I spend a lot of my day answering questions about the EHR incentives from SRS clients and also from users of other EHRs. The questions range from extremely basic ones posed by people who are dazed and intimidated by the scope of the program to nuanced questions from those already knee-deep in meaningful use. Since I began writing Meaningful Use Monday, the resources on the subject have grown in number and specificity. Here are a few that physicians and administrators have found helpful recently:

• Participate in a CMS Provider Call. There is one scheduled for this Thursday (5/19) at 2:30 PM Eastern Time. After the presentation, you will have an opportunity to ask questions and have them answered directly by CMS staffers. To register, click here.
• The Attestation Users Guide not only provides information about both the registration and attestation processes, but by looking through it page by page, you will gain a in-depth understanding of the program‘s structure and how the requirements all fit together.
• The CMS FAQ website is continually updated and has a search function that allows you to zero in on the information you need without reading through all (currently 148) questions.
• Call the EHR Information Center: 1-888-734-6433 when you have questions or subscribe to the CMS Listserv to receive meaningful use news and updates.
• I also invite you to take advantage of the meaningful use section of the SRSsoft website, where you will find a great deal of distilled information on the EHR incentives program and links to where you can find more.

Next week I will write about some interesting information I learned during a recent CMS call when I asked a question related to the reporting of clinical quality measures.

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.

Likewise, says Allscripts’ Tullman, “today we’re building the operating system for the future of healthcare. This country can’t afford its healthcare system anymore, so something’s got to change. We can no longer buy our way out of the problem.” – Source: Information Week

The above comments sparks all sorts of interesting thoughts and questions for me. The first is “What is the Operating System of healthcare IT?” Obviously, we’re quite sure Tullman hopes that it’s the suite of Allscripts products. Although, how ironic is it that one company can have 5-10 (I lost count) different EMR software. I’ve never known an operating system to have 5-10 completely different software. Seems like something needs to change there. Unless you want to say that various segments of healthcare IT are going to have different operating systems.

I do feel like EHR software is the operating system of healthcare IT. It’s going to be the basis upon which many other software packages are built on.

I imagine the above statement is probably why Tullman made the comment and the comparison. Allscripts has an ambitious project (although I haven’t seen many results yet) to create a kind of app eco system for healthcare IT apps. There are other vendors that do the same. For example, I know that SRSsoft has open API’s that allow developers to extend their apps. I love this movement in the EMR world. My biggest challenge is identifying the application developers that are interested and willing to leverage these APIs. That part of the app ecosystem seems to be missing to me.

My next thought is that similar to how we didn’t realize how beneficial an application like Excel would be until we had the operating system that facilitated its creation. Who is going to create an Excel like app that can run on the EMR operating system and provide benefits to claims processing, clinical decision support, diagnosis help, insurance billing, etc etc etc. Certainly it’s possible that the O/S (EMR) developers will make a lot of these applications, but I won’t be surprised if the EMR is just the platform that allows other smart people to innovate on a particular subject.

In my time writing about EMR, one thing has been very clear. You can’t be all things to all people. An EMR vendor that embraces, supports and creates a strong healthcare IT application developer community would cause me to take notice above the noise.

I’m excited to announce the beginning of Meaningful Use Monday on EMR and HIPAA. I first came up with the idea when Lynn Scheps from SRSsoft commented on one of my previous meaningful use posts. Lynn provided such valuable information, I asked her if she’d be interested in becoming a regular guest blogger on EMR and HIPAA. As they say, the rest is history. Each Monday, Lynn (and sometimes myself) will be covering some topic related to the EMR Stimulus money and meaningful use. We hope you enjoy Meaningful Use Monday.
-John

With the impending start of the EHR incentive program on January 1, the results of a recent Health Data Management poll are troublesome. 72% of respondents feel that the meaningful use guidance provided by the government to-date has been either “inadequate and confusing” or “of little use,” with only 8% categorizing it as good.

It is critical to understand the requirements accurately because the regulations provide “no recourse” for providers whose attempt to demonstrate meaningful use is deemed unsuccessful. So where does a provider go for definitive information and answers to their questions?

• The most reliable source to-date has been the CMS website and its FAQ page, but as I learned when I submitted a question, the term “FAQ” is meant quite literally: An automated response informed me that only “frequently-asked” questions are answered! So, if your question is not a common one, this source will not provide the information you seek.
• Vendors and medical societies have offered numerous webinars and educational meetings since the legislation was passed in February 2009, but be aware that presenters have varied in their interpretations of some of the requirements.
• Regional Extension Centers exist to assist providers, but their focus is limited to hospitals and primary care physicians, and they charge for their services. UPDATE: As has been mentioned in the comments, not all RECs charge for their services.
• Knowledgeable consultants will be very busy and may also be costly.
• The most promising source:  CMS has just established the EHR Information Center: 1-888-734-6433. If it operates as well as the ePrescribing and PQRI Quality/Net Help Desk, it will be a great source of information. As of the writing of this post (12/23), however, that number is answered with a recording that refers callers back to the CMS website. Hopefully, the Information Center will be live by the start of 2011.

Lynn Scheps is Vice President, Government Affairs at EMR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

It has become more and more apparent that the way an EMR vendor implements the meaningful use requirements is going to be critically important to a doctor’s successful adoption of the meaningful use criteria which is of course essential to get the $44,000 in EMR stimulus money.

I think it’s easy for doctors and practice managers that aren’t as familiar with the various EMR software and with the details of the EMR stimulus to get confused. On face, it seems that the effort to get the EMR stimulus money shouldn’t be affected by which EMR software you choose as long as it is an ONC-ATCB certified EMR. However, this is just categorically WRONG!

The EHR certification is meant to tell you that it CAN meet the meaningful use guidelines. It doesn’t tell you how easily it is to meet the meaningful use guidelines. It doesn’t tell you how well they integrated the meaningful use guidelines into your regular workflow. It doesn’t tell you how well it lets you delegate the meaningful use tasks to other staff members so you can optimize the doctors time. So, yes, EHR certification should mean it’s possible to show meaningful use. EHR certification does not make any claims to how effective that EHR software will actually accomplish the task.

Here’s a simple analogy:
If I wanted to dig a hole for a footing on a house, I could probably use a spoon to dig the hole. It would take forever to actually dig the hole, but a spoon could work. It would suck to use a spoon to dig the hole and quite honestly I’d probably give up before I finished, but with enough blood sweat and tears I could get the hole dug.

Of course, if I had a shovel, digging the hole would be much easier. I could get it done with just a bit of hard work. It would obviously go a lot faster than a spoon. Now, if I had a backhoe, digging the hole would basically be academic. Achieving the goal would be simple to accomplish, because the tool was designed perfectly to achieve it.

It’s worth asking yourself whether the EMR you use or the EMR you choose is a golden spoon or a powerful backhoe when it comes to achieving meaningful use. Maybe both can achieve the goal of meaningful use, but is it just made to look nice and shiny or was it really designed to make achieving meaningful use as painless as possible?

Thanks to Randall Oates from SOAPware and Evan Steele from SRSsoft for inspiring this post.

I was talking with Randall recently about SOAPware’s approach to EHR certification and meaningful use. He told me that SOAPware could have thrown something together quickly and been easily certified against the EHR certification criteria when it first opened. However, he didn’t like that approach. Instead he wanted SOAPware to take its time and make sure that the criteria were implemented in a usable and useful way.

Evan just posted a blog post about not all meaningful use EMR being equal. Here’s one portion of what he said that prompted this post:

Demonstrating meaningful use will still demand additional work, and certified—or to-be-certified—EMRs are not alike in how they facilitate doing this. It is critical for physicians to understand and evaluate the differences among EMRs in terms of how they deliver meaningful use capability and the impact on the time it takes to meet the requirements with each.

Evan also offers a few suggestions on things you might ask your EMR vendor:
*How easy is it to enter the required data? (This is particularly important as requirements become more demanding in future stages of the program.)
*What changes will you have to make to the way you see patients?
*How will you document the care you provide?
*Does the system effectively allow delegation of tasks to staff members to minimize the time physicians must spend doing data entry?
*Does the vendor’s software platform enable keeping up with evolving requirements?

There you go! Now you have a list of questions you can ask SRSsoft (and other EMR vendors) when you’re evaluating them.

I’d love to hear other ways people are evaluating an EMR vendor’s implementation of meaningful use. Not to mention ways that EMR vendor’s have implemented meaningful use that differentiates themselves from other EMR vendors.

I love the smart readers from this site. They always keep me in line and do a good job clarifying the details of meaningful use for me and you. A few such comments were made on my years for meaningful use post. I thought they were worth sharing since I know that many of you don’t go back and read the great comments people make on my posts (I’ll forgive you for now).

Lynn Scheps from SRSsoft wrote the following comment about a benefit to not showing meaningful use in 2011 and electing to wait until 2012. It’s a way to maximize your incentive money. Although, you will need to implement your EHR quickly to maximize them. Here’s Lynn’s comment:

There is an additional benefit to electing 2012, instead of 2011, as an EP’s first EHR incentive payment year (an unintended consequence of the legislation, no doubt!) In that case an EP can still collect the ePrescribing (1%) bonus for 2011, while potentially qualifying for the maximum ($44K) in EHR incentives. An EP cannot collect under both MIPPA (ePrescribing) and ARRA (EHR incentives) during the same reporting period.

There was also some discussion on the idea of skipping a year of meaningful use and the impact of such a choice. Lynn offers the following comments in response to skipping a year of meaningful use.

In response to Wes Kemp’s comment about the 90-day reporting period and the consequences of skipping years, note that the rules differ under Medicare and Medicaid. Under Medicare, 90 days is sufficient for an EPs FIRST PAYMENT YEAR, regardless of what calendar year that is. For all subsequent payment years, the EP must report on the full year. After the first payment is received by the EP, every year is considered a payment year, whether or not an incentive is earned. So, while an EP can skip a year, he/she forfits the money for that year. Payment amounts are governed by the year in which they are received, not by what year it is for the EP. (p. 44319 of Final Rule.)

Wes Kemp also offered some insights on the Medicaid program and its requirements for meaningful use, attestation and it highlights some interesting differences between the Medicaid and Medicare EMR stimulus (I’ll admit that I don’t know as much about the Medicaid side):

Yes, requirements are more relaxed under Medicaid, than Medicare for MU incentives. My posts relate to MediCAID, since that is my current client’s need. So, with that in mind:

Yes, John, under MediCAID, an EP can attest and then apply for the funds the very next day – no reporting period / requirements in first year. 90 consecutive days reporting in year 2 is required, and full-year reporting for all subsequent participation years.

For subsequent years, the targets are clear enough that EPs will be aware of whether or not they have complied just by reading the data before submitting it. The measures are listed, from which a certain number are selected to report. The denominator / numerator are clearly defined…as are the % targets for each measure. So an EP is able to monitor and strive to achieve the required % of encounters counseled about smoking, for example.

Indeed there are items still to be defined. Optometrists are not specifically included as EPs under the MediCAID MU rules – however, I have been told more than once by ONC that for FQHCs they will be, this is not yet written anywhere that I am aware of. Also, for larger clinics, tracking all the MU measures by EP will require significant effort; especially if EPs come & go during the reporting year.

I think I might invite smart people like Lynn and Wes to do a regular post talking about more details of meaningful use. There’s so many questions still out there about meaningful use. Some we know the answer to, but there’s a lot of things we still don’t understand. Hopefully together we can share what we learn about meaningful use and the EMR stimulus.

This weekend I was thinking about some of the unconventional EMR software that exists out there. One that came to mind was SRSsoft and its hybrid EMR which from what I can tell mixes document management with some of the other essential EMR features like ePrescribing. What other EMR vendors do things like this in their EMR software?

I think another example of this is the XLEMR which is built on top of the Microsoft Office software package. Definitely a unique way to address the issue of EMR.

This is just a few examples to get you thinking. I’m sure there are many more!

Do you know of other EMR vendors that offer similar EMR packages to those listed above? Or do you know of other EMR software that takes an unconventional approach to EMR use? If you know of one or represent an EMR that is unconventional I’d love to hear about it.

I should also mention that I’m not necessarily saying that unconventional is a good or a bad thing. Although, I will say that the unconventional approaches can often teach us a lot. Let’s hear what you’ve seen that’s unique out there.

I’m always interested in the reactions of EMR vendors to various news. Granted, much of it is very predictable. They obviously want to sell more EMR software and so their reaction is usually a positive one when we’re talking about billions of dollars of stimulus money.

This is why I was so interested in hearing Evan Steele, CEO of SRSsoft’s response to the final meaningful use rule. Evan has been a strong proponent of maintaining the productivity of the practice and no doubt government regulations like meaningful use can stand in the way of that goal. The following is Evan’s response to the meaningful use final rule:

While the final rule on meaningful use contained some changes from the proposed rule, these modifications are only deferrals, not permanent changes. Everything that was taken out of the proposed rule will be added back in, according to Farzad Mostashari, and the flexibility granted for Stage 1 will be removed in Stage 2, just two short years away. The bottom line for physicians has not changed:

• Compliance with meaningful use will result in a significant decrease in productivity because the demands on physicians are still onerous and because it requires use of an EMR that is data-driven (traditional, point-and-click EMR) rather than workflow/productivity-driven (like the SRS hybrid EMR).
• The meaningful use measures are still not particularly relevant to specialists, as HIT Policy Committee member Gayle Harrell pointed out during the recent committee meeting.
• Participation in the government program is voluntary, as David Blumenthal made clear during the press conference announcing the release of the final rule. Physicians can choose to follow the compliance path or they can elect to pursue the productivity path.

SRS remains committed to physician and practice productivity and will continue to focus our development resources on our flagship product—the unique, productivity-enhancing hybrid EMR. Most high-performance specialists recognize that the cost of complying with meaningful use far outweighs any incentives that might possibly be earned or any penalties that might be imposed.

As you referenced in a recent post, SRS has entered into an alliance that will ensure that physicians have all the options they need. With SRS, they can reap the significant benefits of the productivity path, with the assurance that if at some point in the future they decide to pursue meaningful use, they will be able to do so as clients of SRS.

Looks like Evan is still preaching the EMR productivity message, but there’s a small sliver of hope for meaningful use with SRSsoft. I’m pretty sure every EMR salesperson is going to be so tired of hearing about meaningful use that Every EMR vendor will need a solid meaningful use strategy. Meaningful Use is here to stay. At least until the EMR stimulus money runs out.

The latest flu bug that’s been going around has hit me pretty hard. I’ll be back tomorrow (assuming all goes well) with more posts.

Until then, some interesting news items for you to consider:
SOAPware Announces Release of PMS – They’ve been working on this for a while. Plus, it’s interesting to see the pure EMR companies getting a PMS. Check out this interview I did previously with the SOAPware president.

SRS and Ingenix Collaborate to Deliver PMS and EHR – Another case of an EMR partnering with a PMS system. Plus, now SRSsoft can get to meaningful use. As expected, EVERY EMR vendor is likely going to need to be able to say, “Our EMR can show meaningful use.”

Back in April, Evan Steele, CEO of SRSsoft, wrote an interesting post about EMR adoption and he asked the question, “Why Are You Still on the Fence?” It’s a very good question. Plus, he adds some value to the conversation by listing some of the problems with paper charts versus an EMR. Here’s a section of his post:

So why are these physicians, who have determined that government incentives are not relevant or achievable, still on the fence about adopting an EMR solution that will deliver measurable benefits? Staying with paper charts is not a good business strategy because there is nothing more inefficient!

• The costs associated with the excess staff needed to manage these medical records are massive and wasteful—these positions can be eliminated or the employees can be more effectively used in revenue-generating or patient-care roles.
• Paper charts hinder practice growth because adding physicians requires a proportional increase in support staff—medical records, billing, nurses, and medical assistants—and because physicians can’t see more patients without lengthening their work hours.
• Slow responsiveness to primary care physicians limits referral volume.
• Profitability is further affected by billing bottlenecks that delay revenue collection.
• The chaos associated with trying to manage paper charts has a damaging effect on staff morale and creates rampant frustration among patients, physicians, and staff.
• Paper charts are a malpractice nightmare—prescriptions are not consistently documented, orders are not easily tracked, and medical decisions are often made without complete clinical information.

So, why are doctors on the fence with EMR? The sad thing for me was the pre-EMR stimulus money, I felt a shift in the tone of conversation around EMR adoption. Doctors had mostly moved from wondering if they should implement an EMR to how they should implement an EMR and which EMR they should implement. They were off of the fence and I saw the tide shifting.

And then in one anti-stimulative swoop, the HITECH act rolled out and doctors decided to go back to the sidelines and see this government incentive play out. Now they’re waiting for meaningful use to be defined. While the HITECH act has increased EMR awareness 10 fold, it’s also done much damage on the short term EMR adoption. I’m not sure that the increased awareness will overcome the damage that it’s caused.

Of course, the damage is done and so we have to go forward from here. I suggest we go back to pre-EMR stimulus times and focus more effort back on the benefits of EMR and the costs of paper instead of the government handouts. If we do that, we’ll see a fantastic shift to more widespread EMR adoption.

I must admit that one person that I was very excited to meet at HIMSS was Evan Steele, the CEO of SRSsoft. Evan and I had interacted a number of times online. Plus, I love an EMR vendor CEO that has a blog. Not just any blog, but one that broadens the discussion about EMR software and provides an alternate view to EMR adoption.

Turns out that many people at HIMSS don’t like the hybrid EMR style of software that Evan Steele and SRSsoft are trying to create. There is certainly an argument to be made against it, but personally I like to see people approaching the challenge of clinical documentation in different ways. I also love how SRSsoft focuses so much effort and energy on the physician. If more EMR vendors had this focused, we’d have much better EMR software.

Now this kind of sounds like a sales pitch for SRSsoft. It’s not. SRSsoft has its flaws and weakness like every other EMR software out there. I do think that they’ve done a good job broadening the discussion so I knew for sure that I had to talk with Evan Steele on video. In this video, he makes a really interesting point about CCHIT certification, now HHS certification, the new ICD 10, etc all working to make many EMR vendor’s software clunky (my word, not his).

Enough talk, check out my interview with Evan Steele, CEO of SRSsoft.

I should also mention that Evan and I were on a Meet the Bloggers panel together. That was a good time too.