If you haven’t yet seen this video that DrFirst created for HIMSS 2012 and the HIMSS Healthcare Hero, then you need to watch it now. It’s a really beautiful video: http://bit.ly/AnNvzU

After seeing such a well made video, I definitely wondered what was up DrFirst’s sleeve at HIMSS 2012. So, I reached out and today I had the chance to talk with Cam Deemer President of DrFirst about the transition that’s happening at DrFirst.

I think that most of us have known DrFirst as an ePrescribing company. Since about 2004 they have been extremely focused on the ePrescribing area and that shows in the fact that DrFirst is the “ePrescribing Inside” 230 EHR companies. That’s a really impressive number and includes a client list with such names as GE and Greenway.

DrFirst is ready to make a shift which they’ll be talking about at HIMSS in Las Vegas. What I think makes DrFirst’s ePrescribing platform really interesting is that they can provide it using the DrFirst interface or an EHR vendor can customize it to their liking using a series of API calls. It takes a unique company and a unique set of skills to be able to do this effectively. Now imagine they provide these same functions and features across a whole array of EHR related products and services. By doing so, DrFirst becomes a really interesting EHR Platform.

You can find DrFirst at HIMSS to get the entire list of the products and services that they’ll be offering to EHR software vendors beyond just ePrescribing. However, I was really intrigued when they talked about their EHR platform providing compliance programs, patient education, and even co-pay discounts which help with medication compliance. I wouldn’t say that any of these things on their own are all that interesting. They are however things that a small EHR vendor wouldn’t have the time or the resources to be able to execute properly. For those EHR vendors who use the DrFirst interface, they can be turned on with the flip of an online switch.

Now just imagine a whole suite of other EHR services that DrFirst could provide EHR vendors as well. It becomes a really interesting value proposition. Plus, DrFirst also has a number of interesting solutions in the hospital market that also leverages this platform. Things like medication history for hospitals and a lab platform.

At the end of the day, EHR vendors are going to decide if this is a value added service or not. Many larger EHR vendors are going to develop a number of these features themselves and that should be expected. I just see it as a really healthy thing to have these type of EHR platform services available. Many EHR vendors have been so swamped with meaningful use and EHR certification, it’s great that a third party integration could continue to add real value to an EHR software.

The real challenge for DrFirst is going to be around how well they integrate these new EHR service offerings into the various EHR software vendors. If the integration is clean and adds value, they’re going to do very well. If it’s kludgy (a software term for messy) and doesn’t integrate well, then we won’t see much adoption. I think their current 230 EHR integrations are one sign that it will go smooth, but we’ll see.

My next question to consider is how DrFirst could extend their platform next. I can think of a number of mobile health companies that could benefit from the right connection to prescription data or to doctors. I’ll be pressing them at HIMSS to find out what’s next. I hope you will too and come back and share what you find out.

On a side note, I just got the list of things DrFirst is doing at their HIMSS 12 booth. It’s extensive and will be a can’t miss booth. Watch for the details in my upcoming HIMSS 12 exhibitor post.

Full Disclosure: DrFirst is an advertiser on EMRandHIPAA.com.

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.

Many physicians will be pursuing EHR incentives in 2012. Because meaningful use is not dependent upon G-codes, providers have been asking whether they need to continue putting “G-8553” on Medicare claims. The answer is YES—keep on G-Coding! 

Even though physicians who receive a Medicare EHR incentive are ineligible for an ePrescribing (MIPPA) incentive, they are still subject to future ePrescribing penalties. These penalties can be avoided by ePrescribing in 2012:

• Prevent the 2013 (1.5%) penalty – CMS is giving providers a second chance. If you failed to ePrescribe on the minimum 25 Medicare encounters in 2011, (which would have already protected you from the 2013 penalty), report G-8553 10 times between January 1 and June 30, 2012 on any Medicare claims. These claims don’t even have to be for the specified CPT “denominator” codes.
• Prevent the 2014 (2%) penalty – Report the G-code 25 times between January 1 and December 31, 2012. These claims must be associated with the specified CPT codes (typically E&M visits). 

If you are not pursuing meaningful use in 2012—or if you are, but for some reason fail to earn the incentive this year—you can still earn a 1% ePrescribing bonus under MIPPA if you report the G-Code on claims with the specified CPT codes 25 times between January and December . 

Like last year, there will be a process for requesting an exemption from the 2013 penalties, but surprisingly, the Proposed Rule did not include earning an EHR incentive as one of the justifications.

I’ve been having a number of really interesting conversations with people about Pharma ads appearing in EHR and other clinical software. Most people’s gut reaction is that they don’t want their doctor seeing a pharma ad while he’s ePrescribing. However, most people also agree that there’s too much Pharma money for it not to happen.

In an article at Lab Soft News a few months back, they discuss the challenge and issues surrounding Pharma ads in an EHR:

Very distressing to me, however, is the clear link of the company, and its software, to the pharmaceutical industry. I have blogged on numerous occasions about some of the ethical and legal lapses of some of these companies (see, for example: On the Corrosive Influence of Big Pharma on Academic Physicians; Merck Creates Phony Peer-Reviewed Medical Journal to Dupe Physicians; Details Emerge About Ghost-Written Medical Articles for Wyeth). I have also reluctantly come to the conclusion that even apparently trivial advertising connections to Big Pharma can lead to mischief. I had previously thought that inconspicuous advertisements in EMRs by drug companies might be tolerated if the companies were to bear the costs of these systems. I now believe that allowing these companies even a tangential relationship to physician-office electronic medical records is too risky.

Certainly there are some really great points made. Absolutely there’s a risk that a doctor could be influenced by a pharma ad in an EHR. Will it make them provide a lower quality care because of the ad? I’m not sure it would. Could the care cost more because of the pharma ad? Possibly so. Do we not trust our doctors to do what’s best for us regardless of the other outside influences?

Back to the initial premise, many are concerned with Pharma ads, but they’re bound to happen anyway. So, I ask you the question, is there any way to have Pharma ads without compromising the integrity of the visit? Is there a way to minimize the influence of Pharma while still allowing them a way to talk with the doctor?

No doubt this discussion is going to come up again and again. With Pharma unable to even give a doctor a pen we’re going to see new creative ways for Pharma to be seen by doctors. Advertising Pharma products to patients won’t be enough.

I always love when people talk about the paperless medical office. It’s as if they believe that after implementing an EMR they will no longer have to have paper in the office. Turns out, EMR software can print out a lot of paper if you’re not careful.

While ePrescribing is on the horizon in many places, the harsh reality is that many still have to print out prescriptions. Add in the requirements around prescribing controlled substances and in almost every state doctors using an EMR are still having to print out prescriptions.

In my clinic, it always felt wrong to print out an entire sheet of paper for one prescription. Eventually we got our vendor to support printing out multiple prescriptions on one sheet of paper. That helped, but many patients only need one prescription so that’s a lot of wasted paper. Beyond the green movement, wasted paper = wasted money.

With this background, that’s why I was intrigued by the DYMO Prescription Printer that I saw at MGMA. I’d worked with DYMO label printers before since the lab I worked with printed off lab labels directly from our EMR software. It makes sense that they could use a little bit larger printer and do the same thing with prescriptions.

It’s pretty obvious to see the paper saving benefits of using a DYMO printer like this, but I think the other advantage to this printer is its size. The printer has such a small footprint that you could easily put it a lot of places that a standard printer just won’t fit.

I admit that I haven’t done a full analysis of the savings using this printer compared with a standard printer. However, the nice thing about the DYMO printers is that they’re thermal printers which means that you’ll never have to spend money on ink or toner to print prescriptions. That’s pretty nice.

I’d love to have some of my readers try out the DYMO Prescription Printer to let me know what they think and whether they think I should add it to my list of EMR related technology products. Maybe I should see if DYMO will give one away to one of my readers to try out and report back.

I always love when small adjustments to current technology can make a huge difference. Or in other words, did I just write a post about a label printer? Sometimes the best innovations are subtle changes.

UPDATE: I just got word that DYMO will be happy to provide a product for review. So, drop me a line on my Contact Us page if you’re interested in trying it in your clinic.

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.

Year 1 of the EHR Incentives program is almost history. Do you have a plan for 2012? What you do next year depends on what you did this year. 

If you did not pursue meaningful use in 2011—and many Medicare providers did not, either because they were not ready yet or because they opted to earn the ePrescribing incentive under MIPPA instead—it is now time to focus on meaningful use. You can choose any 90-day reporting period in 2012 starting as late as October 3^rd, but it would be wise not to leave it to the last minute.

If you successfully attested to meaningful use in 2011, your reporting period for the second year’s incentive is a full calendar year. Regardless of which 90-day period you chose to report on for 2011, in 2012 you will report from January 1 to December 31. Incentives are tied to calendar years, so even if you completed your 2011 reporting period in September, your next period does not begin until January. Take a break from reporting, but do not abandon your meaningful use workflow.

For EPs who participate under the Medicare program, the 5 years of incentive payments must be continuous in order to earn the full $44,000 in incentives. Once you receive your first payment, skipping a subsequent year, (i.e., failing to demonstrate meaningful use), while permissible, will mean that you forfeit the payment associated with that calendar year. 

For EPs who receive a 2011 Medicaid incentive for “Adoption, Implementation, or Upgrade,” 2012 will require the demonstration of meaningful use. Since it will be your first year of meaningful use, you will only be expected to report on a 90-day period, and that period can occur any time during the year. Medicaid participants are eligible for 6 incentive payments—as opposed to 5 for Medicare providers—and unlike Medicare, the years do not have to be consecutive, as long as they are all completed by 2021. 

It’s time to start thinking about 2012.

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.

The Final Rule on ePrescribing was published in the Federal Register on September 6. This is the rule that adds new categories under which some providers can request a hardship exemption from the 2012 (1%) ePrescribing penalties, and it eliminates some of the discrepancies between the Medicare ePrescribing rule and ARRA. (See Meaningful Use Monday June 6.)The only change from the Proposed Rule is the deadline for filing a request—it has been extended to November 1, 2011 (from October 1). Providers should file as early as possible, however, to minimize the number of claims that have to be reprocessed. 

Requests will be reviewed on a case-by-case basis. To submit a request for exemption:

• Access the exemption request form on CMS’ QualityNet website www.qualitynet.org/pqrs
• In the “Related Links” box on the upper left, click on “Communication Support Page”, which will display the online form
• Provide identifying info (TIN, NPI, name, address, etc.)
• Indicate which hardship category applies
• Submit a justification statement explaining how ePrescribing represents a significant hardship
• Attest to the accuracy of the information submitted. 

Craft your argument thoughtfully. There is no appeal process—the decision of CMS is final.

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.

As October approaches, providers who want to apply for the 2011 EHR incentive—and their vendors—are scrambling to implement in time to allow for the 90-day reporting period. An EMR and HIPAA reader submitted the following question: 

Under the EHR Incentive program, in order to receive payment for 2011, the 90- day reporting period must begin no later than 1 October 2011 [Technical point: October 3 is the actual deadline]. Does this mean that the ONC Certified EHR must be in place and operational at that time or can it be installed after 1 October 2011 as long as the pertinent patient data is entered into the EHR once it is installed?

 The EHR must be in use during the entire 90-day period. Data must be reported for the entire 90 days; some measures require something to “be enabled” for the entire period, (e.g., a clinical decision support rule, drug formulary); and other measures have time frames attached, (e.g. provide a clinical summary within 3 business days), which would not be possible to accomplish retroactively. 

My suggestion is that you take the pressure off by postponing meaningful use—and the receipt of your incentive—by just 3 months. If you begin reporting on January 1 instead, you will still have the opportunity to earn the full $44,000 over the 2012-2016 period. You can attest at the end of March and expect your incentive by May. This schedule has the additional advantage of allowing you to earn a 1% ePrescribing bonus for 2011, which you would forego if you earn an EHR incentive since you cannot collect both in the same reporting period. Focus your energy this year on ePrescribing for 25 Medicare encounters and on successfully implementing your new EHR in 2012.

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 great deal of work, discussion, and debate by the HIT Policy Committee and its Workgroup members went into developing the recommendations for meaningful use Stage 2 (discussed in the last two Meaningful Use Monday posts). Meetings were frequent and lengthy, but I tried to listen in on most of them to gain some insights into the thinking behind the decisions being made and the future direction of meaningful use. 

Committee members struggled with striking the right balance between aggressively pressuring providers so that adoption would be accelerated, on the one hand, and maintaining a realistic and practical view of their capabilities, on the other. Some committee members were adamant about staying on track to reach the Stage 3 end goals within the predetermined 2015 time frame, (i.e. remaining on the escalator, as the progression is often referred to), while others recognized that overburdening providers could lead to program failure, i.e., discouraging adoption by imposing unreasonable expectations that would cause providers to doubt their ability to earn the incentives and abandon the effort altogether. The debate led to an open question: does everything have to be accomplished under the umbrella of meaningful use?

 An issue that I think could have used more discussion is how to make meaningful use relevant for specialists—a subject raised frequently by Committee member Gayle Harrell. There was general agreement about the importance of having all types of physicians participate in the incentive program, and testimony from a variety of specialists was solicited. Other than suggesting a large number of new clinical quality measures, however, the basic recommendations are still predominantly primary-care focused. 

Lastly, there was a prevailing sense of frustration over the fact that the calendar did not allow time for an analysis of the experience of Stage 1 before requiring the definition of Stage 2.

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 few weeks ago, the HIT Policy Committee forwarded its Stage 2 meaningful use recommendations to CMS. CMS is expected to issue a Proposed Rule in early 2012 and the Final Rule in mid-2012. 

The first recommendation—intensely debated, but overwhelmingly supported in the end—is to delay the start of Stage 2 until 2014, recognizing the unrealistic time pressure that vendors and providers would face if required to upgrade, implement, and train for the new set of requirements by 2013. 

Most of the proposed changes to the measures themselves are not dramatic in scope. Some measures did not change at all, (e.g., problem list, medication list, etc.) Others, (e.g., ePrescribing, smoking status), would have higher thresholds to meet—not a major obstacle if the higher-than-required performance trend reported among early attesters continues—and some would have a slightly broader scope, (e.g., CPOE would include radiology). 

All menu measures would become core measures, which means that they would be required of all providers. If CMS adopts this recommendation, it will be important to identify exclusion criteria to accommodate physicians for whom particular measures may not be relevant, as they did for specific core measures in Stage 1. 

The changes that are more controversial are those that hold physicians responsible for factors beyond their control, such as requiring that a given percent of patients actually view their electronic health information (Stage 1 only requires that the information be made available), or requiring that a given number of patients send a secure message to the physician/practice. Also interesting is that some of the new measures recommended for Stage 2 are measures that were specifically removed by CMS during the Stage 1 rule-making process, such as advance directives and progress notes.

If you are interested in the specifics associated with the recommendations summarized above, Computer Sciences Corporation’s Update on Stage 2 (PDF) presents a nice review.

Back on September 13, 2009 I wrote a post titled, “FDA Approves Pilot Electronic Prescribing of Controlled Substances.” I’d link to the post, but unfortunately the news got sent to me prematurely and so I had to take the post down. It was unfortunate, since there was and still is a lot of interest in being able to ePrescribe controlled substances. In fact, I’d say that not being able to prescribe controlled substances electronically is the current Achilles heal of ePrescribing.

Fast forward to the recent announcement that DrFirst’s announcement of the Nationwide Launch of their ePrescribing Controlled Substances product. Their latest ePrescribing product for controlled substances is called EPCS Gold and is fully certified to meet the prescription processing requirements for Surescripts, the DEA’s requirements in the Interim final rule, and the Identify Proofing requirements set by NIST.

I’m really glad to see ePrescribing of controlled substances moving forward. This will make ePrescribing much more attractive to physicians. Especially physicians that regularly prescribe controlled substances like surgeons and pain doctors.

However, this controlled substance ePrescribing announcement does of course come with it’s limitations. I think they’re described well in this part of the press release:

Prescribers enrolling for EPCS Gold™ will be able to send controlled substance prescriptions electronically after a simple credentialing and identity-proofing process with DrFirst. After providers are certified, they can begin e-prescribing Schedule II-V drugs based on their individual state laws and the ability of the receiving pharmacy to meet the DEA’s requirements to process these prescriptions. To avoid any confusion and eliminate guesswork by providers, EPCS Gold™ automatically detects which substances can be sent electronically.

The two challenges are quite clear: state laws and pharmacy ability to meet the DEA’s requirements. I haven’t done any in depth research on either subject, but I have a feeling that both of these things will be major issues across the country. I’d like to think it won’t be, but knowing the pace of state legislation and pharmacy adoption of these standards I’m not hopeful that they’re ready to receive controlled substance prescriptions electronically.

However, the above step is an important one. You have to have all sides ready to handle the security required to make ePrescribing controlled substances a reality. This is the first step and a very good one.