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Some of the Thinking Behind Meaningful Use Stage 2 – Meaningful Use Monday

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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.

August 29, 2011 I Written By

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.

What’s in Store for Meaningful Use Stage 2? – Meaningful Use Monday

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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.

August 15, 2011 I Written By

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.

ePrescribing Controlled Substances

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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.

August 3, 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.

Relief May Be in Sight for Some Penalty-Threatened ePrescribers – Meaningful Use Monday

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Some physicians—most notably, surgeons and pain-management specialists—have expressed concern that they will be unfairly subject to the 2012 ePrescribing penalties, based on the fact that their opportunities to ePrescribe are limited by the nature of their practices. The Proposed ePrescribing Rule published in the Federal Register on June 1 offers a potential remedy for these providers.

 The rule, which amends the (MIPPA) 2011 ePrescribing rule, affords providers several new arguments they can use to request a “hardship exemption” from the 2012 penalties. (These are in addition to the already existing reasons, i.e., rural areas that lack high speed internet access and/or rural areas that lack pharmacies that accept ePrescriptions.) The new justifications include:

      1)   Inability to ePrescribe due to local, State, or Federal law, (i.e., providers who predominantly prescribe controlled substances).

      2)   Inability to count the ePrescriptions towards the Medicare incentive program, (i.e., providers who predominantly prescribe post-surgery—visits that are not included in the specified CPT denominator codes.

How does this relate to Meaningful Use Monday? The rule also reconciles the EHR (meaningful use) incentives and the Medicare ePrescribing incentives to some extent, in an attempt to harmonize the differing ePrescribing requirements and eliminate duplicate work for providers. (See “Meaningful Use, ePrescribing, and PQRS: Need for Harmonization” and “Meaningful Use Measures: ePrescribing.”) The Proposed Rule accomplishes this through two provisions:

      1)   Providers who successfully demonstrate meaningful use in 2011, which includes ePrescribing, would be exempt from the 2012 ePrescribing penalties. (Note, however, that these providers will be trading the 1% 2011 ePrescribing bonus for avoidance of the 1% 2012 penalty.)

      2)   ePrescribing software that is ONC-certified would be deemed also certified for the purpose of the Medicare ePrescribing program.

If you’d like to submit a comment to CMS on this proposed rule (file code CMS-3248-P), you can do so by July 25.

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.

June 6, 2011 I Written By

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.

Weekend Healthcare IT and EMR Twitter Roundup

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You know on the weekends I love to through in a little round up of some interesting things said about healthcare IT, EMR and other topics on Twitter. Hopefully, they’ll educate, entertain and inform. If not, tomorrow’s another edition of Meaningful Use Monday.


T2: I used to read 4 newsletters, now I don’t. I’ve chg’d to read tweets & blog post – so much more current. #hcsm
@Colin_Hung
Colin Hung

I’ve been talking about this quite a bit lately on this blog (see my post about social media EMR information). However, I love how the described their shift from newsletters to tweets and blog posts since they’re more current. I obviously agree. Although, if you subscribe to the EMR and HIPAA email you can enjoy the convenience of an email newsletter with the current info of a blog.


Rock Health Launches –The First Seed Accelerator to Promote Interactive Health http://dlvr.it/PZc58
@ehrandhit
EMR, EHR and HIT

I saw this announcement a while ago. I’m really excited to see what Rock Health is able to do. They definitely have a number of big names. I wish that I was some way involved with them since I love their approach. Plus, I’m really excited to have my brother, David, participating with me on the Smart Phone Healthcare website I recently launched. Mobile healthcare is a really hot area of the market and I think together we’re going to bring some interesting perspectives to the mobile area of healthcare.


E-Prescribing Incentive Program Comparison: http://bit.ly/hAjVe5 #healthit #medicare #meaningfuluse
@richelmore
HealthcareTechNews

I usually hate PDF’s and a tweet in a blog post that leads to a PDF is probably even worse. Although, it has an interesting format for considering the multiple e-Prescribing incentive programs. Of course, if you’re a regular reader of the site, then you already have started ePrescribing right?


LOL! RT @: Facebook is like jail, you sit around & waste time, you write on walls & you get poked by people you don’t know.
@Colin_Hung
Colin Hung

This just made me laugh and so I had to share it. Although, if you Like EMR and HIPAA on Facebook, then it will be so much better than prison. Well, maybe not much better, but it will make me smile.

April 24, 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.

Meaningful Use Mondays – Medicare vs. Medicaid Penalties and Other Differences

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To continue last Monday’s post regarding the differences between participation under Medicare and Medicaid, the Medicaid program imposes no penalties (or as Medicare euphemistically calls them, “adjustments”) for not being a successful meaningful user. Medicare adjustments are scheduled to begin in 2015. Upon discovering this discrepancy, one (somewhat devious-minded) physician suggested to me that this provided a loophole: declare as a Medicaid participant, begin participating (successfully or unsuccessfully) in 2015, and insulate yourself from any penalties. I’m sorry to report that, as creative as this strategy seemed, non-meaningful use Medicaid participants will still be subject to adjustments to their Medicare fee schedules when those penalties begin.

Two other noteworthy differences between the programs:

  • The Medicare payment schedule is front-loaded, with more money available in the first years of a provider’s participation. Medicaid incentives remain constant after the first year’s $21,250 for adoption, implementation, or upgrade of an EHR.
  • The Medicaid programs are run by individual states, so requirements and processes may vary somewhat from the Medicare program and from each other.

For information specific to the EHR incentives under Medicaid, the following resources are available: CMS Medicaid State Information and Medicaid FAQ.

For anyone who wants to see how much they really know about meaningful use, take the fun and educational Meaningful Use IQ Test on EMR Straight Talk.

Lynn Scheps is Vice President, Government Affairs at EMR 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.

January 17, 2011 I Written By

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.

Meaningful Use Mondays – Participation Under Medicare vs. Medicaid

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Physicians who are eligible for both programs will likely find participation under Medicaid to be a preferable option because the incentives are higher, the first year rewards adoption/purchase, (without requiring demonstration of meaningful use depending on the state); and the program offers more flexibility in terms of time frames. To participate under Medicaid, a provider must have a practice that is 30% Medicaid (20% for pediatricians), based on number of patient encounters (as opposed to revenue). Some providers are only eligible under Medicaid—nurse practitioners; certified nurse-midwives; dentists; and physician assistants who practice in a Federally Qualified Health Center or rural health clinic that is led by a physician assistant.

Not all states have their EHR incentive programs ready to go yet. 14 states will launch in either January or February; others are expected later in the year.

The major differences between the Medicare and Medicaid incentive programs that providers should take into consideration when making their choice at registration include the following:

MEDICARE MEDICAID
Maximum Incentive $44,000 over 5 years

(+10% for EPS in HPSAs)

$63,750 over 6 years ($42,500 for pediatricians w. 20-30% Medicaid)
First payment year Requires meaningful use $21,250 for adoption, imple-

mentation, upgrading to EHR

($14,167 for pediatricians w. 20-30% Medicaid)

Latest start time to earn maximum 2012

Must start by 2014 to qualify for any incentives

2016
Last payment year 2016 2021
Eligibility for concurrent ePrescribing bonus (MIPPA) No Yes

Next Monday’s post will highlight some other differences between the two programs that are interesting, but less influential.

Lynn Scheps is Vice President, Government Affairs at EMR 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.

January 10, 2011 I Written By

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.

SureScripts Becomes ONC-ATCB EHR Certification Body

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In the weirdest news I’ve seen in a while, SureScripts has become an ONC-ATCB. Here’s the details from Health Data Management:

In a Dec. 23 announcement, the Office for the National Coordinator for Health IT said that Arlington, Va.-based Surescripts can verify that e-prescribing, privacy and security modules meet the standards laid out in the meaningful use requirements. Surescripts is the sixth authorizer to be approved by ONCHIT, but it’s the only one with limited certification abilities—the five others have ONCHIT’s blessing to certify Complete EHRs and EHR modules.

Doesn’t this scream conflict of interest? They run a nationwide e-Prescribing network, and yet they can certify ePrescribing for ONC. I guess you could make the argument that they know ePrescribing well and so they are qualified to do it. Although, it is just weird and awkward to consider them as an ATCB. I wonder which ePrescribing companies will actually use them. Why did SureScripts even go to the effort to become an ATCB?

December 30, 2010 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.

EMR Stimulus Questions and Answers

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One of the challenges of this blog is writing content that will be interesting and useful to a wide variety of readers. At times I think I assume that those visiting EMR and HIPAA have read my 770 previous posts and should have a good understanding about the EMR world.

Of course, the reality is that many of the people visiting this site might only read a couple different posts. Even more significant is that they might only have a remedial understanding of EMR and in particular the EMR stimulus money. This leaves me with the challenge of keeping the long time readers interested and benefiting from the content I create while still helping the EMR newbies understand what they need to know.

In that vein, here’s some questions that I got in an email about meaningful use and the EMR stimulus. Those of you well versed in the EMR stimulus can go and enjoy EMR and EHR or add some content to the EMR wiki while I do what I can to answer.

Are there governing bodies that have been set up to “certify” EMR/EHR software vendors?
Not yet. The government hasn’t recognized any bodies that will certify EMR/EHR per the ARRA requirements. They’ve published some guidelines and rules for those bodies, but HHS has yet to recognize any of them as official ARRA EMR Stimulus certifying bodies. I expect by end of summer we’ll have a couple to choose from. The Drummond Group and CCHIT are both planning to be EHR certifying bodies, but neither has been officially recognized yet.

Do EMR/EHR software vendors have to be “certified”? If they are not “certified”, does this prevent their customers from receiving federal money?
In most cases the EMR/EHR software vendor is the one that will be certified. There has been some provisions and discussions about allowing for 2 other EHR certification options beyond just using a “fully certified EHR” software.

The first is that you could use a combination of certified software vendors. For example, you might use one certified EMR vendor for everything but ePrescribing and then you’ll choose another software vendor who is only certified for the ePrescribing portion. It seems that this type of combo certification will be allowed.

The second is what’s been called a site certification. This would essentially be where a specific site (or location) would be certified against the EHR certification criteria. This is best illustrated by a hospital or clinic which has their own home grown EMR software. This EHR site certification would allow them to certify their site and give them access to the EMR stimulus money. It’s possible that an option like this won’t be available, but from what I can tell it’s looking like it will happen.

Do you think that it is possible to satisfy the Stage 1 objectives?
This is a loaded question. The short answer is that everything is possible. Whether it’s possible or not is not as important as whether doctors will do it or not. This question is hard to answer right now. Mostly because we’re missing a lot of the practical meaningful use details which doctors need to know in order to make a decision.

My gut feeling tells me that it will go about like PQRI stimulus money. Some will get the EMR stimulus and be happy. The same number will try for it and be really disappointed by the whole process. More will say it’s just not worth my time right now. That’s not to say that many of these doctors won’t (or shouldn’t) implement an EMR. I think many of them will, but they’ll do it for the inherent benefits of EMR software and not for the EMR stimulus money.

June 2, 2010 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.

Percent of ePrescribing for Meaningful Use

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I’m still really disturbed by the fact that we have so few practical meaningful use details. Sure, we have a lot of guidelines and a lot of prognosticators guessing at what they mean and how they’ll be measured. We even have a certifying body trying to guess what the EHR certification will be. Sadly, they’re all still guesses.

Let’s just take a simple example for a second and see some of the complexities.

Objective: Generate and transmit permissible prescriptions electronically (eRx).
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

This certainly seems pretty straight forward. Probably about as straightforward as it comes as far as objectives. Basically, 75% of the prescriptions have to be ePrescribed using a certified EHR technology to meet the meaningful use guidelines.

Of course, the real question’s going to be around the word “permissible.” What’s considered a permissible prescription? I imagine this was added because currently you aren’t allowed to ePrescribe controlled substances. If I remember right, controlled substances make up about 15-20 percent of prescriptions. Certainly it wouldn’t be fair to include something that you’re not legally allowed to prescribe electronically in the requirements. Are there other exceptions under the “permissible” rule?

What’s going to happen once ePrescribing of controlled substances is allowed? Will doctors then be required to flip a switch and start sending controlled substance prescriptions electronically as well? Once they’re allowed, they’ll be considered permissible, no?

Let’s also not be surprised if the technology is built to do eprescribing in 2 systems (controlled vs not controlled). Of course, this adds a bit more complexity to measuring the 75% of prescriptions done electronically.

Also, does it give anyone else a bit of angst that the EHR software is basically going to spit out a report saying, “Yes, I ePrescribed 75% of my prescriptions.” I’m not sure how you scale a more sophisticated solution, but just taking some report from an EHR seems plenty gameable to me.

Will ONC be going around and doing some audits of the submissions to ensure that the data was actually good and not messed with? Can you imagine the challenge of having to audit some 300+ EMR vendors. Good luck with that.

I also love how the ePrescribing has to be done with a certified EHR system. A part of me really feels for those specialists that only write a few prescriptions a week. They get to learn the fun thing we call ePrescribing and they forget what they learned by the next time they have to ePrescribe.

UPDATE: Thanks to Russ in the comments, he pointed out the issue of calculating a percentage when your EMR won’t know if you just handed them a paper prescription instead of ePrescribing. I guess the criteria assumes they’re going to order the script and then print it out instead of sending it electronically? So, maybe the criteria should say 75% of scripts ordered in the EMR sent electronically. Just makes me laugh to think about it.

Lest ye think paper scripts don’t happen with an EMR, we can at least argue for them happening during EMR downtime (or printer or workstation or internet or…downtime). Although, they happen other times as well. How will an EMR calculate that percentage of prescriptions? Are they going to translate the freetext note that was entered into the EMR about the paper script that was given? Ideally the doctors will just enter in the script after the fact, but that’s not always the case.

I’m sure I’m missing other intricacies. My point is that there’s still a lot of unanswered questions around meaningful use. It would be nice to get some answers. It would be nice if ONC had a way to get and provide practical answers. You’d think they’d want that type of interaction as well.

April 30, 2010 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.