management system.
  • Notify patients about their deductibles before they come into the clinic, and make sure to collect payments upfront, or keep a card on file.

The healthcare industry as we knew it for the past many years has ceased to exist. As we move into a new era of integrated delivery systems and a greater emphasis on value-based rather than volume-based reimbursements, the industry is going to remain in a state of flux before it stabilizes once again. The only way organizations are going to survive in this shifting landscape is by anticipating and planning for the next change so that they can stay ahead of the curve. The more an organization knows, the better it can be prepared to confront any potentially negative impact of the ever-evolving nature of the industry.

About Ben Quirk
Ben Quirk is CEO of Quirk Healthcare Solutions, a consulting firm specializing in EHR strategic management, workflow optimization, systems development, and training. The company’s clients have enjoyed remarkable success, including award of the Medicare Advantage 5-star rating. Quirk Healthcare presents a weekly webinar series, Insights, to inform clients and the general public about government programs and industry trends. Mr. Quirk is also Executive Director of the Quirk Healthcare Foundation, a learning institution which fosters innovation in the healthcare industry.

What If Meaningful Use Were Created by Doctors?

Posted on September 17, 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

It’s safe to say that meaningful use is growing through its challenges right now. My post yesterday about killing meaningful use and the new Flex-IT Act should be illustration enough. While it’s easy to play Monday Morning Quarterback on meaningful use, I think it’s also valuable to consider what meaningful use could have been and then use that to consider how we can still get there from where we are today.

Many of you might have read my post on The Purpose of the EHR Incentive Program Accordign to CMS. CMS clearly stats that the purpose of the EHR incentive money and meaningful use is to move providers towards advanced use of health IT to:

  • Support Reductions in Cost
  • Increase Access
  • Improve Outcomes for Patients

This has very clearly been CMS’ goal and it’s reflected in what we now know today as meaningful use. Let’s think about those from a physician perspective.

Support Reductions in Cost – So, you’re going to pay me less for doing the same work?

Increase Access – So, you’re going to send me patients who can’t pay their bill? Or does this mean I have to do more work making my records accessible?

Improve Outcomes for Patients – Every doctor can support this. However, many are skeptical (with good reason) that the various elements of meaningful use really do improve outcomes for patients.

If I were to step back and think what a doctor might consider meaningful use of an EHR system, this might be what they’d list (in no particular order):

  • More Efficient
  • Improved Care
  • Increased Revenue

More Efficient – Will the technology help me see patients more efficiently? Will it allow me to spend more time with the patient?

Improved Care – Will the technology help me be a better doctor? Will the technology help me make better use of my time with the patient?

Increased Revenue – Will the technology help me get paid more? Will the technology lower the cost of my malpractice insurance and reduce that risk? Will the technology create new revenue streams beyond just churning patient visits?

I’m sure there are other things that could be listed as well, but I think the list is directionally accurate. When you look at these two lists, there’s very clearly a major disconnect between what end users want and what meaningful use requires. With a lot of the EHR incentive money already paid out, this divide has become a major issue.

Killing Meaningful Use and Proposals to Change It

Posted on September 16, 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Isn’t it nice that National Health IT Week brings people together to complain about meaningful use? Ok, that’s only partially in jest. Marc Probst, CIO of Intermountain and a member of the original meaningful use/EHR Certification committee (I lost track of the formal name), is making a strong statement as quoted by Don Fluckinger above.

Marc Probst is right that the majority of healthcare would be really happy to put a knife in meaningful use and move on from it. That’s kind of what I proposed when I suggested blowing up meaningful use. Not to mention my comments that meaningful use is on shaky ground. Comments from people like Marc Probst are proof of this fact.

In a related move, CHIME, AMDIS and 15 other healthcare organizations sent a letter to the HHS Secretary calling for immediate action to amend the 2015 meaningful use reporting period. These organizations believed that the final rule on meaningful use flexibility would change the reporting period, but it did not. It seems like they’re coming out guns blazing.

In even bigger news (albeit probably related), Congresswoman Renee Ellmers (R-NC) and Congressman Jim Matheson (D-UT) just introduced the Flexibility in Health IT Reporting (Flex-IT) act. This act would “allow providers to report their Health IT upgrades in 2015 through a 90-day reporting period as opposed to a full year.” I have yet to see any prediction on whether this act has enough support in Congress to get passed, but we could once again see congress act when CMS chose a different course of action like they did with ICD-10.

This story is definitely evolving and the pressure to change the reporting period to 90 days is on. My own personal prediction is that CMS will have to make the change. I’d love to hear your thoughts.

Happy National Health IT Week!

EHR Certification Flexibility Final Rule Commentary and Analysis

Posted on September 3, 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The news came out late on Friday that the EHR Certification flexibility was published as a final rule. I covered my initial take on the EHR Certification Flexibility on Hospital EMR and EHR. I’ve now had a chance to dig through the delicious 90 pages of government rule making and comments that make up the final rule. For those following along at home, you can skip to page 10 of the document to start the fun read. Although, I’ll also direct you to specific sections that might be of interest to you below.

In this post, I’ll just cover the EHR certification flexibility. You can see the meaningful use extension and delay timelines here. Here’s the important chart when talking about the EHR Certification flexibility (CMS Calls it CEHRT):
2014 EHR Certification Flexibility - CEHRT

The EHR Certification flexibility has a number of major talking points:

  • What Does “unable to fully implement” and “2014 Edition CEHRT availability delays” mean?
  • Fairness of EHR Certification Flexibility
  • 90 Day Reporting Period in 2015 Instead of 365 Days
  • Future Audits

What Does “unable to fully implement” and “2014 Edition CEHRT availability delays” mean?
On page 62 of the rule is the best description of the rule’s intent. It says that if you want to take advantage of this EHR flexibility, then they (Eligible providers or hospitals) “must attest that they are unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays when they attest to the meaningful use objectives and measures.” This basically covers the asterisk in the chart above.

This piece of the rule was so unclear that CMS in the final rule used 12 pages (pg. 36-48) to describe when this rule would apply and when it would not apply. CMS tried to make this apply as broadly as possible, but I think they also wanted to encourage as many organizations as possible to not use the exception.

My short summary of these 12 pages is: If you have the 2014 Certified EHR software and can attest to meaningful use stage 2, then you better go ahead and do it. Trying to find a loophole that allows you to avoid meaningful use stage 2 and just do MU stage 1 puts you at risk during a future meaningful use audit.

Of course, if you’re EHR vendor hasn’t provided you the proper software/updates/training, etc that you require to attest to meaningful use stage 2, then this rule will apply. CMS’ intent seems pretty clear. If you can attest to meaningful use stage 2, then you should. However, if your EHR vendor prevents you from being able to attest, then they don’t want to hold the providers accountable for the EHR vendors failure. Although, CMS notes multiple times in the final rule that they don’t want to point blame at the EHR vendors since it could have been other outside issues (ie. final rule was late, ONC-ACB’s were backlogged, etc) that caused the EHR vendors to not be ready.

I wonder if one of the unintended side effects of this rule will be EHR vendors taking their sweet time releasing and rolling out their 2014 Certified EHR product and updates. It’s too late for this in the hospital setting since hospitals have to do a full year of MU 2 on a 2014 Certified EHR starting October 1, 2014. However, the same might not be true on the ambulatory side where they have until the end of the year to start on meaningful use stage 2.

I’ll be interested to see how many organizations are able to take advantage of this delay. Had this rule been finalized in early 2014, it would be a very different story. However, at this late date, I’m not sure that many providers or hospitals will be able to change course.

I mostly feel bad for those organizations that rushed their EHR implementations onto barely-beta-tested 2014 Certified EHR software and will now have no choice but to go forward with meaningful use stage 2. This change in rule makes many of these organizations wish they’d slowed their implementation to make sure they’d done it right and they’d have also only been required to do MU stage 1.

Fairness of EHR Certification Flexibility
The last paragraph above highlights part of the reason why many providers feel that this EHR certification flexibility is unfair. While it’s not a direct penalty on organizations that were on top of things, the change rewards those organizations that didn’t take the risks, push their EHR vendors, and push their implementation timelines to meet the MU stage 2 requirements. The reward an organization gets for going after MU stage 2 is that they have to do a lot more work (Yes, MU2 is A LOT more work) while their procrastinating competitors get to do the much simpler MU1.

This was such an important complaint that CMS addressed these comments in two different places in the final rule (pg. 21-22 and pg. 48-50). CMS tries to argue that in their research they didn’t see providers that were deliberately trying to delay MU stage 2, but found that providers wanted to do MU stage 2, but their EHR vendors weren’t ready. I’d suggest that CMS may want to dig a little deeper.

However, let’s set providers aside for now and assume that they all want to do MU stage 2, but their EHR vendors just aren’t ready for it. This EHR certification flexibility still lets EHR vendors who procrastinated their 2014 EHR certification off the hook. In fact, it rewards them and their users for not performing well. Once again, CMS doesn’t want to point the finger at EHR vendors, but will blame themselves for not finalizing the rule fast enough and ONC-ACB’s for having a backlog. However, if you’re an EHR vendor who’s been 2014 Certified for a while now, no doubt this rule makes you angry since it rewards your competitors in a big way (intended or otherwise).

Certainly there are a lot of reasons why an EHR vendor isn’t yet ready to be 2014 Certified. However, most of them have little to do with the rule making process and the EHR certification backlog. Some freely admit it, and others hide behind excuses. I think CMS realized this EHR Certification flexibility would benefit these EHR vendors, but they didn’t want to punish the providers who use these EHR software.

I still think the simple solution here was to extend this same flexibility to all providers and all EHR vendors. However, in the final rule CMS argues that doing so would reduced the amount of meaningful use stage 2 data that they’d have available to make the adjustments needed to meaningful use stage 3. I understand how a provider doing MU stage 2 this year might feel like the government’s guinea pig. We need you to do MU stage 2 so we can figure out how to make it right in MU stage 3. CMS also argues that they need more people on meaningful use stage 2 in order to push their agenda and the intent of the HITECH act forward. What doesn’t seem aligned to me is the goals of meaningful use and providers’ goals. I think that’s why we see such a disconnect.

90 Day Reporting Period in 2015 Instead of 365 Days
This seems to be one of the most heated discussion points with the final rule. CHIME President and CEO, Russell P. Branzell, even suggested that “Now, the very future of Meaningful Use is in question.”

CMS’ comments about this (pg. 34-36) basically say that a change to the EHR reporting periods was not part of this proposed rule. Then, they offered this reason for why they’re not considering changes to the reporting periods:

We are not considering changes to the EHR reporting periods for 2015 or subsequent years in this final rule for the same reasons we are not considering changing the edition of CEHRT required for 2015 or subsequent years. Changes to the EHR reporting period would put the forward progress of the program at risk, and cause further delay in implementing effective health IT infrastructure. In addition, further changes to the reporting period would create further misalignment with the CMS quality reporting programs like PQRS and IQR, which would increase the reporting burden on providers and negatively impact quality reporting data integrity.

What this comment doesn’t seem to consider is what will happen if almost no organizations choose to attest to meaningful use because of the 365 day reporting period. Talk about killing the “forward progress” of the program. From a financial perspective, maybe that’s great for the MU program. CMS will pay out less incentive money and they’ll make back a bunch more money in the eventual penalties. However, it seems counter to the goal of increasing participation in the program. Personally, I’m not sure that the end of organization’s participation in meaningful use would be such a bad thing for healthcare. It would lead back to a more rationale EHR marketplace.

Future Audits
On page 55-56, the final rule addresses the concerns over audits. We can be sure that some organizations will be audited on whether they were “unable to fully implement 2014 Edition CEHRT because of issues related to 2014 Edition CEHRT availability delays.” Sadly, the final rule doesn’t give any details on what documentation you should keep to illustrate that you meet these requirements for which you will have to attest. The final rule just says that they’ll provide guidance to the auditors on this final rule and that audit determinations are finalized on a case by case basis that will cover the varied circumstances that will exist.

This wouldn’t give me much comfort if I was going through an audit. Not to mention comfort that the auditors wouldn’t interpret something differently. I’ll defer other audit advice to my auditor friends, since I’m not an audit expert. However, in this case you likely know how far you’re stretching the rule or not. That will likely determine how comfortable you’ll be if an audit comes your way. Now you can see why my advice is still, “If you have the 2014 Certified EHR software and can attest to meaningful use stage 2, then you better go ahead and do it.

Conclusion
I really see the meaningful use program on extremely shaky ground. I don’t think this final rule does much to relieve any of that pressure. In fact, in some ways it will solidify people’s bad feelings towards the program. We’ll see for sure how this plays out once we see the final numbers on how many organizations attest to meaningful use stage 2. I don’t think those numbers are going to be pretty and 2015 could even be worse.

Note: For those following along at home (or work), here’s the final rule that I reference above.

Revisiting the ROI of an EHR Investment

Posted on August 5, 2014 I Written By

The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
Barry Haitoff
Now that we’re well on the road to being meaningful users of an EHR, I thought it would be interesting to take a step back and look at the ROI of an EHR investment. Hopefully this will be a valuable resource for those still considering an EHR investment and those who’ve already adopted an EHR in their practice. Some of the items listed below are benefits you receive automatically just by using an EHR. Other benefits require some thought and effort on your part. Hopefully this list will remind you of EHR benefits you might have forgotten and ones you can still work to achieve.

Repurpose Space – One of the big advantages of EHR software is that you can store your entire chart room on a relatively small server. Plus, if you’re using a hosted EHR solution, you don’t even need space in your office for a server. Once your paper charts get scanned into your EHR, you can often repurpose your chart room into a revenue generating exam room. I’ve seen some cases where an extra exam room made it possible to bring on another doctor or mid-level provider. In other cases, the extra exam room was able to make existing doctors more efficient. Either way, I don’t know very many practices who say, “We have too much space.”

Eliminate or Repurpose Staff – Nobody likes the idea of eliminating staff as part of an EHR implementation. However, there are two ways I’ve seen organizations reduce staff after implementing an EHR. First, some organizations reduce their staff through natural employee attrition. When a member of your staff chooses to leave your organization, some organizations decide not to replace that staff member since many of their duties are no longer needed in an EHR world. Second, some organizations take their existing staff and repurpose them to perform other tasks. For example, I’ve seen HIM (medical records) staff who are also medical assistants switch to more of a clinical role in the organization after implementing an EHR.

Avoid Penalties – One of the best reasons to make an early investment in an EHR is to avoid the government penalties. I’ve written about the meaningful use and PQRS penalties before, but this is likely just the start of the penalties the government and private payers will implement on those who don’t use an EHR. The long term ROI of these penalties is very large for most practices.

Quality Measures and Value Based Reimbursement – Meaningful Use together with the Value Based Reimbursement Modifier (VM) are the start of a shift towards reporting and getting paid based on clinical quality measures and outcomes. EHR software is at the center of this shift and will be essential to easily document and report these measures and outcomes. While we can put a hard number on the EHR incentive payments that are tied to these measures and the VM, you can be certain that this number will only continue to grow as the government and payers require more data.

Improved Charge Capture – Eight years ago, improved charge capture was the main ROI mechanism that EMR vendors used to sell software. The idea being that the EMR could help you more fully document the patient visit and thus allow you to bill at a higher level than you were doing previously. As in most things involving money, some doctors took this too far and started using the EMR to over code visits. These EHR over code abusers aside, the majority of doctors I know are chronic under coders. Many of these doctors under code because they don’t want to spend time documenting the normal findings that would let them code at a higher level. A well implemented EHR can help doctors fully document even the normal findings in a visit and therefore allow them to bill at a higher level.

Cancel Transcription – Depending on how you use (or don’t use) transcription, this may or may not be a part of your EHR ROI calculation. While transcription can still be used with an EHR, the majority of EHR users stop transcribing as part of the EHR implementation process. Once you make the switch to documenting directly in the EHR or using voice recognition, it’s easy to forget how much money you were spending on transcription.

Improved Workflows – A well implemented EHR software can improve your clinic’s workflows. The lab result workflow is a great example of how an EHR can improve the workflow in your office. The amount of time saved ordering labs and retrieving lab results in an EHR world is significant. Sure, lab interfaces aren’t perfect, but they’re a lot better than the paper model. You can see similar workflow benefits from X-rays and even a well implemented patient portal. Of course, your workflow can be negatively impacted if you’re not careful and thoughtful in how you implement your EHR. However, EHR technology can do a lot to improve a clinic’s workflow when you replace time intensive paper processes.

Streamlined Internal Communication – Related to improved workflows is improved communication. When it comes to internal office communication, most EHR software comes with a secure internal messaging service or task system. This replaces all those sticky notes, stacks of charts, or notes in boxes that would occur previously. Now messages aren’t lost and can be more easily tracked in the internal EHR messaging. Plus, you can also often report on how fast tasks are being completed.

Streamlined External Communication – We’re still early in EHR’s ability to facilitate secure communication with external providers. While some EHR software offers a provider portal for this communication, I’m more interested in the progress of Direct Project which allows the secure transfer of patient records between doctors. As these technologies mature, the time saved at the fax machine and sorting data records will be tremendous.

Eliminate Paper – Once you implement an EHR, you quickly forget how much money you were spending on paper and paper charts. Don’t forget to think about this cost savings when looking at the value of EHR. While some paper just disappears post EHR implementation, you’ll likely find that there’s still plenty of paper lingering around your office. You’ll never eliminate all of the paper from your practice, but you should ask yourself if you really need the paper you’re using or if it’s just part of an old practice that’s no longer needed. Furthermore, many EHR enabled offices print off insane amounts of paper from their EHR for no reason. This extra cost can be avoided with a little planning and awareness.

Chart Search Time – This is another one of the EHR benefits that quickly gets taken for granted. In the EHR world, it is extremely simple to find the right chart. I don’t need to outline the challenges that existed in the paper world with finding the paper charts. Medical records staff were amazing at organizing and finding paper charts, but this all required a lot of time organizing and locating the right chart. This is all but eliminated in the EMR world.

Along with the financial and efficiency benefits mentioned above, there are lots of other benefits to using an EHR like: legible notes, drug to drug interaction checking, and ePrescribing to name a few. However, even more important than all of the benefits mentioned above is how important an EHR will be to future reimbursement and care. As was mentioned, Medicare’s started penalizing non-EHR users and we’ll likely see other payers in some form or fashion follow their lead. Along with current and future EHR related penalties, there’s a real risk that you won’t be able to practice the highest quality medicine without an EHR and the future technologies it facilitates. The medical standard of care will likely require an EHR.

Medical Management Corporation of America, a leading provider of medical billing services, is a proud sponsor of EMR and HIPAA.

Practical Application of Watson with EHR

Posted on July 24, 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 13 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Ever since Watson made its debut on Jeopardy, I haven’t been able to not check out what Watson was doing next. No doubt what Watson did on Jeopardy was impressive. However, it’s one thing to do what it did on Watson. It’s another thing to commercialize the Watson into something useful.

I’d long been hearing that Watson was going to be great for healthcare IT and that healthcare would really benefit from the technology. However, everything I saw felt very conceptual as opposed to practical and implemented. So, I was really interested in talking with Modernizing Medicine about their EHR integration with Watson.

You can find my interview with Daniel Cane and Dr. Michael Sherling, Founders of Modernizing Medicine, talking about Watson and some of the other cool ways they’re trying to help doctors make use of the data in an EHR in the video below. Plus, we even talk ICD-10 and MU 2 delay as well.

Note: Modernizing Medicine is a Healthcare Scene advertiser.