Choosing the Right EHR Vendor for Your Practice
Robert Redling | Source: Physician's Practice | August 8, 2011
So your practice has decided to finally take the plunge and get an electronic health record. But with more than 300 software vendors to choose from, chances are you're racking your brain about what to do next.
Here's your guide to asking the right questions, to make sure you pick the EHR that's right for you. These are only a few of the many questions to ask an EHR vendor, but they touch on the critical information you should know as you embark on your technology shopping expedition.
Shared Vision
What does it take to pick the right EHR? Savvy purchasers — those with years of experience with various technologies from multiple vendors — say it's a bit like choosing a life partner, as opposed to a dream date: go for shared goals and long-term compatibility instead of looks.
The federal government's meaningful use criteria, part of the EHR incentive program, may lead to more similarities than differences between EHR systems, but choosing the right system has not gotten any easier. Now, as always, finding the right system means finding the right vendor.
For Gina Tucker, a practice manager in Northampton, Mass., getting the right vendor meant taking a chance. In 2001, the five-physician practice she manages, Hampshire Obstetrical and Gynecological Associates, Inc., opted for an integrated EHR and practice management system. The vendor was new on the scene and still developing its product line, but the bet paid off, she says. Not only has that vendor grown into a top-10 player in physician EHR systems, but it continues to deliver the high levels of service and support that Tucker gambled it would.
Looking back, Tucker says it wasn't an entirely risky bet; in large part due to the method her practice used to select its EHR. Because the software for electronic medical records was still a work in progress a decade ago — much more so than today — Tucker and her practice's selection team looked as carefully at potential vendors' market strategies, as it did their products.
"We didn't go to software vendors and say 'here's what we want to fix,' but rather (we said), 'our goals are thorough documentation and staying on top of everything we need to so we can provide good patient care, be efficient, and keep improving,'" Tucker says. "We felt the company we chose was on the same path as we were to improvement."
Tucker says to look beyond a vendor's statements about being the best in the business, best in breed, and other similarly inflated phraseology. Instead, look at how much it invests in research and development of new products. Ask whether its product-development team includes seasoned pros with success in developing information technology for physician medical practices and similar environments.
"You want to feel that they understand your business," she says. "It's a feeling that you have a melding of philosophies, which goes well beyond any statements that a salesperson can make."
Scoping out vendors: a checklist
There are many questions you should ask vendors and other users to figure out what the right system — and vendor — is for you. Here's what Tucker suggests asking:
Questions to ask the vendor:
- How many practices use your system nationwide?
- What are the specialties and sizes (in number of physicians, not full-time equivalents) of practices using your system?
- How many users have switched to other systems and why?
- Are any physicians involved on a day-to-day basis in your research and development, implementation strategies, design, or other key areas?
- How does your company integrate ideas submitted by end users?
Next, here are questions to ask other users of the product (ask your vendor for references):
- Do you feel the vendor and its staff understand medical practice business and clinical challenges?
- Is it easy to reach someone from the company on the telephone?
- What is the number one reason you chose the system?
Train to perfection
Qualifying for the federal government's full complement of EHR Stage 1 meaningful use incentives might cover much of a new system's cost. Or it might not. It's all too tempting to cut corners on training costs to lower the acquisition cost of a new system. Don't do it, says technology consultant Rosemarie Nelson, with the Medical Group Management Association's Healthcare Consulting Group.
The train-the-trainer approach is necessary to build a core of in-house experts, but don't expect that a few people on your staff can adequately train the many others who need the knowledge, too, she says.
"There's way too much to absorb in a new EHR for one or two people to quickly get the big picture and be able to transmit that to everyone in the practice who needs the knowledge, which is pretty much everyone in the practice," Nelson says.
Make sure there is enough money in the proposal for the vendor to train several employees, she says.
"My recommendation is to listen to the vendor's recommended schedule of training and don't try to shortcut it," Nelson adds.
There's no argument from Anna Randall about the role of training in a successful EHR implementation. She worked with several EHRs and managed implementations at other practices before becoming practice administrator of Middle Georgia OB/GYN, in Warner Robins, Ga., seven years ago.
"The best investment you can make after determining what EMR to buy is the training hours," Randall says. "It will help you create a better form and learn the little tricks that make using the system much less time consuming for providers."
Recently, Middle Georgia OB/GYN opted to replace its EHR with one from a different company. Implementation of the new system went better than expected: The practice's two physicians didn't skip a beat, seeing their usual combined daily workload of 48 patients and entering every bit of necessary documentation into the record on that first day. Randall says Advance training made it possible for Middle Georgia OB/GYN to avoid the physician productivity dip so common in the first few days to months after a practice takes its EHR live.
Randall says that in the weeks leading up to the EHR go-live date, she created a group of administrative users and set up a separate training area for them to use a few hours a day. Next, the head of each department received a half-day of training. Then the physicians were trained one-on-one by the vendor.
Scoping out the training: a checklist
Picking an EHR is often easier than training staff to use it. So when you're shopping around for your EHR, Randall suggests asking a vendor the following questions about training:
- Will you give us a written estimate of the number of hours of training we will need?
- Will you observe a typical patient visit to determine the intensity of training we will need?
- Will you create a training-skills checklist designed specifically for our practice?
- Do you take into account each provider's previous computer experience?
- Do your training suggestions also account for our practice's size, specialty, and its existing information technology?
- Do we have choices in Web-based, onsite, and off-site training?
- Will you provide one-on-one training for the physicians, either via the Web or in person?
- Can you offer training (via Web or in person) during or after our office hours?
When calling other users who have installed the EHR, be sure to ask:
- How many providers were trained by the vendor?
- How many of your staff needed to be trained?
- What was your impression of the content of the training materials and the quality of the vendor's training, including the individuals conducting the training sessions?
- Was the Web-based training offered live or was it in the form of pre-recorded tutorials?
- What is the quality and flexibility of the training modules the vendor provides for the practice to train new employees?
Support counts
Vendor support seems to the area of an EHR purchase that brings the most mystery and, sometimes, the greatest number of complaints. Tucker says support was an area of concern when her practice made the leap into an integrated EHR and practice management system.
"It's not just 'can I get a hold of somebody on the vendor's support line,' but will they know about our software and understand the types of things a medical practice will be asking them about," she says.
Nelson adds that technical support is important enough to include in a purchasing contract. Spell out the expected response times and, perhaps, penalties for poor or late response ? such as discounts on technical support, staff training, or other considerations. An additional protection for the purchaser is for the contract to spell out how the penalties would escalate if the vendor's support remains less than promised.
"Support is really instrumental in what will make you happy as a customer," Nelson says. "Trying to gauge support is something I would be asking of the vendor's references, but also what I'd ask of the users I found through professional societies, online user forums, or other ways."
Another support snafu Nelson often sees is when hardware and software from different vendors fail to mesh as promised with the new system. While technology mismatches can be costly, a lot can be done in advance to prevent the finger pointing that slows down the search for solutions.
She suggests setting up a conference call with the EHR vendor, software and hardware suppliers, and your information technology support staff or contractors. Let them hammer out details, such as the right type of PCs, the proper wired or wireless network configuration and so on. Otherwise, the practice administrator is left playing middleman, she says.
"Before the purchase, you should be able to speak with the person who will be handling your support," Nelson says. "Ask questions that will give you a sense of what kind of people this vendor is hiring to support you."
Nelson suggests that you approach conversations with support staff as if you were interviewing them for a job in your practice. Questions to ask might include:
- What do you feel are your greatest strengths in helping clients?
- How did you learn to operate this system?
- What other experience do you have in this technology?
- What is your background in healthcare?
- Have you ever worked with medical practices?
Nelson says you can avoid disappointments with the support you'll get by asking vendors:
- Do you offer live support during my practice's usual daytime work hours?
- What is your turnaround time for returning customer calls?
- Are your support telephones answered by operators who take messages, or will your technical staff be immediately available when I call with a problem?
- How long does it take to get a response when a question needs a more senior person to respond?
- Is there a way to ask non-urgent questions via the Web?
- What percentage of customer questions is answered within the first 15 minutes?
- Describe the process your implementation staff will follow to hand my account over to your telephone support group?
Finally, when calling references or other users, ask these questions about the vendor's support:
- How quickly do you get a response?
- How long does it take to resolve problems?
- How hard is it to get someone from support on the telephone?
- When you have a problem with the vendor's system interacting with another company's software or hardware, do they cooperate to help you find a solution or do you feel abandoned?
- Are management and staff satisfied with vendor problem solving?
- What is the name(s) of your "go-to" support technician? What is the name of the best trainer?
- Who do you call when you can't get the resolution you need?
In the long run, though, finding the best EHR software is a matter of finding the best company, and that's not easy. It took Randall nearly three years to find that perfect partner for Middle Georgia OB GYN.
Says Randall: "I looked at the financial backing of the company to see if they are going to be around for the long haul but also if they were putting money into research and development so they can give us new tools down the road."
Oops, You're Violating HIPAA and Didn't Even Know It
By Ericka L. Adler | Source: Physician's Practice | August 31, 2011
From time to time I visit physician offices, whether for client meetings, appointments as a patient, or even just to accompany another family member. I usually cannot help myself from evaluating the practice from the perspective of a visitor and am often surprised at what I see, specifically with regard to patient privacy and HIPAA concerns. Consider the following:
1. At one office I was greeted by a beautiful bulletin board that welcomed new patients to the practice, identifying the patient by the patient’s full name and town. Patient names and addresses are protected health information under HIPAA and may not be shared in this manner without authorization from the patient.
2. In most doctor offices I have visited, patients are called up in the waiting room by their full names in front of everyone. Using first or last names only is recommended. In smaller offices, approaching the patient directly is preferable.
3. The check-in process for patients also leaves much to be desired in terms of privacy. Consider this fairly common interaction at my doctor’s office:
Staff: What’s your birthday?
Me: March 5, 1990 (I wish)
Staff: Is your name Ericka Adler?
Me: Yes
Staff: Is your address still ___________?
Me: Yes
Staff: Are you still with Blue Cross Blue Shield?
Me: Yes
In this one conversation, overheard by everyone, information is revealed that is protected health information under HIPAA and which could be used for identity theft. This is an interaction that is unnecessary and inappropriate. Patients should be spaced out so they cannot be overheard with the reception staff. In addition, the amount of information reviewed verbally should be minimized. Consider simply asking if anything has changed or request the patient review private information on a computer screen to confirm its accuracy.
4. I cannot tell you the number of times I have been left in a room waiting for a physician with another patient’s chart sitting on the desk or otherwise readily accessible. Likewise, standing at receptionists’ desks, I see charts in plan view which identify a patient’s name, address and other information without the need to even open the chart.
5. I brought my daughter to a practice for a procedure and in the procedure room was a large mounted screen which identified the scheduled procedures for the day: every patient’s full name and birthday, the time of the procedure, the assigned physician and the service being provided. This is a blatant disclosure of protected health information.
6. An OB/GYN practice client ran into trouble when its receptionist recognized a woman from her neighborhood who came in for STD testing. The receptionist promptly posted a gleeful message on Facebook regarding the patient’s medical issue after tracking down the test results, and common acquaintances on Facebook became privy to this confidential information. Improper access to patient information by office staff and dissemination of these details using social media are significant challenges that must be addressed.
The privacy rules created by HIPAA can seem cumbersome but every practice should evaluate its operations to make sure it is compliant:
1. Hand out/provide a Notice of Privacy Practices to every new patient. Review your HIPAA policies from time to time to update them.
2. Do not disclose protected health information to anyone except for payment, treatment, or healthcare operations. This means you are limited as to what information, if any, you may disclose to family members without an authorization (there are specific rules for minors/incompetent patients).
3. Make sure everyone in your office has access only to the limited amount of information necessary for their job performance. Computer access should be password protected and there should be strict rules regarding the use of social media.
4. Minimize access to protected health information by third parties in your office: Reconsider your check-in procedures, chart organization and look for gaps in your policies where disclosures may occur.
5. Educate your staff on the requirements of HIPAA and have a policy of discipline for failure to comply.
There are many scenarios where HIPAA can be cumbersome, illogical, or hard to apply. Basic patient privacy in the practice setting, however, is something that can be achieved with proper planning and attention to detail.
Choosing the Right EHR Vendor for Your Practice
It's not just the software that makes an EHR tick; it's also the vendor behind it. Here's how to find out if you and the vendor are truly a perfect match.
By Robert Redling | Source: Physician's Practice | August 8, 2011
Shared vision
What does it take to pick the right EHR? Savvy purchasers — those with years of experience with various technologies from multiple vendors — say it's a bit like choosing a life partner, as opposed to a dream date: go for shared goals and long-term compatibility instead of looks.
The federal government's meaningful use criteria, part of the EHR incentive program, may lead to more similarities than differences between EHR systems, but choosing the right system has not gotten any easier. Now, as always, finding the right system means finding the right vendor.
For Gina Tucker, a practice manager in Northampton, Mass., getting the right vendor meant taking a chance. In 2001, the five-physician practice she manages, Hampshire Obstetrical and Gynecological Associates, Inc., opted for an integrated EHR and practice management system. The vendor was new on the scene and still developing its product line, but the bet paid off, she says. Not only has that vendor grown into a top-10 player in physician EHR systems, but it continues to deliver the high levels of service and support that Tucker gambled it would.
Looking back, Tucker says it wasn't an entirely risky bet; in large part due to the method her practice used to select its EHR. Because the software for electronic medical records was still a work in progress a decade ago — much more so than today — Tucker and her practice's selection team looked as carefully at potential vendors' market strategies, as it did their products.
"We didn't go to software vendors and say 'here's what we want to fix,' but rather (we said), 'our goals are thorough documentation and staying on top of everything we need to so we can provide good patient care, be efficient, and keep improving,'" Tucker says. "We felt the company we chose was on the same path as we were to improvement."
Tucker says to look beyond a vendor's statements about being the best in the business, best in breed, and other similarly inflated phraseology. Instead, look at how much it invests in research and development of new products. Ask whether its product-development team includes seasoned pros with success in developing information technology for physician medical practices and similar environments.
"You want to feel that they understand your business," she says. "It's a feeling that you have a melding of philosophies, which goes well beyond any statements that a salesperson can make."
Scoping out vendors: a checklist
There are many questions you should ask vendors and other users to figure out what the right system — and vendor — is for you. Here's what Tucker suggests asking:
Questions to ask the vendor:
- How many practices use your system nationwide?
- What are the specialties and sizes (in number of physicians, not full-time equivalents) of practices using your system?
- How many users have switched to other systems and why?
- Are any physicians involved on a day-to-day basis in your research and development, implementation strategies, design, or other key areas?
- How does your company integrate ideas submitted by end users?
Next, here are questions to ask other users of the product (ask your vendor for references):
- Do you feel the vendor and its staff understand medical practice business and clinical challenges?
- Is it easy to reach someone from the company on the telephone?
- What is the number one reason you chose the system?
Train to perfection
Qualifying for the federal government's full complement of EHR Stage 1 meaningful use incentives might cover much of a new system's cost. Or it might not. It's all too tempting to cut corners on training costs to lower the acquisition cost of a new system. Don't do it, says technology consultant Rosemarie Nelson, with the Medical Group Management Association's Healthcare Consulting Group.
The train-the-trainer approach is necessary to build a core of in-house experts, but don't expect that a few people on your staff can adequately train the many others who need the knowledge, too, she says.
"There's way too much to absorb in a new EHR for one or two people to quickly get the big picture and be able to transmit that to everyone in the practice who needs the knowledge, which is pretty much everyone in the practice," Nelson says.
Make sure there is enough money in the proposal for the vendor to train several employees, she says.
Meaningful Use Incentives Jeopardized by GOP Bill
By Dan Bowman | Source: feircehealthit.com
January 28, 2011
Despite news Thursday that support for H.R. 408 —the Republican-sponsored House bill aimed at cutting $2.5 trillion in federal spending over the next decade--could mean the repeal of the Meaningful Use incentive program allotted in the American Recovery and Reinvestment Act of 2009, some people, including Justin Barnes, former leader of the HIMSS Electronic Health Records Association, have said they aren't worried.
Barnes, who now serves as vice president of marketing, corporate development and government affairs at Greenway Medical Technologies, calls the bill more of a "message bill" than anything else.
"I have zero concern about it taking away the incentives," he told Health Data Management. "It is a campaign promise."
Geoff Gerhardt, a senior staff member of the House Ways and Means Committee, didn't think it would amount to much, either. "I do think there may be a legislative attempt in the House to try to change some of the funding; however, I am confident that it's not going to succeed at the end of the day," Gerhardt said.
The bill, according to HDM, would repeal some ARRA provisions specific to Meaningful Use. Specifically, Section 302 of the bill states: "Effective on the date of the enactment of this Act, subtitles B and C of Title II and Titles III through VII of Division B of the American Recovery and Reinvestment Act of 2009 [Public Law 111-5] are repealed, and the provisions of law amended or repealed by such provisions of Division B are restored or revived as if such provisions of Division B had not been enacted."
Meaningful Use falls under Title IV of Division B, which means those incentive dollars would disappear if the bill became law, according to HDM.
Meanwhile, confusion abounds over the future of the Healthcare Information Technology for Economic and Clinical Health (HITECH) Act, should the bill be successful. HITECH falls under Division A, Title XIII of H.R. 408, meaning, for the most part, it steers clear of the chopping block.
However, Section 301 of the bill puts "un-obligated balances of the discretionary appropriations made available by Division A" of the stimulus law in jeopardy. In other words, if any of the $2 billion in discretionary spending money allotted to the Office of the National Coordinator for Health IT from HITECH goes unspent, it could be taken back, as well.
All of that has HIMSS Vice President for government relations Dave Roberts just a little on edge, reports Healthcare IT News.
"We're trying to tell people that this process is going on. This is only one body [of Congress]. Don't let this be a concern," he said. But "if this is a new way of thinking, that could be concerning. So I think that while this particular bill may not pass, it's something that has to be watched closely."
Patti Dodgren, CEO of Hielix--which helps to facilitate electronic health information exchanges across the U.S., shares Roberts' view.
"Just the suggestion of repealing HITECH stimulus funds for physicians...is short-sighted at best, and threatens the very progress that is already beginning to be realized within the industry to move our healthcare system into the 20th [yes, 20th] Century," Dodgen told FierceHealthIT. "All this bill serves to do is strengthen the cynics of health IT. We work with thousands of physicians and state government healthcare officials who have worked tirelessly over the past months to achieve the benefits that healthcare IT promises, and this bill is a disservice to them and to the healthcare industry"
Meaningful Use Mondays — Registering for EHR Incentive Money
By Lynn Scheps, Vice President, Government Affairs at SRSsoft
Source: emrandhipaa.com
January 3, 2011
Registration for participation in the EHR incentives program begins today. It is done online (no paper registration, appropriately enough!) by using the registration link that should now appear on the CMS Registration and Attestation page. That page details all the information needed, so I will just remind providers who plan to participate under the Medicare program that they will have to be enrolled in PECOS (Provider Enrollment, Chain and Ownership System) — although not necessarily before they register.
While it is a good idea to begin familiarizing yourself with the registration process and requirements, there is no need to feel rushed. Registration does not have to be done immediately-it can even be done at the same time as attestation-and the earliest date that providers can attest to demonstrating meaningful use is April 1, 2011. Providers have until as late as October 1, 2012 to begin reporting on meaningful use and still earn the maximum reimbursement under Medicare — although it is clearly not advisable to wait until the last minute to start-and they can begin even later under the Medicaid provisions. (To be discussed in future posts.) The important determination eligible providers have to make upon registration is whether they will participate under Medicare or Medicaid, because once they receive their first incentive payment, they will only be able to switch programs one time. The next two Meaningful Use Monday posts will provide information to help providers make this decision.
Meaningful Use — Doctors Have No Choice
By James O'Connor, MD — Source: Physician's Practice
EHR vendors, consultants, regulators, and even some CIOs have giddily promoted the EHR incentive program (“meaningful use”) for nearly a year. Countless businesses and blogs have been born to fulfill the need to ingest and digest compliance information. In-your-face marketing has been a powerful current sweeping doctors towards choosing an EHR system or meaningful use consultant.
Physicians' responses are all over the map. A surprising number of our colleagues still don't know about meaningful use. Some doctors plan to ignore it altogether. (It appears that the fewer the number of years to retirement, the greater the apathy towards meaningful use.) Some practices are optimistically and enthusiastically making plans. Others are revealing their ambivalence, wrestling with the question “should we or shouldn't we?”
I whole-heartedly support the adoption of electronic health records. I was an early adopter in my own practice and have spent a good deal of time in the industry. I am aware that the majority of my colleagues remain resistant to EHRs. Government incentives are a positive way to initiate widespread adoption. Meaningful use has its flaws, but the stimulus will fuel innovation in healthcare IT, potentially creating a powerful engine for economic recovery.
On the other hand, meaningful use places a burden on doctors with little direct return on investment. In most cases, the incentive will not cover the real cost of adoption, which includes more than just hardware and software. There is a well-documented productivity loss in the first 12 to 18 months after adoption of an EHR. It is widely reported that compliance with meaningful use will require medical practices to hire additional staff. Experts predict a shortage of staff with requisite skills. Meaningful use coincides with the planned elimination of the consult code and looming 21 percent cut in Medicare reimbursement.
Nonetheless, the pros and cons of meaningful use are not really the problem. The problem is that, once again, we physicians are subject to a mandate over which we have little control and no choice whether to comply. Is this surprising to you? Consider these facts:
1. CMS penalties begin in 2015.
2. What if you won't or don't accept Medicare/Medicaid patients (13 percent of practices in 2009, up from 6 percent in 2004? In August, four major insurers (Aetna, Highmark, United Health Group, and Wellpoint) announced that, at a minimum, they will link their pay-for-performance programs to federal meaningful use criteria. Other insurers are likely to follow.
3. Do you run one of the increasing number of “boutique” or VIP practices that work on a cash-only basis? The American Board of Medical Specialties (ABMS) released a statement in August saying that they intend to link meaningful use of health information technology into the ABMS Maintenance of Certification© program.
4. You don't care about being board certified? (Sound of crickets chirping.) The Final Rule gives states the authority to impose additional requirements that promote compliance with meaningful use. As reported in Physicians Practice, the state of Massachusetts may take away your license to practice medicine in 2015 unless you demonstrate meaningful use of an EHR system. In Maryland, private insurers will be required to build incentives for acquisition of EHRs and penalties for not adopting them into their payment structure.
OK, so technically, we do have a choice. We could stop taking Medicare and Medicaid patients, accept cash only, give up our board certification (and thus usually hospital privileges), and move to a state (or country) that doesn't impose EHR requirements. But is that really a choice? No. Our only real choice is action. Here are a few suggestions:
1. Submit comments to the Office of the National Coordinator (ONC). Although meaningful use is not likely to be repealed (even with the recent change of guard in the House), the 276-page Final Rule shows that ONC is at least considering and responding to comments. Some comments actually yielded changes in the Final Rule.
2. Contact your specialty organization and initiate a grassroots movement to push back against the ABMS mandates. Larger specialty organizations, such as those for family practice and cardiology, may be able to influence ABMS to repeal the requirement or at least gain reprieve.
3. Get your state medical association involved. Those in Idaho, Wyoming, and Texas may even be powerful enough to prevent state involvement in meaningful use.
4. Call your state legislators and let them know you expect them to protect doctors' interests
The final choice — watchful waiting — may seem like capitulation. But there are two reasons this may be the wisest course. First, there are many who doubt CMS' ability to deliver on the incentives. Small practices can probably wait until early- to mid-Spring 2011 to see what develops and still have enough time left in the year to choose an EHR and qualify for the 2011 incentive. Second, EHR vendors have a huge stake in this market. Vendors will have to introduce innovation into their offerings in order to distinguish themselves and win your business. The right innovation could make this pill easier to swallow.
James O'Connor is an OB/GYN, founder of MDcohort LLC, and co-chair of CCHIT's Clinical Research Group.
Physicians Already Seeing Early Impact of Healthcare Reform -
Are You Prepared?
By Dr. Gunter Dymkova-Fuchs — Source: The Fox Group, LLC
Even though many provisions of the Patient Protection and Affordable Care Act are implemented in 2014, some are active right now. Many of these changes will affect what the covered services are for your patients, or even who will be eligible for coverage in the first place. Consequently, the practitioner will be able to potentially provide service that was not covered in the past.
Examples of coverage related changes due to heatlhcare reform:
- Young people can remain on parents' health insurance until age twenty-six;
- There can be no discrimination against children with pre-existing conditions;
- No dropping people from coverage when they get sick;
- There will be no lifetime limits on coverage;
- New plans must offer free preventive care; and
- There will be an expanded ability to appeal decisions made by the health plan
In addition to the changes in coverage for your patients, there are a number of requirements and operational impacts that providers are needing to reckon with. These changes can in some cases be far reaching, and require some fundamental reorganization for a number of solo and medical group practices.
Examples of operational changes in a medical practice due to healthcare reform:
- Physicians and other providers applying for Medicare participation will be required to have a medical Compliance Program in place. It is yet unknown if this requirement will extend to an existing Medicare participating medical group which is adding a physician or other practitioner who has not previously participated in Medicare, but it's safe to assume that that's the direction things are moving;
- States may use Recovery Audit Contractors (RAC's) for audits of state Medicaid programs. So anticipate more frequent and in-depth scrutiny. Developing and implementing effective Compliance Policies and Procedures that include internal monitoring, and risk-based coding and medical documentation, have become essential; and
- Efficient and effective medical group operations have always been sought, but as reform measures bring about the above described scrutiny, be aware of how much more critical billing practices, personnel management, and general practice operations are going to be if you are to prosper in this new environment. If you're unsure about your current status, or know that there are some rough spots, but are struggling to find solutions, consider having an independent third party review by a qualified healthcare management consultant. Someone who can properly review, evaluate, and give sound advice on necessary modifications. And someone who can help you put those changes in place.
Like so many policy changes, healthcare reform in this country is less than what some hoped for, but more than what others envisioned. That being said, it no doubt is going to play a significant role in physician practices. And the requirement for an effective compliance program formally transitioning from voluntary to mandatory should certainly be a catalyst for taking these changes seriously. Like with most things in business, being proactive is typically easier and more profitable than the alternative.
Meaningful Use: The Rules Explained At Last
By Bob Redling, Bob Keaveney, and contributing editors at Physicians Practice
THE BASICS
The EHR incentive program was created by the Health Information Technology for Economic and Clinical Health Act (HITECH Act), part of the federal stimulus package signed by President Obama in 2009. The legislation provides incentives to each physician (and certain other providers) who meet HITECH's requirements.
There are separate programs for Medicare or the Medicaid participants; you must participate in one of these programs to be eligible for the incentive. If you participate in both, you may choose to participate in either incentive program - but not both. You may switch between incentive programs after you start, but only once.
Medicare offers physicians a bonus of up to $44,000 paid over a five-year period starting in 2011.The payments are tied to 75 percent of the physician's annual allowed Medicare Part B charges that year. If you start in 2011 or 2012, you can capture the maximum $18,000 bonus in your first year of participation by billing at least $24,000 in Medicare allowed charges.
Participation in the bonus program ends in 2015, so waiting until 2013 to begin drops your cumulative take to $39,000, and to $24,000 if you start in 2014. After that, physicians who still aren't using EHRs will begin to see their Medicare payments reduced; the penalties will go as high as 5 percent in 2019.
The Medicaid bonuses are geared to patient volume and there's no penalty for not participating. At least 30 percent or more of your patient volume must be Medicaid beneficiaries (but only 20 percent for pediatricians) measured over any continuous 90-day period in the program's first calendar year. Eligible professionals for Medicaid bonuses include nurse practitioners, certified nurse-midwives, and some physician assistants such as those working in rural health clinics or provider shortage areas.
For both programs, CMS will make bonus payments to each eligible professional in your practice. In other words, a group of three internists could receive $132,000 in total if each successfully participates in the Medicare program.
For practices more likely to refer patients to health credit cards, mostly dermatology, plastic surgery, ophthalmology and other specialties that offer noncovered procedures, it's essential to be clear with patients that they are signing up for a credit card with an outside company and not, as many patients claim they were misled to believe, a payment plan with the practice.
And although new credit card regulations that became effective last month limit the size of late fees and restrict interest rate increases on balances--another area of patient contention--the regulations continue to permit "teaser" or promotional rates, Gail Hillebrand, a senior attorney at Consumers Union, told the Washington Post.
While it's not the practices' responsibility to sit with patients and go over all of a card's terms and conditions, they should encourage their customers to read the information thoroughly before signing, says Maria K. Todd, MHA, PhD, CEO of global health provider network Mercury Healthcare.
THE RULES
The legislation sets four objectives for physicians to get the stimulus money. You must:
- Use certified EHR technology in a meaningful way;
- Utilize electronic prescribing;
- Use a system that electronically exchanges health information to improve the quality of care; and
- Submit information about clinical quality and other measures.
That first bullet concerning the "meaningful use" of an EHR raises questions about what qualifies as meaningful. In response, CMS recently issued final meaningful use rules: 15 mandatory requirements for providers (and 14 for hospitals), as well as a menu of 10 additional requirements, from which providers must select five. You must attest in writing to using your EHR to those capabilities for at least a 90-day period if you start during 2011 and for a full year if you start in 2012 or later. CMS plans to raise the bar further by adding more criteria in subsequent years of the bonus program.
What are the meaningful use criteria? Here is the full list as compiled by David Blumenthal, MD, director of the Office of the National Coordinator for Health Information Technology (ONC) and Marilyn Tavenner, RN, principal deputy administrator of the CMS, in the New England Journal of Medicine. Note: We've modified the list slightly from the version in the New England Journal, in order to make it more user-friendly. The list as originally compiled can be found here.
CORE REQUIREMENTS
To achieve meaningful use of an EHR, providers must meet the following 15 core requirements under the objectives in Stage 1:
| 1 | Record patient demographics |
| 2 | Record and chart changes in vital signs |
| 3-5 | Maintain active problem, medication, and allergy lists |
| 6 | Record smoking status |
| 7,8 | Give patients an electronic copy of their health information and a summary of clinical data |
| 9 | Generate and transmit permissible prescriptions electronically |
| 10 | Use computer provider order entry for medication orders |
| 11 | Implement drug-drug and drug-allergy interaction checks |
| 12 | Implement one clinical decision support rule and the ability to track compliance with that rule |
| 13 | Implement system to protect the privacy and security of patient data |
| 14 | Report ambulatory quality measure to CMS or the state |
| 15 | Implement the capability to electronically exchange key clinical information among providers and patient-authorized entities |
MENU
Providers must also meet at least five criteria of the following "menu" of 10:
Health Credit Cards: Proceed with Caution
Despite revenue-cycle and practice-management experts' early enthusiasm toward encouraging patients to pay for their noncovered care with healthcare credit cards--for which patients apply for right in the office, yielding practices' faster collections--experience has revealed a number of flaws in this solution.
And it's not just New York Attorney General Andrew Cuomo's current investigation in to health credit cards offered by major lenders--including GE Money, JPMorgan Chase and Citigroup--that has made such outside financing options less attractive to patients and practices. According to practice-operations expert Elizabeth Woodcock, MBA, FACMPE, CPC, of Atlanta-based consultancy Woodcock & Associates, patients' track record of defaulting on such loans has led GE's CareCredit and others to be less interested in retaining physician practices as clients. As a result, these companies "have not expanded and sometimes even retracted their business in the medical practice market," Woodcock says.
For practices more likely to refer patients to health credit cards, mostly dermatology, plastic surgery, ophthalmology and other specialties that offer noncovered procedures, it's essential to be clear with patients that they are signing up for a credit card with an outside company and not, as many patients claim they were misled to believe, a payment plan with the practice.
And although new credit card regulations that became effective last month limit the size of late fees and restrict interest rate increases on balances--another area of patient contention--the regulations continue to permit "teaser" or promotional rates, Gail Hillebrand, a senior attorney at Consumers Union, told the Washington Post.
While it's not the practices' responsibility to sit with patients and go over all of a card's terms and conditions, they should encourage their customers to read the information thoroughly before signing, says Maria K. Todd, MHA, PhD, CEO of global health provider network Mercury Healthcare.
Better yet, both experts who spoke with FiercePracticeManagement say, practices should strive to improve their systems of administering and monitoring internal payment plans for patients' large out-of-pocket costs.
Scanning Paper Charts in an EMR Office
By John Meewes, President of National Scanning.
Discretionary scanning, hiring temporary help, and re-purposing office staff to scan patient charts has been a growing trend.
While the costs associated with these practices may at first glance seem lower, there are hidden costs and liabilities that far outweigh the expected savings.
When selecting a scanner, the first number potential buyers see is the "Pages per Minute" (ppm). This is the number of sheets that the scanner can read under optimum conditions (and usually at lower resolution and page size). The number usually not published or ignored is the daily duty cycle - often just several thousand pages per day.
In real world settings, the actual throughput is less than 1/4 of the published PPM. Jams, indexing, and software glitches all slow the process. Equipment maintenance, software installation, training, and employee turnover further add to the time spent on the scanning project.
As labor costs (which are a function of throughput) increase fourfold or more, the ROI model that may have initially shown cost savings with a "do it yourself" project may no longer support that decision.
Most importantly, though, is the liability physicians face for improperly scanned charts. Transient help is cheap, but they have no responsibility to monitor quality, ensure that records are properly filed & attached to EMR, or to ensure that misplaced records are found. We even worked with a physician who had temporary help literally throwing charts away to create the illusion of higher productivity.
Physicians are required by law to maintain a medical record for each patient which completely and accurately documents the person's evaluation and treatment. The failure to maintain a record for each patient constitutes professional misconduct. A missing chart could have serious consequences on the provider's ability to defend themselves in a malpractice claim. If you can't produce the documentation, then your version of the events will be suspect.
Reputable service bureaus have quality and auditing measures in place to ensure accurate and complete conversion of paper charts. While the upfront costs may seem higher, the peace of mind and longer term savings are worthy of consideration.