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Revisiting the ROI of an EHR Investment

Posted on August 5, 2014 I Written By

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Meaningful Use Audits, RAC Audits, and HIPAA Audits

Posted on July 14, 2014 I Written By

The following is a guest post by Barry Haitoff, CEO of Medical Management Corporation of America.
Barry Haitoff
Healthcare has always been a deeply regulated industry, so in many ways healthcare organizations are already used to dealing with government scrutiny. However, we’ve recently seen a number of new audit programs hit the healthcare world that didn’t exist even a few years ago. Here’s a look at a few of them you should be prepared for.

Meaningful Use Audits
This is one of the newest audit programs to hit healthcare. Depending on your attestation history, it could have a tremendous impact on your organization’s financial health. These EHR incentive audits have been happening across every size organization and are conducted by the CMS hired auditing firm, Figliozzi and Company of Garden City, N.Y. If you get a letter or email from Figliozzi you’ll know what it is right away. An EHR incentive audit is a big deal since the meaningful use program is all or nothing. If they find even one thing wrong with your meaningful use attestation, you could lose ALL of your EHR incentive money.

CMS recently released an informative guidance document outlining the supporting documentation needed for an EHR incentive audit. Pages 4 and 5 of the document go through the self-attestation objectives and others detailing the audit validation and suggested documentation needed for each. If you’ve attested to meaningful use, then you’ll want to take some time to go through the document to make sure you can provide the necessary documentation if needed. In many cases this simply includes dated screenshots to prove measure completion. While many EHR vendors can be helpful in the meaningful use audit process, you should not totally rely on them.

In a recent blog post, Jim Tate makes a compelling case for why you might want to consider doing a mock EHR incentive audit and how to make sure that the audit is effective. Although smaller organizations won’t likely be able to afford an outside audit, having it done by someone in your organization that wasn’t involved in the attestation is beneficial. The CMS guidance document could be used as a guide. A mock audit could help discover any potential issues and help you put mitigation strategies in place before you have a real audit and your hands are tied.

Recovery Audit Contractor (RAC) Audits
RAC audits are currently on hold as CMS works to improve the program and deal with the enormous audit backlog. We still haven’t heard from CMS about when the RAC audits will resume, but we should hear something later this summer. While no RAC audits are occurring right now, that doesn’t mean that once the RAC audits resume, the claims you’re filing today can’t and won’t be audited.

The best thing you can do to be prepared for RAC audits is to make sure that your documentation and billing ducks are in a row. A great place to start is to look at your most common denials and look at how you can improve your clinical documentation, coding and billing for each of these denials. Also, make sure that your process for responding to audits is standardized and effective. The RAC audit is just one example of an audit performed by payers. Don’t be surprised if you’re subjected to audits from other agencies or commercial payers.

RAC audits recovered billions of dollars in overpayments in recent years. You can be sure that they will continue and that other similar initiatives are coming our way. There’s just too much incentive for the government not to do it.

HIPAA Audits
The US Department of Health and Human Services’ Office for Civil Rights (HHS OCR) first started doing HIPAA audits as part of a 2011 pilot program. It’s fair to say that HHS OCR’s audit program was one of discovery as much as it was of compliance. However, the HITECH Act and Omnibus Rule have started to up the ante when it comes to enforcement of HIPAA. HHS OCR announced that they’d be surveying 800 covered entities and 400 business associations to select the next round of audit subjects. An OCR Spokesperson said, “We hope to audit 350 covered entities and 50 BAs in this first go around.”

Unlike previous audits that were done by KPMG, these HIPAA audits will be done by OCR staff. One area that these audits will likely focus on is the HIPAA Security Risk Assessment. The importance of doing this cannot be understated and is illustrated by the fact that it’s a requirement for meaningful use. I will be surprised if these audits don’t also focus on the new HIPAA Omnibus Rule requirements. I’m sure many of the HIPAA audits will catch organizations that never updated their HIPAA policies to comply with HIPAA Omnibus.

Summary
No one enjoys an audit of any sort. However, being well prepared for an audit will provide some level of comfort to yourself and your organization. Now is your opportunity to make sure you’re well prepared for these audits that could be coming your way. These audit programs likely aren’t going anywhere, so take the time to make sure you’re prepared.

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

CMS May Revisit Patient Engagement Rules – Meaningful Use Monday

Posted on October 29, 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.

Health Data Management has a fascinating quote from Travis Broome, specialist at CMS, during a presentation on meaningful use Stage 2 at MGMA 2012.

Stage 2 electronic health record meaningful use requirements that at least five percent of patients conduct secure messaging with physicians, and view, download, or transmit their ambulatory and inpatient data came at the insistence of HHS Secretary Kathleen Sebelius. And those requirements might not be set in stone.

The patient engagement requirement has long been one of the most talked about challenges with meaningful use stage 2. The problem is easily seen. Doctors EHR incentive is being held hostage by something they don’t control. If patients don’t want to access their health information, are doctors suppose to coerce them into doing so?

An article in Fierce Health IT also has a money quote on what’s wrong with this MU stage 2 provision:

As Jeremy Tucker, medical director of MedStar St. Mary’s Hospital in Leonardtown, Md., told FieceHealthcare, better patient experience comes from cultural change across all levels of the organization. “If the reason for doing patient experience is simply to get a better score on a test, you will fail,” he said. “It only takes one cold meal tray or a roll of the eyes by a staff member to derail the patient experience.”

While I love the intent of patient engagement, I don’t love it as a requirement for EHR incentive money.

Another great comment from Broome from the Health Data Management article above is in regards to meaningful use audits:

Answering a question about meaningful use payment audits, Broome acknowledged that the audits have begun. He declined to give many specifics other than saying that providers falling into certain “risk profiles” might be asked to justify their attestations. One practice, for example, attested to meaningful use and supplied identical statistics across multiple criteria, all but inviting suspicion. When challenged, that practice returned the money, Broome said.

UPDATE: Travis Broome sent me this clarifying tweet:


Of course we know he can’t do anything without the secretary approval. Hopefully the bar is a little more than everyone failing. How about almost everyone failing or most people failing?

OIG to Include Meaningful Use and EHR Incentive Reviews – Meaningful Use Monday

Posted on October 22, 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.

We all knew that meaningful use audits were on their way. Healthcare IT News is reporting that the Office of the Inspector General (OIG) will undertake a review of ARRA which will include probes into the EHR stimulus program.

“We will review Medicare incentive payments to eligible health care professionals and hospitals for adopting electronic health records (EHR) and the Centers for Medicare & Medicaid Services (CMS) safeguards to prevent erroneous incentive payments, the OIG’s states in its work plan for fiscal year 2013.

In its plan OIG states it will look at incentive payments CMS made beginning in 2011 to identify payments to providers that should not have received incentive payments – those that did not meet the meaningful use criteria.

This shouldn’t come as a surprise to anyone. Considering meaningful use is a self attestation process, then it’s just common sense that the self attestation will receive an audit to help ensure that people attested to meaningful use properly.

Plus, if you’re a regular reader of this site, you might remember that we’ve written about meaningful use audits a few times before. I don’t know anyone that likes audits, but Lynn Scheps provided a good list of suggestions on what documentation you should keep from your meaningful use attestation.

If you’re part of a meaningful use audit or hear about what’s involved in the meaningful use audits, please do let us know in the comments. We’d love to learn from those who have first hand experience with the process.

MU Attestation Audits – Meaningful Use Monday

Posted on July 30, 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.

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.

By definition, attestation is based on the honor system—that is, at least until you find yourself the subject of an audit. CMS has launched its anticipated program, and some physicians who have received an EHR incentive payment recently received a letter from the designated auditing firm, Figloiozzi and Company

Although there is no way to predict which physicians will be audited, providing the information requested should not be too onerous a task for those “lucky” ones who are tapped. Providers are being asked to show proof that they possess a certified EHR and to substantiate the data they reported for the core and menu measures—specifically, via “a report from their EHR system that ties to their attestation.” Since all certified EHRs generate an automated measure calculation report and a clinical quality measure report, that documentation should be readily accessible. It would not surprise me if they are also asked to provide documentation of the security and risk analysis that the practice conducted to ensure HIPAA compliance. For suggestions regarding the type of data to retain to support your attestation, see the Meaningful Use Monday post, MU Attestation: Save Your Documentation.

Based on material published by the auditors and by CMS on its EHR Incentives website, it does not seem that the audits will be so detailed as to require site visits or reviews at the patient chart-level. My sense is that CMS is looking to identify failures to comply with the major requirements—adopting and using a certified EHR to meet the meaningful use measures and reporting accurately on the data generated by that EHR. 

(If you have been audited and would like to share your experience, please post a comment.)

First CMS Audits of Meaningful EHR Users – Meaningful Use Monday

Posted on July 2, 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.

In response to the topic I covered in my post on gaming the EHR incentive money, I got the following message:

Although I suppose this is within the letter of the law, it seems like a highly suspect practice, especially when CMS has said on conference calls that people who take the first check and subsequently drop out will be the first in line for audits.

I found this reply quite interesting. I’d never heard CMS say on a conference call that the first meaningful use audits would be those who got the first EHR incentive check and then chose to stop with meaningful use. Are there other readers that have heard this as well or that have heard or read similar things?

I’m a little torn on the idea of meaningful use audits. I’m certain that CMS will be doing meaningful use audits. It’s just a matter of time and how they’ll complete the audits of meaningful use. However, I don’t think they’re tremendously motivated to really clamp down on auditing those that adopt EHR software. I don’t think they want the bad PR of practices that have adopted EHR software getting audited and losing their EHR incentive money. They want doctors to adopt EHR and they want to pay them the EHR incentive money.

I guess the one exception to the above comment is those that really aren’t adopting EHR software and instead are just trying to game the system. CMS will likely be happy to make an example out of those doctors. Add in that Medicaid is done by the states and doesn’t require meaningful use and I’ll be interested to see how many doctors get the first Medicaid EHR incentive check and bypass the rest of the checks. I think there’s a lot of funny business that’s going to happen with the Medicaid EHR incentive money.

What else have you heard about EHR Incentive money audits and Meaningful Use Audits? I’m going to try and get some people familiar with other healthcare audits to share some thoughts on how to prepare to deal with the future meaningful use audits.

Meaningful Use 2012 Predictions – Meaningful Use Monday

Posted on January 2, 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.

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?