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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.

Opting Out of Meaningful Use Stage 2

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An old post about meaningful use stage 1 called Hardest Meaningful Use Measure recently was tweeted on @ehrandhit as a way to share from our vault of blog posts. Swithin Chandler saw the tweet and left a really interesting comment when it comes to how challenge meaningful use stage 2 is compared with meaningful use stage 1. Here’s part of his comment (emphasis added):

We’ve had relative success, and I stress relative, in making it as easy as possible in our EHR for our doctors to attest for Meaningful Use Stage 1 as one independent poll showed.

But with MU2 it is getting much harder. There are requirements that demand additional data entry, whether typing, clicking, or dictating that no EHR vendor can help doctors avoid.

My greatest concern is that doctors look at the changes needed to their workflow and decide the incentive is not worth it. I think there are some MU2 requirements that are very cool from a healthcare technology perspective (and as a patient), but one could certainly argue that giving doctors the features they’re asking for that are not in MU2 may be more valuable to them adopting EHR technology than some features they don’t want that are in MU2.

I think there’s a really good chance that huge numbers of doctors will opt out of meaningful use stage 2. As I recently discussed with our local congressman, the inverted incentives of meaningful use don’t make much sense. Usually when you require someone to do more, you compensate them more. In meaningful use as you are required to do more, they pay you less.

I do think the meaningful use penalties will encourage many doctors to press on through the various stages of meaningful use. However, there will also be a large group of doctors who decide that the cost of meaningful use stage 2 is more than the penalties for not being a meaningful user.

If you still don’t believe this is the case, last I checked only only a small handful of EHR vendors have become MU stage 2 certified. As Swithin says above, it’s not easy (and I suggest might be impossible) for an EHR vendor to make MU stage 2 easy for providers. No doubt this is a huge reason why many EHR vendors are still not MU stage 2 certified (or I think it’s officially called 2014 Edition EHR Products). Certainly all of them could have rushed the requirements for EHR certification, but implementing the EHR certification requirements without making life miserable for the end user is a challenging and possibly impossible task.

August 19, 2013 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.

Bill Would Offer More Ways To Avoid Medicare EMR Cut

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Federal lawmakers have introduced a bill which would grow the list of exemptions physicians could seek to the Medicare penalties faced by those not meaningfully using an EMR.

The bill, which was filed in the House by Rep. Diane Black (R, Tenn) would add new hardship exemptions to an existing list which would help solo practice physicians and doctors who are approaching retirement, according to American Medical News.

As readers probably know, most doctors who don’t have a meaningfully-used EMR in place by July 2014 — roughly a year from now — face cuts to to Medicare reimbursement starting in 2015.  The penalty cuts would lower Medicare reimbursement by 1 percent in 2015, and would climb to 3 percent by 2017.

Some physicians already enjoy exemptions from the cuts, AMN notes. Doctors who:

  • Have insufficient Internet access or who face insurmountable barriers to obtaining infrastructure, such as high-speed or broadband Internet.
  • Begin practicing in 2015.
  • Encounter unforeseen circumstances, such as a natural disaster or other unforeseeable barrier.
  • Lack face-to-face interaction with patients or follow-up opportunities with patients.
  • Practice in multiple locations and do not control access to EHRs during more than 50% of patient encounters.

Are already eligible for exemptions from the pending Medicare cuts, AMN reports.

The new bill would extend the above list of hardship exemptions to doctors in a solo practice. It would also offer an exemption for physicians who are 62 or older by the last day of 2015, or who will reach age 62 by 2020, according to the magazine.

It seems like the help with the cuts is needed for solo physicians in particular. According to the National Center for Health Statistics at t he CDC, only 29 percent of solo practitioners had adopted EMRs by 2011.  While that number may have climbed since 2011, solo docs are doubtless still way behind in adoption, and slapping them with reimbursement cuts simply may not make sense.

June 25, 2013 I Written By

Katherine Rourke is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

EHR Penalties after Meaningful Use Failure

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While at HIMSS I had a discussion with the consulting firm Stoltenberg Consulting. I was really intrigued by their approach to EHR consulting and will likely write more about it later. Plus, the started what in many ways became a theme of my HIMSS experience around rural healthcare EHR. You can be sure I’ll be writing about rural EHR here on this site and on Hospital EMR and EHR much more in the future.

In our casual introductory conversation we had a good discussion about how many of the smaller hospitals look at meaningful use and the EHR incentive money. Needless to say, many of these smaller institutions are faced with a huge challenge when it comes to adopting an EHR and showing meaningful use. Many of these rural hospitals barely have an IT staff and the CFO usually takes care of the IT environment. I heard one story at HIMSS where the IT person at a rural hospital started out as the janitor and his home IT skill made him the most qualified person to help.

Needless to say, rural and smaller hospitals have some real challenges facing them when it comes to EHR adoption and showing meaningful use of that EHR. Although, an even worse thought struck me in my discussions about these smaller hospitals.

Imagine many of these smaller hospitals making a good faith effort to adopt EHR and show meaningful use. It’s not that hard to see many of these hospitals falling short of the meaningful use standard. What will this mean to that organization? They’ve spent millions on an EHR. They won’t get the EHR incentive money they likely used as a justification for the EHR spending. To add insult to injury, now they’re going to get penalized for not being meaningful users of an EHR.

This scenario honestly makes me sick to even consider. Something similar could easily happen in small ambulatory practices as well. The scale of the damage will just be different. I expect in meaningful use stage 1 this won’t likely be a problem since it’s self attestation. However, this could become a much bigger issue in meaningful use stage 2.

Although, consider an organization who fails a meaningful use stage 1 audit. In most cases you can’t go back and fix whatever you failed in the audit. You’d be in a very similar situation where you have to return the EHR incentive money and would be open to the meaningful use penalties. At least that’s my understanding of how the EHR penalties will be implemented. If you know otherwise, I’d love to hear it.

While I think the above scenarios are brutal, hopefully this will also serve as a warning for those hospitals pursuing EHR and the EHR incentive money. Be sure you are able to show meaningful use or you’ll not only lose out on the incentive money, but you’ll also be open to the EHR penalties. Not to mention, are you ready for a meaningful use audit?

March 15, 2013 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.

The Coming Physician EHR Revolt

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From my blogging viewpoint I’m sensing a growing discontent among doctors that is starting to really heat up. I can’t quite predict when this discontent will reach a boiling point that will start to boil over, but the fireworks are coming. As I’ve watched the past couple years, doctors were first overwhelmed with all the government regulations. They were confused by everything was coming out and really just didn’t know where healthcare IT and EHR was headed. That overwhelmed confusion is slowly turning into a reality that many doctors are realizing is changing how they practice medicine. If you’re not seeing this, then you might want to get out and spend some more time with your casual every day doctors.

One doctor emailed me today suggesting that doctors were being literally “eaten alive” as they are working harder to provide patient centered care. It would be a disservice to doctors if we don’t take the time to acknowledge and understand the enormous pressures that many doctors are feeling right now.

Here’s a quick look at what I believe is the perspective of many doctors I connect with on a daily basis.

Regulations
Everywhere doctors look they’re getting hammered by new regulations. I recently heard Shahid Shah say, “We’re experts in the industry that spend all day thinking about the market and regulations and even we have a challenge understanding what’s going on. Now think about the doctors and adminstrators which have challenging day jobs and only a small amount of time to understand the regulations. They don’t really understand the details of what’s being regulated.”

This is a reality for many doctors and practices. Is it any wonder that many are happy to sell off their practices to major hospitals? I’m sure that many do so just because they’re tired of trying to understand all the changing regulations they’re required to know.

If we look at just the healthcare IT and EHR related regulations you have: meaningful use, ACOs, ICD-10, 5010, and Obamacare/Healthcare Reform. Any one of those is a challenge to understand and implement. Yet doctors and hospitals are dealing with all five of them simultaneously. Not to mention doctors being asked to participate in HIEs, being graded and rated online, engaging with empowered patients through social media, and embracing a new technology savvy culture while reimbursement lags behind.

Is it any wonder that doctors feel overwhelmed, overworked, and unsure whether they want to continue being doctors. Is this going to lead to a real shortage of medical professionals?

EHR Discontent
Since this is an EHR blog, we should spend some time on the growing discontent with EHR software. I hate to dwell on this, because EHR is going to be the future of clinical documentation. It’s hear to stay and no amount of belly aching and moaning is going to stop EHR software from becoming the de facto standard for clinical documentation. However, just because this is the case doesn’t mean we should ignore the realities that so many doctors are facing when it comes to EHR software today.

Many doctors see EHR as a major time suck. Their EHR software requires them to work longer hours and/or see fewer patients. Overtime this usually improves, but we have to acknowledge the initial productivity hit that pretty much every EHR implementation sees. Some clinics never get back to their previous productivity. We’ve discussed the reasons for this over and over again on this blog. We’ll save the list of reasons and ways to avoid those issues for another blog post. However, until all 300+ EHR vendors solve the EHR productivity issue, we’re going to hear more and more stories of how much of a time suck an EHR is to many doctors.

Not all doctors see it this way. Many doctors can’t imagine their practice without an EHR. As we’ve been covering in our EHR Benefits Series, there are a lot of benefits to having an EHR. Many of the benefits we’ve already covered in that series are ways that a clinic can save time thanks to an EHR. However, it can take time for a new EHR user to get up to speed where they can speak the EMR language well. It’s not easy learning a new language, and so this adds to the growing discontent that many doctors feel towards EHR.

Template EHR and Copy Paste
Many EHR vendors have implemented a complex set of templates that doctors can use to be more efficient. It’s a thing of beauty to see a full template pulled into a patient’s chart with a single click. A full patient physical documented with a single click sounds like it should save the doctors a lot of time and make them more efficient. In fact, many have argued that template based EHR documentation is a great way for doctors to achieve higher reimbursement levels since they are better able to document the actual care they’re providing. In the paper world they would have passed on the higher reimbursement because they didn’t have the time or desire to document all of the items they examined and so they just accept a lower reimbursement level. EMR templates made it possible for doctors to finally be reimbursed for all of the care they provided a patient since the templates made it easy to document.

Sounds great doesn’t it? Well, it did until the government realized that EHR software often drove up their costs. This shouldn’t have been a surprise to anyone in the EHR world. I’ve been writing about the ability to increase your reimbursement rates from EHR for over 7 years. However, instead of the government choosing to acknowledge something that was apparent to many in the industry, they decided to blame the increased costs on, you guessed it, dishonest doctors.

Think about the message that we’re sending doctors. First the government tells doctors to start using EHR. Then, the government calls those doctors dishonest for using the tools that the government told them to use. A doctor recently described their perspective is like being stuck in a pit with sly hyenas all around ready to take their bite out of them.

Add in all the recent discussions about copy and paste in EMR’s, and it shouldn’t be any wonder that doctors are gun shy. When they implement technologies to try and make things more efficient they get their hands slapped or even worse.

Reduced Reimbursement and Penalties
In the midst of all the things mentioned above, doctors are also getting hit with reduced reimbursement rates. This is particularly true for those in the general medicine area. They’re being asked to do more to improve patient care, reduce hospital re-admissions, treat the whole patient, etc and they’re getting less reimbursement.

Plus, now the EHR penalties are hanging over their head if they choose to not show meaningful use of a certified EHR. I still have my doubts that the EHR penalties will be enforced. I expect there will be a whole series of exceptions offered up which make it so pretty much all of the doctors avoid the penalties. However, that’s still unknown and many doctors see those EHR penalties as just another slap into the face.

Data Data Data
Most doctors see the push for EHR as a way for someone to get at the data in healthcare. In many ways, they’re right. EHR’s were first created as big billing machines to get at the financial data. Now with meaningful use, EHR’s are repositories of other healthcare data. The data is being used to optimize reimbursement (rarely a good thing for doctors). The data is wanted for population health analysis. The data is wanted for public health needs. The data is wanted to be able to facilitate ACOs. Everyone wants a piece of the healthcare data it seems.

The problem from a physician perspective is that everyone wants that data, but it’s not often clear how that data is going to facilitate that doctor being a better doctor. In many cases it won’t and there’s the rub. Almost every doctor I know wants to improve healthcare. So, they don’t have any problems supporting initiatives that improve healthcare, but I think that most of them also sit back and wonder at what cost.

Audits
I don’t know anyone that likes audits. Yet, most doctors are surrounded by a wide variety of audits. RAC Audits are on the way. HIPAA audits are possible and HIPAA is always lingering in the back of most doctors minds. Especially when you start talking about technology and HIPAA. There are so many unknowns that there’s no place of comfort for those doctors who want to be compliant. Most make a best effort and then push it out of their minds as they try to provide great patient care. Next up our meaningful use audits. You can be sure they’re coming.

Solutions
I wish I could say that I have a bunch of really good solutions available. What does seem clear to me is that most of the challenges that doctors face revolve around the current reimbursement models that we have today. I’m not sure we can fundamentally change those. One interesting option that’s emerging is concierge medicine.

Every doctor I know loves the idea of concierge medicine. When you tell them they don’t have to worry about reimbursement, insurance companies, etc, you see this huge weight lifted off of their shoulders as they wonder what life would be like for them if all they did was provide the best patient care to those who came to their office. The problem with concierge medicine was highlighted in a tweet I saw recently that said, “Concierge Medicine – Does it really work?”

The answer to that question is: it’s still too early to know for sure. Although, my prediction is that concierge medicine will work in certain situations and communities, but won’t be able to provide the widespread change of reimbursement that we need for healthcare to alleviate doctors concerns.

When it comes to EHR, concierge medicine is quite interesting. None of the mainstream EHR vendors really work for concierge medicine since they’re all focused around reimbursement and concierge throws that out the window. Plus, think about how few of the meaningful use requirements a concierge medicine clinic cares about. In fact, implementing many of the meaningful use and EHR certification requirements gets in the way of the concierge doctor’s workflow. I expect many doctors would love a concierge focused EHR software.

The other solution is likely going to be EHR vendors yielding to the idea that they’re the database of healthcare. Once they make this decision, EHR vendors can really open up the proverbial EHR kimono and let outside developers really make their EHR useful for doctors across all specialties, all regions, all sizes, and every unique workflow. One company can’t satisfy every doctor the way a community of empowered developers can.

No One Feels Bad for Doctors
I’ve written about this idea before, but almost no one feels bad for what most people think of as “well paid doctors.” Far too many doctors are still driving around Mercedes and BMW’s for most people to feel too bad for them. Compared to many people who don’t have a job at all, I don’t feel bad for them either.

While we don’t have to feel sorry for them, that doesn’t mean we shouldn’t acknowledge the pressures that doctors are facing. Plus, I see this only getting worse before it gets better. As an entrepreneur, I see this as a tremendous opportunity. Plus, I see a number of companies that are working to capture this opportunity. However, far too many companies are blind to this physician discontent. I’m not sure if it’s purposefully blind, ignorantly blind, or arrogantly blind, but many are ignoring it. As I predicted in the beginning of this post, I see this reaching a boiling point soon which leads to some fireworks.

Let me highlight what I’m talking about using the words of a doctor’s message I literally received in my email as I was writing this post:

EMR’s are making it more and more difficult to practice medicine. They used to be fun and helped my daily work. Now, they are getting so complex that is takes much more time to do them. MU is becoming a nightmare for physicians.

February 5, 2013 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.

Understanding Meaningful Use Stage 1 and Stage 2 Deadlines – Meaningful Use Monday

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The following is a guest blog post by Zubin Emsley, CEO of ChartLogic, Inc. I think readers will find this post by Zubin quite interesting. He brings up some important points, makes some strong assertions, and even makes some daring projections. I look forward to more discussion of the post in the comments. Are we at “the tipping point?”

With all the controversy surrounding the CMS’s proposed Meaningful Use Stage 2 requirements, it is easy to forget that the clock is ticking on the Stage 1 requirements. Physicians who have not yet qualified for the Stage 1 incentives are at risk of leaving $5,000 of incentives on the table if they don’t get started immediately.

The comment period on the proposed Stage 2 rules is now closed and the CMS is expected to incorporate the comments and issue final rules around August 1. The Stage 2 program is currently scheduled to take effect for eligible providers on Jan. 1, 2014; however, there is a good chance this date will be pushed back.

Physicians who want to qualify for the full, five-years’ worth of meaningful use incentives ($44,000 total) must register, adopt a certified EHR system and submit 90-days’ worth of data by Jan. 1, 2013. That means your practice must have incorporated your EHR system into its workflow and be collecting the needed data sets by Oct. 3, 2012.

Since most medical groups need several months to select an EHR vendor, get their new system installed, and get physicians and staff trained, that means time is running out for those who have postponed a decision.

If you miss this year’s deadline, you may still participate in MU Stage 1 next year (2013); however, you will only be eligible for four years of payments ($39,000 total). Those who wait until 2014 to qualify will only be eligible for $24,000 in payments.

We have reached “the tipping point” in terms of EHR adoption. Penalties for failing to e-prescribe began this year, and in 2014 and 2015, physicians will face mounting financial penalties from Medicare and Medicaid if they don’t adopt an EHR. Commercial insurers are also adopting various kinds of accountable care programs that require submission of clinical data. Within five years, the only way a physician practice will be able to operate without an EHR would be if it moved to an all-cash, concierge type model.

Zubin Emsley is chief executive officer of ChartLogic, Inc., a national EHR vendor based in Salt Lake City. For more information see www.chartlogic.com

June 11, 2012 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.

No EMR Mandate in HITECH or ACA – Meaningful Use Monday

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I’m going to veer off a little bit from the regular Meaningful Use Monday topics to cover something that I think needs to get more coverage and is related to the EHR incentive money and meaningful use. Let me start by making something extremely clear:

There is NO EMR mandate. There is NO EHR mandate.

For those of you who want a broader post on the subject, you should read my post from a little over a year ago about the 2014 EHR Mandate. The key is that there’s no EHR mandate and no one is going to put an EHR mandate in place. Certainly there are incentives to use EHR and penalties if you don’t use EHR, but that’s not a mandate.

For those that don’t want to click to the full post above, in it I give five other reasons to implement EHR and an explanation of each. These reasons together could feel like a mandate. Here they are:
* Ability to Sale Practice
* Government Mandated Reporting
* Reimbursement Requirements
* Patients
* ROI for Your Practice

I’m sure that people are still confused on this subject. In just the past 7 days, this website has gotten 250+ people searching terms related to EHR mandate. A lot of people are starting to get concerned about what they’re hearing on the street about EHR. Will this fear of an “EHR Mandate” push many into EHR adoption?

HITECH and Obamacare (ACA)
Related to this mandate for EHR, many people are also confused by the EHR incentive money and the supreme court case for Obamacare. Many people confuse Obamacare, otherwise known as ACA, with the HITECH act (which was part of the ARRA legislation).

What you need to know is that when 99% of people talk about EHR incentive money, meaningful use, EHR mandates, EHR penalties, etc, they are talking about ARRA and more specifically the HITECH act. ARRA and the HITECH act aren’t going before the supreme court and so they’re not at risk. ARRA and HITECH could be affected if the republicans win the Presidency, Congress and the House, but most people argue that HITECH is pretty bipartisan. Although, that’s a topic for another post.

ACA is what’s gone before the supreme court and we’re awaiting a ruling. If ACA is declared unconstitutional, then there will be some affect on healthcare IT programs in general but most EMR programs won’t be affected.

April 16, 2012 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 2012 Predictions – Meaningful Use Monday

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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?

January 2, 2012 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.

EHR Q&A: Is EMR or EHR a Requirement

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Brenda asked:
As a private OT clinic that does not contract with medicare/ medicaid, are we required to use electronic medical records? We do submit claims to private insurance companies electronically.

Answer:
The short answer is no.

In fact, NO ONE is REQUIRED to use EMR whether they take Medicare or Medicaid. However, if you take Medicare or Medicaid, then you have to be a “meaningful use” of a “certified EHR” in order to: 1. Get the EHR Incentive money and 2. Avoid the government penalties for not being a meaningful user of an EHR.

Some might argue that the work to show meaningful use is not worth the effort compared to the incentive money you receive. Plus, the penalties for not using an EHR are not that big of an issue (see this post on the EMR penalties ) Although, there are plenty of people arguing on the other side. For example, Meaningful Use is relatively easy (at least in Stage 1) and the penalties are going to be a major issue for their clinic since they have such a large Medicare or Medicaid population.

Then, there are the doctors that are leaving Medicare and Medicaid behind completely (see this doctor as an example). The argument here is that Medicare and Medicaid are the lowest paying payers out there and now they’re going to penalize them even more so they might as well just stop taking them. We’ll see how many adopt this strategy.

One word of Caution…
There’s a possibility that insurance companies will hop on board the requirement of an EHR and Meaningful Use (see this post about private insurance and meaningful use ). I’m sure they’re keeping a keen eye on how well it goes for the government before making any decisions. My gut feeling is still that they won’t wholesale take the governments approach to EHR and meaningful use. Instead, they may require some sort of electronic documentation or reporting requirements which are more easily performed with an EMR. Essentially it will be an extension of their requirement to have claims submitted electronically.

Despite the myth that EMR is a requirement, so far no one can require you to use an EMR. They can only provide incentives and penalties if you don’t (which only the government has done to this point). Although, there’s always the aspirational goal that Bush and Obama have made of Full EHR by 2014.

The longer answer is…EMR is not a Requirement….yet?

Be sure to check out all the EMR Stimulus Questions and Answers posts.

April 14, 2011 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.