Free EMR Newsletter Want to receive the latest news on EMR, Meaningful Use, ARRA and Healthcare IT sent straight to your email? Join thousands of healthcare pros who subscribe to EMR and HIPAA for FREE!!

Why Is It So Difficult To Reduce The Cost Of Care?

Posted on April 17, 2014 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.

By refusing to pay for readmissions within 30 days of discharge from a hospital, Medicare has sent a strong message across the healthcare industry: < 30 day readmissions should be avoided at all costs. As a result, providers and vendors are doing everything in their power to avoid < 30 day readmissions.

This seems like a simple way to reduce costs, right? Well, not quite…

The vast majority of costs of care delivery are fixed: capital expenditures, facilities and diagnostics, 24/7 staffing, administrative overhead, etc. In other words, it’s extremely expensive just to “keep the lights on.” There are some variable costs in healthcare delivery – such as medications and unnecessary tests – but the marginal costs of diagnostics and treatments are small relative to the enormous fixed costs of delivering care.

Thus, Medicare’s < 30 day readmission policy doesn’t really address the fundamental cost problem in healthcare. If costs were linearly bound by resource utilization, than reducing readmissions (and thus utilization) should lead to meaningful cost reduction. But given the reality of enormous fixed costs, it’s extremely difficult to move down the cost curve. To visualize:

Screenshot 2014-04-14 23.46.37

Medicare’s < 30 day readmission policy is a bandaid – not a cure – to the underlying cost problem. The policy, however, reduces Medicare’s outlays to providers. Rather than reduce (or expand, depending on your point of view) the size of the pie, Medicare has simply dictated that it will keep a larger share of the metaphorical pie for itself. Medicare is simply squeezing providers. One could argue that providers are bloated and that Medicare needs to squeeze providers to drive down costs. But this is intrinsically a superficial strategy, not a strategy that addresses the underlying cost problems in healthcare delivery.

So how can we actually address the fixed-cost problem of healthcare? Please leave a comment. Input is welcome.

EMRs and Patient Satisfaction

Posted on August 7, 2013 I Written By

James Ritchie is a freelance writer with a focus on health care. His experience includes eight years as a staff writer with the Cincinnati Business Courier, part of the American City Business Journals network. Twitter @HCwriterJames.

When it comes to keeping patients happy, EMRs matter, a new study suggests.

More patients are logging on to access their own records – and they tend to like it, according to data from research firms Aeffect and 88 Brand Partners. About 24 percent of patients have used EMRs for tasks such as checking test results, ordering medication refills and making appointments. And 78 percent of those patients reported being satisfied with their doctors, compared with 68 percent of those who hadn’t used EMRs.

“EMR users are telling us that they are more confident in the coordination of care they’re being provided, and think more highly of their doctors, simply because of the information technology in use,” Michael McGuire, director of strategy for Chicago-based 88 Brand Partners, said in a press release.

Patient satisfaction is fast becoming a top priority in health care as it determines a growing portion of providers’ reimbursement. So far, it’s mainly been an issue for hospitals. Their patient satisfaction survey results make up 30 percent of  their quality score in Medicare’s “value-based purchasing” program, part of the Affordable Care Act. In fiscal 2013, hospitals saw 1 percent of their Medicare reimbursement put at risk based on the overall score, which also considers performance on clinical measures. The figure will increase to 2 percent by fiscal 2017. Private insurers are also starting to link payments with quality scores.

The trend is now taking hold outpatient clinics, as well. About 2 percent of primary-care doctors’ compensation is tied to patient satisfaction measures, and the figure is likely to grow in coming years, according to a recent report from the Medical Group Management Association. Specialist physicians reported, on average, that 1 percent of their salary hinged on patient satisfaction.

Patients cited several reasons for preferring that their doctors use EMRs, according to the EMR Patient Impact Study from Aeffect and 88 Brand Partners. Among them were ease of access to information and the perceived clarity and thoroughness of communication that the records systems provide. And adoption rates could be set to go higher: 52 percent of survey respondents said they aren’t using an EMR yet, but would be interested in trying one. Only 18 percent said they had no interest.

A host of other factors, such as level of attention and ease of making appointments, also factored into patient satisfaction, according to the survey of 1,000 consumers. But for doctors who have implemented EMRs, getting their patients to log on might be a simple way to create a more loyal following. In many cases, according to the survey, EMR-using patients had adopted the technology after being encouraged by a physician.

Rural Hospital EHR

Posted on April 2, 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.

As I mentioned in my previous post on EHR Penalties and Meaningful Use Failure, I had a really good discussion with Stoltenberg Consulting about rural hospital EHR at HIMSS this year. While Stoltenberg no doubt works with hospital systems of every size, I could tell that they had a real affection for the rural hospital EHR challenge. Plus, it was great to be educated some more on the challenges rural hospitals face when it comes to meaningful use and EHR since I’ve been doing a lot more writing about it on my Hospital EMR and EHR website.

I collected a few observations from my chat that I think are worth talking about when it comes to the unique rural hospital EHR situation. One of those ideas is the challenge that rural hospitals have in providing EHR help desk support. It’s worth remembering that hospitals are 24/7 institutions that need 24/7 support in many cases. Now imagine trying to staff an EHR help desk for a small rural hospital. From what I’ve seen, most can barely have an IT support help desk available, let alone an EHR help desk. Stoltenberg Consulting wisely sees this as a great opportunity for EHR consults to provide this type of service to rural hospitals. If you spread the cost of a 24/7 EHR help desk across multiple hospitals, the costs start to make sense.

Another interesting observation was that most rural hospitals are mostly Medicare and Medicaid funded. I’m not an expert on the pay scales of rural America, but when you look at the costs of living in the rural areas you realize that they don’t need to make as much money to live. Plus, I imagine in some cases there just aren’t that many jobs available to them. If they aren’t making as much money, then they’re more likely to qualify for Medicare and Medicaid. Why does this matter?

The amount of Medicare a rural hospital has matters a lot since if they don’t show “meaningful use” of a “certified EHR” then they will incur the meaningful use penalties. It’s simple math to see that the more Medicare reimbursement you receive the larger the EHR penalty you’ll incur.

There’s something that doesn’t feel right about the rich hospitals who’ve likely implemented an EHR before the stimulus getting paid the EHR incentive money while rural hospitals who can barely afford to keep their doors open getting not only penalties, but large penalties because of their large Medicare reimbursement. It’s probably water under a bridge now, but I could see why Stoltenberg Consulting suggested that rural and community hospitals should have been given more time to show meaningful use of an EHR.

As I mentioned, I’m still learning about the rural hospital EHR space, but I found these points quite interesting. If you have a different view or have experience that differs, I’d love to hear about it in the comments. No doubt there are thousands of unique rural environments and I’d love to learn more about them and how they’re approaching EHR. Please share your experiences and thoughts in the comments.

Will EMR Adoption Bankrupt Medicare?

Posted on November 27, 2012 I Written By

Mandi Bishop is a hardcore health data geek with a Master's in English and a passion for big data analytics, which she brings to her role as Dell Health’s Analytics Solutions Lead. She fell in love with her PCjr at 9 when she learned to program in BASIC. Individual accountability zealot, patient engagement advocate, innovation lover and ceaseless dreamer. Relentless in pursuit of answers to the question: "How do we GET there from here?" More byte-sized commentary on Twitter: @MandiBPro.

Much hullaballoo is made over the 47% increase in Medicare payments from 2006-2010, which some seem eager to attribute to the adoption of EMR. The outcry is understandable; a 47% increase is a big dang deal, and taxpayers should be concerned. But haven’t we all heard that statistics lie?

“Hospitals received $1 billion more in Medicare reimbursements in 2010 than they did five years earlier, at least in part by changing the billing codes they assign to patients in emergency rooms,” cited the New York Times based on analysis of Medicare data from American Hospital Directory. Indeed, billing codes have changed from 2006-2010, in accordance with the HCPCS (Health Care Procedure Coding System) reform of CPT (Current Procedural Terminology) application and inclusion guidelines, cited here: HCPCS Reform from CMS. Healthcare industry growth and care advances drove an increase from 50 – 300 new CPT code annual applications between 1994-2004, leading to sweeping change in the review and adoption process starting in 2005 – including elimination of market data requirements for drugs.

Think about that for a second. If Pharma no longer has to submit 6 months of marketing data prior to applying for an official billing code, how many new CPT codes – and resultant billing opportunities – do you think have been generated by drugs alone since that HCPCS process change adoption in 2005? Which leads me to my next correlating fact: the most significant Medicare Part D prescription drug provisions did not start until 2006.

Let’s put two and two together: Medicare Part D prescription drug coverage (2006) + change in HCPCS billing code request process to speed drugs to market adoption (2005) = significant increase in Medicare reimbursements. To use the NYT analyst language, “in part”, administration of those drugs occurs in an emergency room. And who might be in the ER on a regular basis? I’ll give you a hint: “I’ve fallen, and I can’t get up!”

Perhaps the most profound contributor to this Medicare reimbursement increase is a recent dramatic rise in the Medicare-eligible population. Per the National Institute on Aging’s 65+ in the United States: 2005, the 65+ population is expected to double in size between 2005 and 2030 – by which point, 20% of the US will be of eligible age. The over-85 age group, as of 2005, was the fastest-growing population segment. Elderly people who are prone to chronic conditions as well as acute care events just might lead to higher Medicare reimbursements.

Of course, there are myriad contributing factors. Some industry analysts attribute the rise in Medicare claims cost to fraud, citing that the workflow efficiencies that the EMR technology provide allow for easy skimming. Activities such as “cloning”, or copying and pasting procedures from one patient to the next with minimal keystrokes within the EMR software, might contribute to false claim filing for procedures that were never performed. While the nefarious practice of Medicare fraud long predates EMR, the opportunity to scale one’s fraudulent operations to statistically relevant proportions increases significantly with automation. And as my mother always told me, it only takes one bad apple to spoil the bushel.

But how many bad apples would it take to spoil a multi-billion dollar bushel to the tune of a 47% cost increase? According to the NYT article, “The most aggressive billing — by just 1,700 of the more than 440,000 doctors in the country — cost Medicare as much as $100 million in 2010 alone,” and the increase in billing activity for each of those 1700 occurred post-EMR adoption. After all, “hospitals that received government incentives to adopt electronic records showed a 47 percent rise in Medicare payments…compared with a 32 percent rise in hospitals that have not received any government incentives.”

Wait, did that statistic just indicate a significant increase in Medicare reimbursements, across the board? So the differential between those providers who have received government incentives for EMR adoption, and those who have not, is 15%. The representative facilities and providers responded to the “aggressive billing” accusation by indicating that they had 1) more accurate billing mechanisms, 2) higher patient need for billable services. I’ll buy that. Sure, it’s likely that there is Medicare fraud happening, but that’s not new – it’s unfortunate that there will always be ways to game the system, whether manual or electronic. But is the increase in “fraud” pre and post-EMR adoption statistically relevant?

Considering the complex variables involved, I’ll chalk up the 15% increase to the combination of more specific billing practices, Medicare Part D drug provisions, an aging population and the health issues which accompany it, and not vilify the technology which facilitates further advances. Let the EMR adoption expansion continue!

Will Meaningful Use and EHR Incentive Put Medicare in a Bad Position?

Posted on September 12, 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 Jennifer’s post on Raising EMR in the Meaningful Use era, the always colorful Al Borges, MD provided the following comment:

Ahhh- but John, you’ve never compared EHR/MU to Death! The current Federal Government involvement in HIT is to providers more like the 5 steps of death and dying:

1) Denial and isolation: “This is not happening to me.”
2) Anger: “How dare Obama do this to me! What a jerk!”
3) Bargaining: “Please Obama- just let me continue to survive under Medicare.”
4) Depression: “I can’t bear to face going through this, I’m meaningfully depressed.”
5) Acceptance: “I’m ready to empty my pockets, go into debt, and possibly buy an expensive EHR or just retire… I don’t know. All I know is that I don’t want to struggle anymore.”

I, for example, am perpetually stuck in step 2. I continue to buck the system whenever I can. I’ve actually quit doing hematology/oncology and streamlined my [now] internal medicine practice to survive in these tumulous waters. Result: as more than 60% of the offices next to Virginia Hospital Center [my admitting hospital] have closed and been bought out by the hospital, I’m part of the less-than-40% that have survived. My income for 2011 will most likely show a doubling of my personal gross income.

As I’ve become a “nonpar” Medicare provider, I initially lost many Medicare patients, but I’ve gained what I want now- cash paying and younger PPO/HMO patients to fill in the empty slots. Many Medicare patients now have come back too, because I give them attention and the best care that I can offer. They pay me up-front using the “nonpar” Medicare contractual scale. THEY end up paying the current (s.a. eRx) and future penalties that Medicare will shell out, which is what always happens when big government taxes businesses- the clients end up paying the bill.

Some go through to step 5, buy an EHR, then either deinstall their systems, become hospitalists (or go to another endeavor), or retire. I plan on NOT going through these routes, at least for the next 10 years.

What needs to occur is that the Federal Government has out of HIT. Until that happens, we will never achieve a true “meaningful use” of EHR systems. Yes, doctors will get into inexpensive EMRs (like I have), but they will never buy into something that they cannot afford in both time and money. If EHR/MU continues, you’ll see Medicare suffer as doctors opt out or become “nonpar” making it difficult for the elderly to get the care that they need.

I know that Dr. Borges isn’t the only doctor that has done what he’s done. He’s much more outspoken about it than most, but every doctor I’ve ever met has had essentially the same feeling about Medicare: They hate it. Those that only modestly hate it do so because they realize that currently their livelihood depends on it. Although, even those wish they had a way to get out from Medicare.

While Dr. Borges story is interesting, his last question is the one that I think should be most concerning. Will the EHR incentive money and meaningful use drive many doctors to abandon Medicare and put Medicare in a bad position? One thing I believe goes against this trend is the number of hospital owned practices. I haven’t dug into the economics of hospital owned practices, but I’m pretty sure they won’t have the same flexibility to leave Medicare. I’d love to hear if you think otherwise.

Is Dr. Borges in the minority or could EMR and MU become a real issue for Medicare?

GINA, Runtastic, and The Future of Patient Engagement: Around HealthCare Scene

Posted on August 19, 2012 I Written By

Katie Clark is originally from Colorado and currently lives in Utah with her husband and son. She writes primarily for Smart Phone Health Care, but contributes to several Health Care Scene blogs, including EMR Thoughts, EMR and EHR, and EMR and HIPAA. She enjoys learning about Health IT and mHealth, and finding ways to improve her own health along the way.

EMR and HIPAA

Worried about HIPAA? Don’t Forget GINA

If remember HIPAA regulations wasn’t hard enough when it comes to EMR security, a new factor is being brought to the table: GINA. GINA, which stands for Genetic Information Non-Discrimination Act, primarily aimed at the workplace. The purpose of GINA is to prevent employers from requesting or obtaining any genetic information concerning an employee at any time. This post discusses GINA, and possible issues that may be related to it.

Hospital EMR and EHR

Medicare’s New Requirement for Evidence-based Order Sets

This is a guest post by Sean Benson, co-founder of ProVation Medical. He discusses the new changes to Medicare’s Conditions of Participation for hospitals that recently went into effect. These changes were small, but significant, and Benson clears up things that might be confusing, and clarifies the new requirements.

5 Mistakes Healthcare Vendors Make in Tracking Customer Satisfaction

The company, KATALUS Advisors, focuses quite a bit on helping healthcare vendors interact with their clients. Chris O’Neal, Managing Partner at KATALUS Advisors, recently created a list of the top 5 mistakes that he sees healthcare vendors make in tracking customer satisfaction. He mentions the importance of customer satisfaction, and how “savvy” vendors are finding ways to avoid this pitfalls.

Smart Phone Health Care

Runtastic Makes Tracking Exercise Easier and More Fun

As a follow up to a recent post about apps for runners, this post has a review of another great running app, Runtastic. The app has tons of features, including a 3D Google Earth view of completed workouts. The basic app is free to download, however, upgrades and exercise plans are available for a fee.

FDA Approves Voice Guided Epinephrine Injector: Auvi-Q

Many people are plagued with allergies, and at times, have to rely on an epinephrine injector to save their lives. However, when an allergic reaction happens, the victim may not be able to use the injector themselves. As a solution, the FDA has recently approved an epi pen, called the Auvi-Q, which provides step by step audio on how to use the injector and save a life.

EHR and EMR Videos

GetWellNetwork Unveils the Future of Patient Engagement Video

GetWellNetwork released a video recently which illustrates how innovations in IPC will improve outcomes for patients for hospitals by becoming a part of everyday life. IPC has been implemented in over 20,000 hospital beds across the US and GetWellNetwork has been leading the way for IPC.

Meaningful Use Infographic – Meaningful Use Monday

Posted on August 13, 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.

It seems that everyone (including myself) love infographics. So, I was really glad to see that Greenway (Full Disclosure: They advertise on the site, but they didn’t ask me to post this. I found it on my own.) put together an Infographic with the Meaningful Use stats. They offer the following important details on the data for the meaningful use infographic:

  • Payment and registration statistics as of May 2012
  • Top Specialties participating in Medicare MU 2011
  • Meaningful Use attestations by Region 2011
  • Money available for Eligible Providers
  • Who is eligible to participate
  • Necessary steps to achieve Meaningful Use

88 New ACO Organizations – What Does That Mean?

Posted on July 24, 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.

It has been a really interesting couple months for those interested in ACO’s (Accountable Care Organizations) and healthcare. I love how Gregg Masters of ACO Watch called the ACO the “Child of the ACA (Accountable Care Act).” He even declares the SCOTUS supreme court ruling as a big battle won for the ACO. I certainly can’t disagree with him when it comes to the government ACO initiatives. The loss of ACA would definitely hamper much of the government’s work on ACOs. Although, he also acknowledges that ACA is still up in the air pending the Presidential election. ACA is directly in the republican cross hairs.

Politics aside, the ACO program is going forward. CMS recently named 88 new Accountable Care Organizations (ACOs) that will take part in the Medicare Shared Saving Program (Originally it was 89 ACOs, but one organization dropped out).

You can see the full list of ACOs on the press release linked above, but I really like this image that The Advisory Board Company put together that shows the location of the various ACOs across the US (click image twice for full size):

I think this represents a pretty good distribution across the country. However, there are a few things that I find a bit disturbing about the organizations participating in the government ACO programs. The first is that many healthcare organizations that you think would be perfect fit for an ACO aren’t participating. Kaiser and IHC come to mind. I’ve heard that both organizations are very interested in ACOs, but not the government ACO programs. I think this is a bad sign for the government sponsored ACO programs.

The second is that only five of the ACOs applied for the version of the Medicare Shared Savings Program where they have a chance to earn a higher share of any savings, but they’ll also be accountable for any losses if the cost o the care increases. You might take a look back at my ACO Risks and Reward post. These five organizations have gone all in with the ACO program. With that said, I wonder why only five of them chose to participate in it? Shouldn’t we want more organizations to have some accountability and responsibility if they don’t improve care and lower costs?

As I have pointed out before, the ACO movement is happening and is not likely to slow down. Even if ACA or other government legislation is repealed, the move to ACOs is going to happen. With that knowledge and some of the comments above, it makes me wonder if the government should be the one funding an ACO initiative. Will their involvement help or hurt the overall ACO movement?

I’ll be interested to see how it goes for these new ACOs. As we’ve seen with EHR and meaningful use, we’ll have to be careful to filter through the messages coming out of CMS about the success or failure of the ACOs. As they progress we’re going to have to reach out to the ACOs and hear the first hand stories. If you’re an organization that’s participating, we’d love to hear your thoughts in the comments.

The Meaningful Use Stage 2 Proposed Rule: Highlights for Providers – Meaningful Use Monday

Posted on February 27, 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.

Although I cannot claim to have read through the entire 455-page Proposed Rule on Stage 2 Meaningful Use, the fact that it is shorter than the 864-page rule that defined Stage 1 does not mean that it is simpler—it just requires less explanation since the basic structure of the program has not changed.

Rather than trying to summarize the Rule at this point, I am just going to point out some highlights gleaned from the presentations at HIMSS last week and from my quick skim through the document:

  • The meaningful use bar has been raised significantly for Stage 2.
  • The earliest that any providers will be subject to Stage 2 requirements is 2014; all EPs operate under Stage 1 requirements for their first 2 years of participation, regardless of when they first enter the program.
  • Most measures have higher thresholds, some have increased complexity, and new measures have been added.
  • Providers have fewer choices—there are 17 Core Measures that all providers must meet (subject to the same types of exclusions as Stage 1), all Stage 1 Menu Measures except syndromic surveillance become Core Measures, and providers will have to meet 3 of the 5 Stage 2 Menu Measures.
  • True interoperability is required—Stage 2 no longer asks providers to test their ability to exchange clinical data, but rather requires them to successfully exchange information on an ongoing basis across organizational and EHR vendor boundaries.
  • Providers will be accountable, to some degree, for actions by patients. For example, it will no longer be sufficient to make clinical information available to patients online—in Stage 2, a percentage of patients will have to actually access this information.
  • Providers will have the flexibility to purchase just the capabilities that they need to meet meaningful use—e.g., a chiropractor who does not prescribe will not have to have an EHR with ePrescribing capabilities, and a provider who is still at Stage 1 will not have to possess the meaningful use capabilities relevant to Stage 2 (until he gets to Stage 2).
  • Providers will report on 12 clinical quality measures, and there will be a broader array of measures from which to choose. One option under consideration would consolidate reporting for meaningful use and PQRS.
  • 2015 penalties can be avoided by demonstrating meaningful use in 2013, or for those who enter the program in 2014, by successfully attesting no later than October 3, 2014.

For more information, see the CMS Stage 2 Meaningful Use Fact Sheet.

Are Retiring Physicians Eligible for Incentives? – Meaningful Use Monday

Posted on February 20, 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.

As the industry anxiously anticipates the Proposed Rule for Stage 2 meaningful use—likely expected during HIMSS this week—many providers are still struggling to understand meaningful use Stage 1. So while we wait for the impending news story to break, let me address another question that was recently posed by a reader. 

Q: Can a physician attest and earn a Medicare EHR incentive for his second reporting year if he will be retiring in the middle of the year? 

A: To my surprise, this situation is not explicitly addressed in the regulations. One would think that a physician who works full time for part of the year would be just as eligible as one who works part time for the full year. The retiring physician, however, faces two obstacles: 1) The regulations require that an EP report for an entire calendar year after receiving a first meaningful use payment. 2) The EP must have an active enrollment record in PECOS (Medicare) to be eligible to attest—if he retires and withdraws from Medicare, he would no longer have active status. These factors suggest that a retiring physician is not eligible for an incentive (unless, of course, he times his retirement for the end of the year!)

In lieu of a definitive answer to the question, however, I offer the following food for thought: 1) Couldn’t the retiring physician simply wait until December 31 to attest and then report on the full calendar year? 2) What if he simply postpones surrendering his PECOS enrollment until the end of the year? (According to a local Medicare contractor, nothing prohibits him from doing that even though he would no longer be submitting claims.) If there are countervailing reasons not to do this that readers are aware of—and there may well be—please share your insights by commenting below. 

(Note: This is not an issue for retiring physicians in their first incentive year since they attest immediately upon the conclusion of their 90-day reporting period.)