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Meaningful Use Mondays – 90 Day Reporting Period

Posted on January 31, 2011 I Written By

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

I receive many questions about the 90-day reporting period and skepticism about whether the provision applies to years beyond 2011. To clarify: The reporting period is 90 days as long as it is the first payment year for that particular provider—whether that year is 2011, 2012, 2013, or even 2014.

People frequently ask me for documentation of the above, so I am providing it here.

The following citations are from the Final Rule in the Federal Register:

  • “We are finalizing the 90-day reporting period for the first payment year based on meaningful use as proposed for Medicare EPs, eligible hospitals and CAHs and full year EHR reporting periods for subsequent payment years.” – page 44320.
  • “The first payment year for EPs is any calendar year (CY) beginning with CY 2011 and for eligible hospitals and CAHs is any fiscal year (FY) beginning with 2011.” – page 44318.

The ARRA legislation also defines the first payment year and relates it to the specific provider: “the first year for which an incentive payment is made with respect to professional services furnished by an eligible professional. The terms ‘second payment year’, ‘third payment year’, etc. refer to each successive year immediately following the first payment year for such professional.” – Section 4101(a)(o)(1)(E) – page 355.

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.

The Meaningful Use Sky is Falling

Posted on January 28, 2011 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.

The always opinionated Anthony Guerra has an article up on Information Week that describes why he thinks the Meaningful Use sky is falling. Add that to a recent comment I got on a previous post that links to a Healthcare Data Management article talking about the potential repeal of the HITECH act and it seems worthwhile to assess the state of meaningful use.

I’ll start with the potential repeal of meaningful use first. We’ve known for a long time that the house was going to be going after healthcare reform once the republicans took over control of the house. In fact, we posted about the potential impacts to HITECH from the new Congress before.

I personally get the feeling that not much has changed on this front. I’m going to reach out to some of the government liasons for EHR vendors that I know that follow this even closer than I do. However, I still believe that:
1. The HITECH funding or at least the Medicare and Medicaid stimulus funding is safe from Congress. I’ve read this a couple of places and so I believe it to be true.
2. Any legislation that is passed by the house still has to pass through the democratic controlled Congress and avoid the Presidential veto. These two seem unlikely.

Of course, when it’s government work you could always be surprised by some loophole in the process that impacts funding or legislation. I won’t be surprised if one of these loop holes appears and affects the HITECH act. However, I still argue that if something does happen to HITECH, it will likely be a casualty of some other political agenda (ie. cutting whatever costs they can find) and not actually because they were specifically targeting HITECH.

Long story short: I still feel like the EHR incentive portion of HITECH is likely safe. Maybe some of the other funding will be cut short. We’ll see.

Now to the points that Anthony Guerra makes in his article. He describes the challenges that many hospitals are facing in regards to meaningful use. Plus he highlights the potential difference in the number of people who “think they qualify for the money” and those who “plan to apply.”

I might argue that if EHR adoption is the goal, then this might not be such a bad result. The idea of “forcing” meaningful use on people has always bothered me a little bit. Encouraging people to show meaningful use is only as good as the meaningful use criteria. If the meaningful use criteria is not very good, then do we really want everyone showing meaningful use?

For example, imagine that a doctor or hospital decides to use an EHR based on the EHR software’s ability to improve the efficiency of their office and the quality of the services they provide to the patient, but deems meaningful use as contrary to those goals. This seems like a great outcome to me. In fact, it seems like a better outcome than a doctor trying to force themselves into the meaningful use hole.

Obviously there are parts of meaningful use that can be very beneficial. For example, having an EMR that can communicate using a standard format (CCD for example) is important and valuable. If it is beneficial, then I see most doctors implementing these features regardless of whether they showed meaningful use or not.

One thing definitely seems clear from all the surveys and other stats I have: interest in EMR has never been higher. Whether that translates to “meaningful use” of a “certified EHR” or physicians meaningfully using an EHR of their choice, is fine with me.

You know my mantra: Select and implement an EMR based on the benefits that you and your clinic want to receive from the EMR. Don’t select and implement it based on a government handout. Those hand outs will be gone after a few years, but your EMR will be with you long after.

RECs Get More Funding…Or Something Like That

Posted on January 27, 2011 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 many of you know, I’ve never been a huge fan of most of the RECs even if I believe that RECs could be a great force for good. I am a huge fan of some of the incredibly smart people I’ve met that work at the RECs. However, some of the actions of RECs make me cringe.

Not the least of which is the “preferred EHR vendor” approach that many (thankfully not all) of the RECs have taken. I realize the challenge for a REC to have to support many different EHR vendors, but I hate having my tax dollars spent to support a small list of EHR vendors. Especially considering many of the suspicious (and possibly dishonest) and terrible REC EHR vendor selection processes that have occurred.

Leaving that part of it aside, I’ve always wondered how RECs were going to be successful considering the REC funding model. I heard one person in the EMR industry tell me point blank that ONC expected all of the RECs to pretty much fail and not reach the next funding milestone. He suggested that ONC was just hoping that some best practices could come out of the RECs from the funding. I’m not sure I fully agreed with this person’s comments, but I did agree that the milestones that were required by RECs to reach the next funding milestones were nearly impossible to achieve.

Turns out, ONC must have seen the same thing, because today Dr. David Blumenthal announced new funding for RECs:

For the RECs, we are providing additional funding of $32 million. This especially reflects our plan to accelerate outreach to health care providers to encourage registration for the CMS Incentive Programs and to provide more support in the field as providers adopt health information technology in their practices. We recognize that the early transition to HIT can be challenging and we want to make sure that our RECs are fully operational to help make this transition as smooth as possible. We are committed to offer substantial ongoing support to achieve meaningful use through the RECs.

Also interesting to note is that Dr. Blumenthal said that the 62 RECs have enrolled 38,000 providers interested in RECs assistance. Of course, there goal for the RECs is 100,000 providers. Still quite a ways to go.

What I find really interesting is that Blumenthal stated above that their providing $32 million in additional funding for the RECs. In a LinkedIn discussion on the announcement the following was clarified:

The ONC did not change the amount of funding the RECs receive; it is the same amount they were initially awarded. The funding was always for 4 years as well. What changed is the “cost share” proportions. Initially, in the first two years, the ONC would pay $9 and for every $1 contributed by the RECs and it would flip in years 3 & 4 (so RECs would contribute $9 for every $1 received by the ONC). What changed is that now for all 4 years, the ONC will contribute $9 and the RECs $1. It is a huge relief for RECs as many of them were worried about how they were going to match in the last two years.

The statement above [Feds to Better Fund RECs] is misleading because the feds are not increasing the total amount of funding available to RECs, they are just alleviating the pressure of the increased cost share in the later years.

I’ll let you weed through the possible inconsistencies in those two viewpoints. At the end of the day, it doesn’t really matter all that much to most of us. What matters is that RECs are in a much better position thanks to these changes to their government funding. Of course, after the four years, it will be interesting to see which of the RECs survive and what business model they’ll use to achieve it.

It’s also worth noting that the clinic that received the first EHR stimulus checks were helped by their local REC. I wonder how many others are using the RECs as well.

EMR and HIPAA Reader Feedback

Posted on January 26, 2011 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 meaning to do a survey of my readers for a long time now. Today I finally decided to make it happen. No doubt many of you have provided feedback to me in the comments and by email, but I thought that a simple 12 question anonymous survey would be a great way to solicit more feedback from the readers of EMR and HIPAA.

I’m sincerely interested in seeing your responses on how I can make EMR and HIPAA better. So I appreciate you taking the time to fill out the survey. No questions are required so just answer the ones you feel comfortable with.

The survey is embedded below, but if you’re getting this by email then here’s a link to fill out the EMR and HIPAA Survey.

Study Ignores Other Benefits of Electronic Health Records

Posted on January 25, 2011 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 now had two people send me links to a study coming out of Stanford University that says that EHR software doesn’t improve patient care in the US (Here’s one story about it from Reuters). So I figure that it must be a topic that my readers would enjoy me discussing. Here’s a portion of their summary:

A team from Stanford University in California analyzed nationwide survey data from more than 250,000 visits to physicians’ offices and other outpatient settings between 2005 and 2007.

They found electronic health records did little to improve quality, even when there was “decision support” software that gives doctors tips on how best to treat individual patients.

I’ve always found it a bit off to talk about EMR software as a means to improve the quality of care that a doctor provides. For the vast majority of healthcare, more information, clinical decision support, drug to drug interaction checking, drug to allergy checking, etc aren’t going to improve the care a doctor provides. First, because the doctors have been well trained to do many of these things already. Second, because if I come in as a generally healthy patient with a common cold, then of course the doctor doesn’t need any of these advanced EMR functionality.

Now in more advanced and complicated cases, there is potential that an EMR software could offer some benefit. I remember a doctor commenting back in 2009 on my blog about how the Body of Medical Knowledge could become to complex for the human mind to process it all. Whether we’re there or yet, is open for debate, but the concept is interesting. Although, this still only applies to the outlier cases.

I remember one time hearing a clinician tell me about how the Drug to Drug interaction alerts informed her of some medical knowledge that she hadn’t known previously. So, there are instances where various parts of an EMR software can provide better patient care, but is it dramatic enough difference to really improve the quality of care? I think that’s a hard argument to really make. At least with the current iteration of EMR software.

Other EMR Benefits
Quality of Care aside, I think the thing that studies like this (and their related headlines) miss is the other benefits of having an EMR system (see also my list of EMR benefits in my EMR Selection e-Book).

I can’t tell you how many times I’ve heard doctors talk about how they love the legibility and accessibility of patient charts in the EMR. No difficult to read handwriting (others or their own). No waiting for chart pulls. These are guaranteed benefits to having an EMR system. Sure, it’s hard to quantify them when it comes to dollar signs or improved quality of care. However, they’re a real tangible benefit to having an EMR. Not to mention that I still think there’s long term benefits to widespread adoption of EMR that we can’t even imagine yet.

I could go on about many of the other benefits. It’s just unfortunate that studies and those who report on these studies don’t take into account these other benefits of EMR software.

UPDATE: Over at HIStalk, Mr. H also points out that the study only focuses on a couple quality measures. So, it doesn’t actually say that EHR doesn’t improve quality of care, but instead it says that it doesn’t improve quality of care when it comes to the couple simple measures that the study used to measure it. There could be many other quality measures where EHR does improve the quality of care. We just don’t know.

Meaningful Use Mondays – What’s a Patient for Meaningful Use Reporting?

Posted on January 24, 2011 I Written By

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

To successfully demonstrate meaningful use, providers must report on all patients, regardless of payer.

The government describes the program as “payer-neutral” as it applies to patients. Even though providers elect to pursue incentives under either Medicare or Medicaid, they must meaningfully use their EHR in the same manner, and report the same data, for their entire patient population—private and self-pay patients, as well as those who are government-insured. While the descriptions of many of the meaningful use measures define their respective numerators and denominators as a subset of the provider’s patients, these distinctions are based on factors totally independent of payer status.

It is interesting that the government can impose requirements related to patients for whom it is not paying the bills. This says something about the broader purpose behind the legislation.

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.

What could replace E&M coding to improve healthcare (and EMR)?

Posted on January 21, 2011 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.

A comment on my somewhat controversial thought post about imagining an EMR without billing reminded me that I wanted to ask the question of my readers about what could replace E&M coding. Seriously, I can’t think of anyone I know that actually likes E&M coding. I know some people that are good at it and so they like that they have a skill in that area. However, I don’t remember anyone being a proponent of E&M coding because it provides better patient care or makes life easier for doctors. Am I just missing these reports? So, this leads to the important question…

What could replace E&M coding that would improve healthcare and still handle billing?

Plus, after you read the comment below, you’ll understand why improving billing could also improve many of the billing machines EMR software that’s out there as well. Let’s hear your thoughts.

Here’s the comment that prompted this thought:

The broader problem is that the billing aspects have many more insidiously negative effects than simply sending a charge transaction across an interface.

They actually degrade the quality of the documentation by requiring certain elements to support specific levels of billing. The whole issue of needing to have a certain number of elements done and documented to bill a particular E&M code is one example. A particular visit may have extremely complex history/assessment/decision-making but to get “credit” one also has to document a certain number of irrelevant review of systems items.

It is no surprise that the places that have used EHRs most effectively such as Kaiser and the VA are incentivized to give care that will produce better outcomes. They are less beholden to bureaucratic insurer-driven documentation demands that do not aid in patient care or communication.

Eliminating all of these items (and similar demands for information to fulfill PQRI and other measures that are irrelevant to a particular patient or that fragment thought processes) would improve workflow and efficiency in any system, paper or electronic. It would certainly make it easier to develop an EMR that would support patient care needs.

But just having distinct EMR and billing software isn’t going to do the trick in our current dysfunctional health care system. It is only if an EMR can be designed (and insurer/payor/regulatory demands can be synchronized) so that the health care system looks like a single payer system to the EHR user and clinicians can go about the business of treating patients.

It’s a little bit pie in the sky thinking, but sometimes that’s beneficial.

Imagine If the Car Industry Had HITECH

Posted on January 20, 2011 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.

The following is an interesting comment that’s kind of an extension to my previous post about a visit to an EMR using Doctor’s office. I think many of you will enjoy it.

Can you imagine this in a manufacturing environment? If GM, Ford, etc were legislated (incented?) to implement automation and safety changes that caused them to cut production in half…and cause the workers to be a bit distracted from what they were doing on the other 50% (then maybe tax them higher if they don’t put the changes in place within 3 years)….how healthy would that be for GM? And for the cost and quality of the cars being built?

Of course, not all EMR software causes you to cut production in half. EMR also doesn’t have to mean you’re distracted the other 50% of the time. Take a look at this post by Dr. Koriwchak that talks about some of the principles he used in his EMR implementation. My favorite comment he made was that he “rejected the notion that we would have to decrease patient volume and lose revenue, even temporarily, to get EMR implemented.”

So, if you see the HITECH act / EMR Stimulus money incentivizing what’s described above, then maybe….just maybe…you’re looking at the wrong EMR software.

EMR Companies Holding Practice Data for “Ransom”

Posted on January 19, 2011 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.

UPDATE: JamesNT sent me an update to his comments in this post. It’s interesting to see the EHR vendors’ evolution on the question of openness.

JamesNT wrote a really interesting forum post recently about how a number of EMR vendors are holding doctor’s patient information “ransom” (his word) from them. Here’s his whole description and he even names a few EMR vendors and the challenges related to getting the EMR data out of their systems:

To many EMR’s lock up the practice’s data and hold it for ransom. The data entered into an EMR belongs to the practice, not the EMR. It is not fair for EMR’s to not provide ways to interface or export data from the database. If a doctor wants to hire an IT person or developer such as myself to write custom reports or export data from the EMR, then it should be possible. Consider the following examples:

Amazing Charts: They use SQL Server 2005 Express as their database but they remove the built-in Administrator account from the SQL instance and change the SQL Server SA password. This means anyone hoping to interface or export data is at a loss – and Amazing Charts will not share the SA password. Amazing Charts also does not publish a database diagram.

eClinicalWorks: Overly complicated database. Does not publish mySQL password (you can find it, though). Does not publish database schema. If you ask them for help, they want to charge $5000 to build an interface.

PODMED (now TrakNet): Kudos for sharing the SQL Server SA password – but does not offer a published database schema.

GE Centricity: Database schema available – if you are willing to tell a bold-faced lie to someone to get it.

Medinotes: Even after sunsetting the product, Allscripts refuses to give out the ODBC driver and database password.

MD Logic: Uses a pathetic HL7 file interface. You can place only one patient demographic in each file – so if you have 200 patients to update that means sending 200 files.

Officemate: Uses SQL Server and it is easy to get to their database – but they do not offer the schema.

I find this situation deplorable. Every EMR should make it easy to get to the data and not try to hide it or charge outrageous amounts for an interface. Seriously – who here would pay $5000 to make an interface?

Of course, he’s just highlighting the EMR software he’s used. I’m sure there are hundreds more EMR vendors like this.

Then, there’s also EMR vendors that don’t hold your EMR data for ransom like Medtuity. Here’s what Matt Chase from Medtuity said about what they provide to users of their EMR:

At Medtuity, we provide open access to the SQL database. We also provide an export facility under Options. You can export each and every encounter, years and years worth if you wish, to a PDF file for each visit, neatly labeled with the date of the encounter and pt’s name to keep it from colliding with other PDF documents. You can also export a CCR for each pt.

We also have our own proprietary format in XML. For a group with a huge number of records, they may wish to hire a consultant to write a program to consume that xml into a new system. Our xml format is most complete and includes the stuff you would not usually wish to transfer (the audit trail on that chart, for example). But it is there. We also have CSV format, but let’s face it, you cannot export sophisticated data in a CSV format. It’s fine for demographics.

How “liquid” is the data in your EMR software? This discussion is a very important one between you and your EMR vendor when you’re selecting an EMR. Make it part of your EMR contract.

More EMR vendors need to voluntarily step up to the plate and provide this type of EMR data liquidity.

HIMSS 11 New Media Meetup – Sponsored by MEDecision

Posted on January 18, 2011 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.

REGISTER NOW!!

I’m really excited to announce the second annual New Media Meetup at HIMSS 2011. Last year’s event was pretty amazing in Atlanta and I expect this year’s will be just as good and with a whole bunch of interesting new and old faces. It’s one of the most interesting networking events that I did at HIMSS.

Everyone is welcome at the event. Maybe you participate in New Media (Blogger, Tweeter, LinkedIn, Facebook, etc) or maybe you just enjoy consuming other people’s media (like this blog) or maybe you’re interested in using New Media for yourself or your company. Everyone is welcome to attend and network with others interested in New Media.

If that isn’t enough reason to attend, I’m really happy to have teamed up with MEDecision again this year to sponsor the New Media Meetup at HIMSS Orlando. They’ll be fully catering the event (Translation: Free FOOD) which if it’s anything like last year, you won’t be disappointed at ALL! Not to mention, they’ll be providing an enclosed area in their swanky booth on the main aisle of the exhibition floor for the event.

Ok, now to the gory details. The event will be on Tuesday 2/22 4:30-6:00 PM in Booth 2563 (MEDecision booth). It’s right at the end of the day on Tuesday before you head out to all the other night parties. Grab a bite to eat and meet some really great people.

UPDATE: Thanks to the good people at Ozmosis, we’ll be giving away an iPad at the event. Plus, along with providing all the food and drink, MEDecision has offered up a bunch of FLIP video cameras to giveaway.

REGISTER NOW!!

Please register for the event so we know how many to expect. At some point we may have to close registrations since their booth can only hold so many, so register now and come join the fun.

Be sure to tell all your Blogger, Twitter and other new media friends about the event. The more people you invite, the better the event will become. I look forward to meeting you all!

About Sponsors
MEDecision offers collaborative healthcare management solutions that provide a simple and smart way for payers and providers to harness the power of knowledge to enable the best clinical decisions and improve health outcomes. Designed around a patient-aware health management philosophy, MEDecision’s solutions include Alineo, Nexalign, and InFrame. You can find them at HIMSS in Booth 2563.

Ozmosis provides a social powered knowledge management solution to healthcare enterprises. It’s flagship platform, OzmosisESP, enables clinicians, administrators, staff and researchers at hospitals and health systems to collaboratively develop, manage, and share knowledge within a fully integrated and indexed repository of clinical content and user expertise.

We’re still looking for additional sponsors who would like to provide some other Giveaways at the HIMSS 2011 New Media Meetup. Drop us a line on our Contact Us page if you’re interested.