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The Impact of the 2016 Election on Healthcare IT

Posted on November 9, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Today it’s pretty obvious that the Presidential is on everyone’s mind. While I don’t plan to discuss the details of the election and the specific results, it’s worth thinking about what Donald Trump in the white house will mean for healthcare IT.

Let’s start off with the easy one: Meaningful Use/MACRA. One doctor tweeted me that now that Trump is President, MACRA will be gone. I don’t think that’s further from the truth. In fact, I really can’t imagine any scenario where the EHR Incentive program (Meaningful Use, which still applies to hospitals and Medicaid) and the MACRA program would be gone. I think they’re here to stay and won’t be altered at all by this election.

The biggest reason for this belief is that Trump is going to have so many other things on the agenda. Not the least of which is ACA (Obamacare), which we’ll get to later in this post, but also a whole suite of other things that he’ll make a priority. Why would Trump want to take on a relatively bipartisan thing like healthcare IT, EHR and MACRA? I don’t think he’ll waste a second on the subject.

Plus, even if Trump wanted to go after the MACRA and EHR incentive legislation, I can’t imagine the Senate and House passing something to replace those programs either. Remember that Trump can propose all he wants, but the Senate and House have to pass it too and both of those groups seem to be firmly behind both efforts. Add this to the previous point and why would Trump go after health IT when it’s unlikely to pass and isn’t a strategic goal of his? Short Answer: He won’t.

My opinion: we’re unlikely to see any change to MACRA and other healthcare IT initiatives.

The trickier part to assess is the impact a Trump presidency will have on the Affordable Care Act (ACA or Obamacare). I live in Vegas and I wouldn’t even want to offer odds on what’s going to happen there. The rhetoric out there is to “repeal and replace Obamacare.” What’s not clear to me is if this concept is even practical and possible. There are so many issues with the idea of repealing Obamacare, that I can’t imagine it ever happening. I could see parts of it being repealed, but not the whole thing.

I also think it would be seen as very unfavorable for Trump to roll back things like the pre-existing condition exemption that allows those with pre-existing conditions to get insurance. There are probably a dozen other things like this that would likely be hard to take back without some major backlash and so I think they’ll have to preserve many of these things in whatever they do with Obamacare. Maybe that means a full repeal, but then rolling back in some of the popular pieces of the legislation so they can say they repealed it.

All of this said, I think that Trump will evaluate all options to undermine many of the things that were implemented by Obamacare including the insurance mandate and the insurance exchanges. Most people don’t realize that there’s so much more to Obamacare than just the mandate and exchanges. How he’ll undermine Obamacare and the impact it will have is anybody’s guess. I’m not sure anyone really knows and it’s certainly beyond my political punditry.

Long story short on Obamacare, I have no idea. I know that something’s going to happen because of the strict “Rip and Replace” rhetoric. I just think it’s really hard to predict which parts they’ll be able to rip out at this point and what they’ll replace it with going forward.

No doubt this will keep many in healthcare on edge. Unknowns are always a challenge. While I think the Trump Presidency will likely have a big impact on healthcare, I don’t see it having a big impact for good or bad on healthcare IT. I think the path to healthcare IT is happening and he won’t do anything to really stop it.

Side Note: Check out this interesting lessons learned post by Mr. H at Histalk which talks about the challenge of relying on data. As healthcare enters the world of data in a big way, it’s important to make sure we have a good understanding of what the data really tells us and what it doesn’t.

How Will the Coming Election Year Impact Healthcare IT?

Posted on November 10, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

It seems like the Presidential election should be closer since we’ve been hearing about possible Presidential candidates for the past year. However, we still have a whole year before the next Presidential election. Does anyone else think we’re going to be tired of this process a year from now? (But I digress)

In past years, there was certainly a lot to talk about when it comes to the impact a new president would have on healthcare IT. However, I don’t think that this presidential election will be the same. I think that’s true for healthcare in general as well.

On the healthcare IT side, meaningful use has basically run its course. Sure, Jeb Bush has asked to eliminate meaningful use and government mandates and penalties for EHR use. Although, John Halamka and Marc Probst have both recently asked for the same. We’ve written previously about how getting rid of meaningful use wouldn’t do much of anything to alter the current course of EHR and healthcare IT. It just wouldn’t change much of anything.

What could a presidential candidate do to impact healthcare IT? I really don’t see them having an interest in doing much of anything to impact the current course of healthcare IT. If you think otherwise, I’d love to hear why.

On the healthcare side of things we might see more changes. Certainly the topic of healthcare costing the US too much money is a very big an important topic for the president. However, I think Obamacare and those healthcare reform efforts are too far gone to be able to really go back and change them now. Sure, we could see some changes here and there, but I think it’s too late for a new President to really drastically change what’s already been done.

Related to this is the move away from fee for service to a value based reimbursement environment. Would any President condone this direction? Would any President advocate for a return to the old fee for service environment? I don’t see it happening. As many people have told me, the shift to value based care has left the building. There’s no coming back. Could they modify the approach and some of the details. Certainly! However, they’re not likely going to change the trajectory.

Long story short, I’m not sure any Presidential candidate will do anything that will drastically impact healthcare IT and healthcare as we know it. Sure there will be some tweaks that will have some impact, but nothing major like Obamacare or the HITECH Act.

Do you agree or disagree? I always love to hear other perspectives.

Hospital EHR Adoption Chart

Posted on May 15, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I always love a good chart and this one illustrates what those of us in the industry have know for a while. EHR incentive money absolutely increased EHR adoption in hospitals. I think it also did in ambulatory environments as well, but not quite to the extent of hospitals.

Can we just put the discussion of whether HITECH helped EHR adoption to rest? It increased EHR adoption.

To me that’s not the question that really matters. What really matters is whether the EHR incentive money has incented adoption of the right EHR software. It’s great that we’ve adopted EHR software, but have we just locked ourselves in to the wrong software for the next 5+ years? Or have we implemented a great EHR foundation that will prove to be extremely beneficial to healthcare for decades to come?

I look forward to a deep discussion in the comments.

The Fundamental Challenge of Building a Healthcare-Provider Focused Startup

Posted on March 6, 2015 I Written By

Kyle is CoFounder and CEO of Pristine, a VC backed company based in Austin, TX that builds software for Google Glass for healthcare, life sciences, and industrial environments. Pristine has over 30 healthcare customers. Kyle blogs regularly about business, entrepreneurship, technology, and healthcare at kylesamani.com.

Over the past few years, the government imposed copious regulations on healthcare providers, most of which are supposed to reduce costs, improve access to care, and consumerize the patient experience. Prior to 2009, the federal government was far less involved in driving the national healthcare agenda, and thus provider IT budgets, innovation, and research and development agendas among healthcare IT vendors.

This is, in theory (and according to the government), a good idea. Prior to the introduction of the HITECH act in 2009, IT adoption in healthcare was abysmal. The government has most certainly succeeded in driving IT adoption in the name of the triple aim. But this has two key side effects that directly impact the rate at which innovation can be introduced into the healthcare provider community.

The first side effect of government-driven innovation is that all of the vendors are building the exact same features and functions to adhere to the government requirements. This is the exact antithesis of capitalism, which is designed to allow companies to innovate on their own terms; right now, every healthcare IT vendor is innovating on the government’s terms. This is massively inefficient at a macroeconomic level, and stifles experimentation and innovation, which is ultimately bad for providers and patients.

But the second side effect is actually much more nuanced and profound. Because the federal government is driving an aggressive health IT adoption schedule, healthcare providers aren’t experimenting as much as they otherwise would. Today, the greatest bottleneck to providers embarking on a new project is not money, brain power, or infrastructure. Rather, providers are limited in their ability to adopt new technologies by their bandwidth to absorb change. It is simply not possible to undertake more than a handful of initiatives at one time; management can’t coordinate the projects, IT can’t prepare the infrastructure, and the staff can’t adjust workflows or attend training rapidly enough while caring for patients.

As the government drives change, they are literally eating up providers’ ability to innovate on any terms other than the government’s. Prominent CIOs like John Halamka from BIDMC have articulated the challenge of keeping up with government mandates, and the need to actually set aside resources to innovate outside of government mandates.

Thus is the problem with health IT entrepreneurship today. Solving painful economic or patient-safety problems is simply not top of mind for CIOs, even if these initiatives broadly align with accountable care models. They are focused on what the government has told them to focus on, and not much else. Obviously, existing healthcare IT vendors are tackling the government mandates; it’s unlikely an under-capitalized startup without brand recognition can beat the legacy vendors when the basis of competition is so clear: do what the government tells you. Startups thrive when they can asymmetrically compete with legacy incumbents.

Google beat Microsoft by recognizing search was more important than the operating system; Apple beat Microsoft by recognizing mobile was more important than the desktop; SalesForce beat Oracle and SAP because they recognized the benefits of the cloud over on-premise deployments; Voalte is challenging Vocera because they recognized the power of the smartphone long before Vocera did. There are countless examples in and out of healthcare. Startups win when they compete on new, asymmetric terms. Startups never win by going head to head with the incumbent.

We are in an era of change in healthcare. It’s obvious that risk based models will become the dominant care delivery model, and this is creating enormous opportunity for startups to enter the space. Unfortunately, the government is largely dictating the scope and themes of risk-based care delivery, which is many ways actually stifling innovation.

Thus is the problem for health IT entrepreneurship today. Despite all of the ongoing change in healthcare, it’s actually harder than ever before to change healthcare delivery things as a startup. There is simply not enough attention of bandwidth to go around. When CIOs have strict project schedules that stretch out 18 months, how can startups break in? Startups can’t survive 18 month cycles.

Thus the is paradox of innovation: the more of it you’re told to innovate, the less you can actually innovate.

Breaking News: Meaningful Use is Not Covering Costs

Posted on April 21, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In one of my recent interviews with a healthcare IT consulting company, they revealed some breaking news for those of us in the EHR world. They told me point blank that:

Meaningful Use is Not Covering Costs

Ok, so that’s not really breaking news. Although, it seems that very few people want to actually articulate this point. It almost feels like heresy that someone would “complain” about the fact that the government is spending $36 billion on EHR incentives and that the money isn’t enough to cover the implementation of these EHR systems.

Actually, I should clarify that last point. The EHR incentive money is covering the costs to purchase the systems. It’s not covering the costs of implementing those EHR systems and then poking, prodding and otherwise cajoling end users to show meaningful use of that system (not to be confused with meaningfully using the system).

Let me also be clear that I’m not complaining about the EHR incentive money. I’ve done enough of that previously. What I’m just trying to acknowledge is something that everyone who deals with the EHR budget already realizes, but no one seems to want to say it. Organizations are spending more money on EHR and meaningful use than they’re getting from the government.

I think this is important for a couple reasons. First, many organizations didn’t budget any EHR money beyond what the EHR incentive money. You can certainly argue this was a mistake on their part, but that’s going to leave a bunch of organizations in a lurch. We’re already seeing the fall out of this as news reports keep coming out about hospitals systems in financial trouble due to the costs of their EHR system. Plus, in each of these cases, it seems their costs continue to balloon out of control with no end in sight. It makes me wonder if the compressed meaningful use timeline is partially to blame for a rushed implementation and poor EHR implementation and cost planning.

Second, there is still a swash of providers and organizations that haven’t yet implemented their EHR. If you can’t support the cost of EHR with government money, how does that bode for those who won’t be getting any EHR incentive money? One could make the argument that they’ll actually be in a better position since they won’t have to worry about meaningful use and can just focus on getting value out of their EHR. Hopefully that’s the case, but many of the meaningful use functions are now hardcoded into the EHR systems. Even if an organization isn’t planning on attesting to meaningful use, that doesn’t mean they won’t be forced by their EHR software to do a bunch of things they wouldn’t have done otherwise.

What are you seeing from your perspective? Is the EHR incentive money covering the costs of an EHR implementation? What are the impacts if it doesn’t?

Realizing the Value of Health IT

Posted on September 16, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ve been focused on the value of healthcare IT for a long time. Obviously, I’ve been particularly focused on the value of EHR including a whole series of posts on the benefits of EHR (which I need to finish). I’m a huge fan of the value of EHR and healthcare IT, but I also am a realist. I realize that we aren’t getting all of the value out of healthcare IT that we could be getting. I also realize that poor health IT implementations can actually decrease value as opposed to increasing the value of health IT. Plus, I also see a huge disconnect between the value government sees in healthcare IT and what doctors find valuable.

If you don’t believe healthcare is missing out on the value healthcare IT could provide we don’t need to look any further than the fax machine. A recent CovisintPorter Research study found that “76% of respondents stated that they are handling their inflow of information via Fax.” Mr H from HISTalk aptly described this: “Healthcare: the retirement home for 1980s technology.”

I’ve also seen illustrated dozens of times the way a poor implementation can actually cause more problems than it solves. The Sutter EHR implementation is one example to consider. No doubt there is a lot of internal politics involved in the challenges that Sutter is facing with their EHR, but soon I’ll be publishing on Hospital EMR and EHR some first hand experiences with that EHR implementation. It’s a sad thing to see when an EMR implementation is done the wrong way. However, the opposite is also true. I’ve seen hundreds of organizations that love their EHR and can’t imagine how they practiced medicine before EMR.

One thing I’ve never heard a practicing doctor say is that they want to show meaningful use to be able to realize the value of health IT. I’ve certainly heard doctors say they have to show meaningful use to get the government money. I’ve certainly heard doctors say they want to show meaningful use to avoid the EHR penalties. I haven’t heard any doctor say they want to show meaningful use because it provides value to their clinic.

To me this illustrates the wide divide between the value government wants to see from healthcare IT and the value healthcare IT can provide a healthcare organization. Currently the government is riding on the back of incentive money and penalties to motivate healthcare organizations. No doubt this has caused many healthcare organizations to adopt an EHR. However, the incentive money and penalties won’t last forever. Then what?

What’s sad for me is that EHR adoption was starting to gain some momentum pre-HITECH act. There was a definite shift towards EHR adoption as organizations realized they needed to head that direction. Then, once the HITECH act hit it threw every EHR organizations plans out the door and created an irrational hysteria around EHR. This has led to irrational selection of EHR vendors, rushed EHR implementations, and cemented in many Jabba the Hutt EHR vendors that the relatively free EHR market wouldn’t have adopted pre-HITECH. To be honest, I’m ready for a return to a more rational EHR market based on value created. That’s when we’ll truly start realizing the value of health IT.

Beyond EHR, we need more brave leaders in healthcare IT that aren’t afraid to move beyond the fax machine. Leaders who don’t need a business model to realize that we can do better than the fax machine and other 80’s technology. It shouldn’t take five committees, two research studies, a certification, and outside money for an organization to do what’s right for patients. In fact, doing so is the very best business model in the world.

What scares me is that we’re going to miss out on the value of healthcare IT because our healthcare leaders are too busy fighting the proverbial meaningful use, ICD-10, and ACO fires.

Health IT & EHR State Summaries

Posted on June 18, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’m always happy to look at data. Certainly data can lie, but it can also inform if you are looking at the right data and considering the biases of the data. I applaud ONC for being as transparent as possible with the EHR incentive program data. They have an entire Health IT Dashboard for analyzing the data. I think this is a great step towards accountability for how the EHR incentive money is being spent.

ONC recently announced a set of Health IT Quick Stats and even created a widget (embedded below) that lets you download a 3 page health IT and HITECH summary for your state. I think a few states are missing from the widget and why they grouped them by area I don’t know, but there’s some interesting data in the reports.

I downloaded my home state of Nevada to see how we’re doing with Health IT and HITECH. Here are a few thoughts I had when looking at EHR use in Nevada.

I was amazed that so many REC assisted providers were live with an EHR, but less than half of those had demonstrated meaningful use. We’ll see if that changes after this years attestations.

I do have to question some of the data since it shows the overall access to view lab results electronically as 0% for Nevada. Something is wrong with their data there. They did show office based EHR adoption in Nevada at 23% (39% nationally). I’m not sure how that national EHR adoption number meshes with the $60% I’ve heard thrown around. Different sources of data.

For hospital adoption of EHRs they show Nevada at 36% EHR adoption (35% nationally). It’s nice to see Nevada ahead of the national average in something.

I’ve always told people there were about 700,000 providers in America, so I was glad to see they listed 715,984 health care providers.

Lots more data in there, but those were a few of the things that stood out for me in the Nevada Health IT and EHR report. Take a look at your state and let us know what numbers stand out for your state in the comments.

Hospitals, Representative Ask For Extension of EMR “Safe Harbor”

Posted on April 3, 2013 I Written By

Anne Zieger 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.

Right now, it’s legal for hospitals to give doctors EMRs under certain circumstances, despite the existence of the Stark law banning payments intended to induce referrals.  Specifically, hospitals won’t face anti-kickback enforcement if doctors pay 15 percent of the cost of EMRs donated by hospitals.

But the Stark law exception established by CMS, plus a “safe harbor” rule established by the HHS Office of the Inspector General, are both due to expire at the end of 2013. This will take place despite the fact that Medicare incentives for EMR adoption will continue through 2016, notes iHealthBeat.

Hoping to address this state of affairs, the Federation of American Hospitals has made the renewal of EMR exceptions to the Stark law its top recommendation in a proposed list of safe harbors, reports Modern Healthcare. More recently, Rep. Jim McDermott (D-Wash.) wrote a letter to the chief counsel to HHS’ OIG to extend those exceptions soon.

Extending these safe harbor provisions at least through the life of the Meaningful Use program seems necessary and wise. After all, it’s hard enough to get smaller practices up on EMRs even with the promise of incentives. Letting hospitals pay for most of the cost of the system would meet the public policy objectives which prompted the creation of HITECH in the first place.

According to Modern Healthcare, the federal Office of Management and Budget is reviewing proposed rules regarding the Stark exception and the anti-kickback safe harbor. Let’s hope they’re finalized in time to solve the problem.

Keeping Up with Healthcare Regulations

Posted on November 7, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I know that meaningful use and the EHR incentive regulatory process has been an eye opening experience for many of us that weren’t as familiar with how the government put regulations in place. However, most hospitals are quite familiar with this process since they have been having to deal with it for a very long time.

Even with all this background and expertise, I’ve heard more and more organizations telling me that “they just can’t keep up with all of the healthcare regulations.”

Think about all of the regulations in just healthcare IT. It’s overwhelming and the healthcare IT regulations pale in comparison to many of the other regulations that hospitals must know about and follow. Plus, we’re just getting started with the fun of 5010 and ICD-10 is right around the corner.

With all of these regulations I was intrigued by a new offering from HCPro I saw during the AHIMA convention in Chicago this year. While HCPro has long been a publisher of healthcare content, they have a new product they are just launching called HCPro Comply. I think the best way to describe HCPro is a portal into every healthcare regulation imaginable. Certainly you could find all these regulations in other locations for free, but there was something beautiful about having them all available in one easily searchable place.

Plus, HCPro Comply does a lot of things to add value to the regulations they make available. For example, they chunk out sections of the regulations that really matter. I remember my shock when I heard that the Meaningful Use regulation was 692 pages. Then, as I looked at the regulation, I realized that there were really only a small number of pages in the middle that really mattered since the beginning was a bunch of overview. From what I understand, HCPro uses its clinical regulation experts to help you identify and bring out those sections of the regulation that matter most.

The other part of HCPro Comply that I found quite interesting was their “Ask An Expert” feature. While many hospitals likely have someone (or multiple people) in their organization that understand regulatory changes very well, there are always situations where it’s beneficial to get outside advice and analysis about a particularly challenging regulatory change. I’m quite familiar with meaningful use, but I’m often emailing a number of other experts to either make sure my interpretation is correct or to ask about nuances I haven’t quite figured out.

One thing that I think HCPro Comply should consider adding is allowing the experts from the various hospitals share their expertise with their colleagues. I can easily see a community of healthcare regulatory compliance experts interacting on their platform to discuss the latest regulatory changes. I’m sure that HCPro has many experts on their staff, but a network of the top hospital compliance experts would be an even more powerful offering.

Now that Obama won the Presidential campaign, ACA, HITECH and other healthcare reform are here to stay. I can see portals like HCPro Comply being a great asset in the ever changing healthcare regulatory environment.

New Opportunities to Avoid ePrescribing Penalty for 2013 – Meaningful Use Monday

Posted on November 5, 2012 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.

According to the 2013 Medicare Final Rule released last week, there are new ways to avoid future payment adjustments under the MIPPA ePrescribing rule for those who have not already taken the necessary steps to avoid them: 1) The exemption request period has been reopened and 2) meaningful use will satisfy the ePrescribing requirements according to specific timetables.

1) CMS is offering a second chance to physicians who missed the June 30 deadline for requesting an exemption to the 2013 ePrescribing penalty (1.5%) under the original 4 categories. Between November 1, 2012 and January 31, 2013, physicians can go to the Quality Reporting Communication Support Page and request an exemption based on one of the following justifications:

  • Inability to electronically prescribe due to local, State, or Federal law or regulation (i.e., prescribe predominantly controlled substances)
  • Prescribed fewer than 100 prescriptions between January 1 and June 30, 2012
  • Insufficient high speed internet access (i.e., rural area)
  • Insufficient available pharmacies that accept electronic prescribing.

2) In the interest of harmonizing the various government programs that contain ePrescribing components, CMS now will provide two additional ways to avoid the 2013 MIPPA penalties:

  • Achieve meaningful use during 2013
  • Demonstrate intent to participate in the EHR Incentive Program and adopt Certified EHR Technology by January 31, 2013

This information will be retrieved by CMS from the information in its EHR Incentive Program’s Registration and Attestation System, rather than by having providers request an exemption as in #1 above.