Guest Post – Amit Trivedi – As the healthcare program manager for ICSA Labs, Amit Trivedi spearheads the lab’s overall efforts in the healthcare industry, including launching and managing the 2011/2012 Office of the National Coordinator (ONC) Authorized Testing and Certification Body (ATCB) certification program.

We all know there is no such thing as perfect security. All we can do is try to mitigate as many risks as possible. In this regard, there are areas related to information security that the current ONC-ATCB 2011/2012 (commonly referred to as meaningful use) certification testing does not yet address and that the health IT community should be aware of when implementing systems.

ICSA Labs is an Office of the National Coordinator-Authorized Testing and Certification Body (ONC-ATCB), designated to test both complete and modular electronic health record (EHR) technologies under the auspices of the federal government’s Temporary Certification Program. ICSA Labs has a history rich in the certification of security products. We have been testing security products and developing test criteria for more than two decades and we understand the importance of raising security awareness in the health IT community and helping Eligible Providers and Hospitals understand what meaningful use EHR certification testing does and doesn’t cover.

It is important to remember that regardless of the number of security features a product has, an incorrect or incomplete implementation can introduce vulnerabilities or compromise the security of the system. Certification testing can really only demonstrate that a product is capable of being used securely, not that its security can never be compromised.

Testing bodies must test products within the scope of approved test procedures. As an organization that has developed testing procedures and methodologies, we understand that there is a delicate balancing act when developing requirements so that general concepts and capabilities are covered by the testing, but the testing process is not designed so specifically as to stifle innovation in new products. As such, we recommend that end users and implementers be aware of these requirements when deploying ONC-ATCB 2011/2012 certified products.

Encryption Requirements Do Not Address the “What”

Consider the encryption requirements (criteria 170.302.u and 170.302.v). The current testing criteria require FIPS 140-2 level encryption. This an excellent way to require products to support some of the best levels of encryption available today, and that they are also in line with other federal encryption requirements.

One could compare encryption to a bank vault. You might purchase the most secure, unbreakable vault in the world, but if you don’t put your valuables in the vault, it won’t be of any help when there is a break-in. The current meaningful use testing procedures do not dictate what must be encrypted. Ultimately it falls to end users to make a determination as to how they want to implement security – hopefully basing the decision on a risk-based approach. Fortunately, meaningful use testing and certification follows a staged approach to getting from where we are today to where we’d like to be in the future. The meaningful use certification is planned to be rolled out in three stages. Right now, we are in the midst of Stage 1. Some recommendations to the ONC for Stage 2 security criteria include addressing things like encrypting data at rest (including data in datacenters and mobile devices) – something that is not part of the Stage 1 requirements.

Negative Testing Examines the Unexpected

Another area to highlight is related to negative testing, which is currently out of scope for ONC-ATCBs. The testing performed today relies on giving the EHR an expected input and verifying that the expected result is met. Negative testing, however, is the concept of giving unexpected or invalid inputs to a system and verifying receipt of an expected result (typically, that the data is not accepted or an error is generated that does not crash the system). Negative testing is common throughout ICSA Labs’ proprietary security testing programs and something we feel should be incorporated into future testing of EHR technologies under the ONC Certification program.

Consider the authentication and access control requirements (criteria 170.302.t and 170.302.o). Some of you may be aware of an old Unix bug that resulted in the operating system being unable to correctly support passwords over eight characters. If the password was 12 characters long, a user only needed to enter the first 8 characters to be allowed to login. This made password cracking on Unix servers much easier, and because the system allowed the entry of a longer password, most users were unaware of this limitation.

ICSA Labs has discovered the same or similar problems when testing products in our proprietary security certification programs, and the primary way we discover this is by negative testing. For example, we configure a password greater than eight characters, and then we attempt to login to the system using only the first eight characters. This should be treated as invalid by the system and rejected. However, the meaningful use EHR testing only tests that the system accepts valid passwords. There is no testing done on the system’s acceptance or rejection of invalid passwords.

The Future of EHR Testing Must Increase Security, Privacy

As we progress to the next stages of meaningful use certification, the requirements should begin to look at other areas of security, such as application testing for vulnerabilities like buffer overflows, SQL Injection, and cross-site scripting attacks. These are all examples of security testing best practices. In many instances, ONC has signaled its flexibility in allowing third-party products to complement functionality of EHR technologies, which means that not all of the functionality needs to be native to the product. This can allow EHR developers to focus on functionality that their customers are looking for, while at the same time keeping security as an important consideration in the product life cycle development.

It is our hope that future stages of meaningful use testing will raise the bar and specify how and when features like encryption should be used and the scope of testing will be expanded to include things like negative testing. As the meaningful use criteria evolve, it is critical that both the criteria and testing procedures are developed in ways that consider the long-term security and privacy of patient health records.  

Time for the next entry covering Shawn Riley’s list of 101 Tips to Make your EMR and EHR More Useful. I hope you’re enjoying the series.

If you want to see my analysis of the other 101 EMR and EHR tips, I’ll be updating this page with my 101 EMR and EHR tips analysis. So, click on that link to see the other EMR tips.

60. Reporting, reporting, reporting, reports
What’s the point in collecting the data if you can’t report on it? I’ve before about the types of EMR reports that you can get out of the EMR system. The reports a hospital require will be much more robust than an ambulatory practice. In fact, outside of the basic reports (A/R, Appointments, etc), most ambulatory practices that I know don’t run very many reports. I’d say it’s haphazard report running at best.

Although, I won’t be surprised if the need to report data from your EHR increases over the next couple years. Between the meaningful use reporting requirements and the movement towards ACO’s, you can be sure that being able to have a robust reporting system built into your EHR will become a necessity.

59. Are the meaningful use (MU) guidelines covered by your product?
Assuming you want to show meaningful use, make sure your EHR vendor is certified by an ONC-ATCB. Next, talk to some of their existing users that have attested to meaningful use stage 1. Third, ask them about their approach for handling meaningful use stage 2 and 3. Fourth, evaluate how they’ve implemented some of the meaningful use requirements so you get an idea of how much extra work you’ll have to do beyond your regular documenting to meet meaningful use.

58. It they aren’t CCHIT certified take a really really hard look
Well, it looks like this tip was written pre-ONC-ATCB certifying bodies. Of course, readers of this site and its sister site, EMR and HIPAA, will be aware that CCHIT Has Become Irrelevant. Now it’s worth taking a hard look if the EHR isn’t an ONC-ATCB certified EHR. There are a few cases where it might be ok, but they better have a great reason not to be certified. Not because the EHR certification provides you any more value other than the EHR vendor will likely need that EHR certification to stay relevant in the current EHR market.

57. What billing systems do you interface with?
These days it seems in vogue to have an integrated EMR and PMS (billing system). Either way, it’s really important to evaluate how your EMR is going to integrate with your billing. Plus, there can be tremendous benefits to the tight integration if done right.

56. How much do changes and customizations cost?
In many cases, you can see and plan for the customization that you’ll need as part of the EHR implementation. However, there are also going to be plenty of unexpected customizations that you don’t know about until you’re actually using your EHR (Check out this recent post on Unexpected EHR Expenses). Be sure to have the pricing for such customizations specified in the contract. Plus, as much as possible try to understand how open they are to doing customizations for their customers.

Check out my analysis of all 101 EMR and EHR tips.

Our next edition of EMR and EHR interviews covers the experience of Jan Patterson and the West Broadway Clinic’s path to meaningful use. The full EMR interview with Jan Patterson can be found on the new EHR and EMR interviews website. The following is a summary of that interview written by Kathy Bongiovi.

If you’re a doctor, nurse, practice manager, EHR consultant, CEO or executive of an EHR vendor, etc with EMR experience that’s interested in being interviewed, let us know on our Contact Us page.

West Broadway Clinic is one of the first clinics to show Meaningful Use. Jan Patterson, the office manager of West Broadway Clinic explained it was the clinic’s desire, from day one, to start using an EHR. The EHR certification is a vital piece for meeting the CME incentive requirements. Additionally the providers felt by using an EHR on day one they could ensure a continuity of care, regardless of which provider a patient might see in the clinic.

The clinic had heard about Cerner Corporation through one of the local hospitals. After interviewing several other vendors it felt that the integration of Cerner’s Practice Management System and Ambulatory EHR would suit its needs best.

West Broadway began using its EHR in May of 2008 and Patterson stated it was able to meet at least 9 of the meaning use requirements because of its EHR. Patterson felt two of the major factors contributing to meeting those requirements so easily were the elements already built into the EHR and the use of the Cerner EHR. As the clinic encountered issues it was able to contact Cerner’s Meaning Use team to assist in the process of attestation.

Additionally, attending Webinars set up by Cerner Corporation, examining materials provided by Medical Group Management Association (MGMA), and attending an MU Summit set up by Cerner Corporation to highlight some of the more important segments of MU, all played an integral role in ensuring West Broadway Clinic would meet Meaningful Use requirements.

The most challenging Meaningful Use requirement was encouraging all of the providers to use the electronic prescriptions function. After reaching MU in just over three months, just two days after attestation opened, Jan Patterson states the clinic continues to maintain its high level of entering the patients’ correct and necessary data and the numbers of electronic prescriptions being sent to pharmacies are increasing.

The benefits to patient care are immediate access to the most current visit information and patient history at its finger tips. Patients receive more continuity of care due to the fact that regardless of what provider they are seeing within their office , the provider can quickly and easily track what services and/or medications a different provider has provided the patient. Components such as eprescribe, medicine/drug interactions, allergy checks, complete documentation, immunization schedules and growth charts etc., have made the clinic more efficient throughout the office.

Patterson’s advice to anyone starting the MU process is to make sure you have gathered all the information and facts first and ensure all physicians/staff are not only fully advised of what is required to meet MU but are also committed to following the process through to its completion. It is important they understand the benefits and necessity of Meaningful Use. After three years of being on an EHR, Patterson cannot imagine functioning as efficiently on a paper system. Although Patterson acknowledges the money as an incentive, the real benefit in successfully attesting is the benefit to their patients. As Patterson suggests, “The increased benefits of safety cannot be undersold. With the assistance of the EHR, we are practicing better, safer medicine than we could on paper records.”

Read the full transcript of Jan Patterson’s interview.

I’ve been having a number of discussions online and through email with people about the future of the EHR incentive money. A number of people are quite concerned with the government funding for the EHR incentive money. You may remember that I posted about this before on multiple occasions and had some really interesting discussion.

Here’s a summary of some of the points that I’ve heard people making when it comes to the EHR incentive money being taken away:

1-There is a crucial difference between the two steps required for Congressional funding, a-authorization and b-appropriations. Congress can authorize, but cannot appropriate for 5 yrs. This applies to the EHR stimulus money. Thus the 5 year EHR payment has been authorized, but no EHR funds have been, nor can they be, appropriated for 5 years, right?

2-There is $18k this year for doctor Medicare EHR. But not the remaining $26k over 5 years has not been apropriated (same applies to hospitals funds).

3-The budget deficit and debt ceiling suggest Congress will be looking now and in the future for cutting every dime they can,
and thus the $20B or so for EHR could be part of the cut. Thus there may be reduced EHR funds, or none, appropriated by Congress after this year.

I still believe in my gut that the EHR incentive money is going to be safe and still around going forward. There’s little benefit to cutting a mere $20 billion from a program that is generally bi-partisan. Plus, no one in congress really knows the potential good or bad impacts of the HITECH act on EHR and healthcare IT. However, it’s really easy for them to quickly assume that more technology in healthcare is good and worth funding (whether the way they’re doing it is good or not…a subject for a different post).

It’s certainly not beyond the realm of possibilities that the government could make some sweeping cuts and the EHR incentive money is a casualty of those sweeping no holds bars type cuts. Point being that I don’t think there are any people in congress that are passionately for it or passionately against it. So, I think that means that it will likely either get carried forward on a whim or cast aside on a whim.

How’s that for a concrete answer? Are there points that I’m missing? Are we misunderstanding the HITECH funding process? Feel free to chime in with any knowledge you might have of the government process.

The CMS FAQ site has a great question up that I have a feeling a number of doctors will be interested in knowing the answer to:
I am an eligible professional (EP) who has successfully attested for the Medicare Electronic Health Record (EHR) Incentive Program, so why haven’t I received my incentive payment yet?

Here’s their answer:

For EPs, incentive payments for the Medicare EHR Incentive Program will be made approximately four to eight weeks after an EP successfully attests that they have demonstrated meaningful use of certified EHR technology. However, EPs will not receive incentive payments within that timeframe if they have not yet met the threshold for allowed charges for covered professional services furnished by the EP during the year.

The Medicare EHR incentive payments to EPs are based on 75% of the estimated allowed charges for covered professional services furnished by the EP during the entire payment year. Therefore, to receive the maximum incentive payment of $18,000 for the first year of participation in 2011 or 2012, the EP must accumulate $24,000 in allowed charges. If the EP has not met the $24,000 threshold in allowed charges at the time of attestation, CMS will hold the incentive payment until l the EP meets the $24,000 threshold in order to maximize the amount of the EHR incentive payment the EP receives. If the EP still has not met the $24,000 threshold in allowed charges by the end of calendar year, CMS expects to issue an incentive payment for the EP in March 2012 (allowing 60 days after the end of the 2011 calendar year for all pending claims to be processed).

Payments to Medicare EPs will be made to the taxpayer identification number (TIN) selected at the time of registration, through the same channels their claims payments are made. The form of payment (electronic funds transfer or check) will be the same as claims payments.

Bonus payments for EPs who practice predominantly in a geographic Health Professional Shortage Area (HPSA) will be made as separate lump-sum payments no later than 120 days after the end of the calendar year for which the EP was eligible for the bonus payment.

For more information about the Medicare and Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms.

This is actually something that I’ve written about before (probably on EMR and HIPAA), but I have a feeling many people weren’t looking at the details to realize why they aren’t getting their incentive money. You have to wait until you have enough Medicare Allowable Charges before they’ll pay you. I think this is a smart plan I do find it interesting that there were some clinics that had enough allowable charges in 3 months to receive the full EHR incentive money right away. I’d love to see some stats on medicare allowable charges per provider. Would be interesting to see how this aspect of the EHR incentive program affects Medicare providers.

Either way, hopefully this information will help someone who is wondering where they EHR incentive money is. Thanks to @jimtate for tweeting the FAQ and reminding me of this part of the program.

One of my readers, Michael Archuleta from Red Planet EMR, sent me the following interesting narrative that talks about the Lettuce industry. It seems like there’s some interesting parallels to some of the government involvement we’re seeing in healthcare. Enjoy the story:

I recently attended the annual TigerLogic Conference to learn about new features and capabilities that are being incorporated into MvBase. While there, I had an interesting conversation with Eric, the data processing manager for a 30-user system. The company he works for is in the agribusiness field of growing lettuce.
“Why are you here?” I inquired.
“Well, the government wants to impose more regulations on us. Ever since the salmonella scare with spinach, the pressure has been on us growers to track things more effectively.”
“What,” I asked, “are you going to do? Spray- paint barcodes on heads of lettuce?”
“Not quite, but close. We are going to have to tag every crate of lettuce. The only problem is that once a problem is identified, that crate will have long since been destroyed.”
“So,” I pressed, “why are you here?”
“Well, we either have to spend 150,000 to upgrade our system, or we have to switch to a new government mandated system which will cost us 150K. It is huge either way.”
The government, I mused, invades yet another small American business.

I wonder if he got any of the stimulus money to upgrade their system.

This is the first in a series of EMR, EHR and Healthcare IT interviews that will be done on EMR and HIPAA and EMR and EHR. The full EMR interview with Dr. West can be found on the new EMR, EHR and Healthcare IT interviews website. The following is a summary of that interview written by Kathy Bongiovi.

If you’re a doctor, nurse, practice manager, EHR consultant, CEO or executive of an EHR vendor, etc with EMR experience that’s interested in being interviewed, let us know on our Contact Us page.

In a recent interview with Dr. West, an endocrinologist in Washington D.C. and blogger at Happy EMR Doctor, the doctor discussed his experience in finding an EMR capable of fulfilling the needs of his specialized practice and, at the same time, saving him time. Dr. West discussed the arduous process of going from a failed to a successful EMR system.

His first experience with EMR was frustrating and he ultimately ended his relationship with the vendor. West heard other horror stories regarding failed EMRs and was convinced if he kept trying he would find an EMR that would fit his needs.

Dr. West advises other doctors and healthcare professionals to avoid rushing into any relationship with an EMR vendor and to make sure that when they sign a contract, first make sure the contract has a “satisfaction and money-back guarantee”. He suggests that anyone searching for an EMR, should find a vendor willing to let them try out their product for at least a month with no strings attached. Dr. West adds that the doctor or healthcare professional should also make sure there are not a lot of very specific hardware requirements in case the provider needs to change vendors.

Although some studies suggest a decrease in productivity with EMR systems because of a lack of customization for given specialties, West is not suffering from any of those issues and gives the credit to his EMR, Practice Fusion which is free and web based. The doctor has been able to customize templates to fit his specialty in endocrinology and is therefore able to see patients faster and complete their notes by the close of business. The benefits of customized templates, in his practice, allow “a more uniform approach to common problems, such as diabetes and thyroid nodules.” He goes on to explain that the result is a “well-defined path of questions designed to gather the most meaningful and relevant information” from the patient.

An EHR thorn in Dr. West’s side is his decision to not participate in the government’s EHR incentive plan. He thought he’d pursue the path to meaningful use, but after a great deal of frustration he abandoned his pursuit of the government’s EHR incentive money. West stated he may blog about his inner struggle with this issue. If so, his comments will appear in his blog Happy EMR Doctor.

The interview also touched upon Medicare’s recent practice of eliminating consultation codes and the consequences of this practice. By eliminating codes, Medicare has restricted providers’ ability to bill in certain instances. This has led to Dr. West and others turning away Medicare patients thereby restricting some patients’ access to care.

Dr. West’s EMR success should give all doctors and healthcare professionals the incentive to conquer the EMR puzzle and regain some of their personal time now spent handling and maintaining paper charts.

Full Disclosure: Practice Fusion is an advertiser on this site. However, they didn’t know we were doing this interview with Dr. West. Also, Happy EMR Doctor, Dr. West’s blog, is part of the Healthcare Scene blog network.

I imagine most of my readers know that I’ve launched the Healthcare Scene blog network. EMR and EHR is one member of the blog network along with 7 other blogs that have been announced with 6 more blogs that will be announced shortly (Have you found them already?). We’re growing rapidly and expanding the number of people that are sharing great content with the world of healthcare IT and in particular EMR and EHR. The goal of providing a platform for the independent Healthcare IT voice is becoming a reality.

It’s a really exciting thing to be a part of. The most exciting part of it all is the amazing people that I get to work with and the content they create. Here’s a quick glimpse at some of their content with my thoughts on their posts.

EMR and HIPAA
Neil Versel recently started posting a regular weekly column on EMR and HIPAA. Check out his latest post on clinical decision support and an update on Dr. Larry Weed. Reading articles like that from Neil help me to appreciate more fully the history of healthcare IT. I’ve admittedly showed up late to the party, but Neil provides some interesting perspectives based on his knowledge and experience in healthcare IT. Here’s my favorite quote from his article:

“Patients may surmise that a physician who uses a [decision support system] is not as capable as a physician who makes the diagnosis with no assistance from a DSS.” I then noted that Weed has been saying for more than 50 years that physicians shouldn’t have to rely on their memory to make clinical decisions when computers can help them process an increasingly voluminous knowledge base.

Meaningful HIT News
Neil’s blog Meaningful Healthcare IT News is also a member of the Healthcare Scene blog network. How can you not enjoy a post entitled Skype for “Redneck Telehealth”? Sometimes, you’ve got to do what you’ve got to do.

Happy EMR Doctor
What doctor isn’t interested in reading another doctor’s perspective on “Getting a Life with Electronic Medical Records,” “Gag Orders and Bad EMR Systems,” and a Doctor’s issues with PQRI Incentive Money? Those are the latest topics from Dr. West over on Happy EMR Doctor. Of course, now that Dr. West has gotten the blogging bug, his EMR gave him a life and his new blog has taken it back. I always appreciate a practicing doctor’s perspective.

Smart Phone Health Care
I’d been covering a number of mobile health care and mHealth related topics on this and my EMR and HIPAA blog, but the topic has become so popular that I knew it was time to start a mobile health care related site of its very own. I’m now doing it in partnership with David. He’s been churning out some interesting posts about Cell Phones Saving Lives in Africa and a Mobile App that Could Detect an Acute Stroke. I’ve always seen one of the major developments of mobile health happening in the developing world where the IT networks aren’t yet in place. Mobile phones can have such a tremendous impact for good. It’s beautiful to learn about. Although, mobile health is still in its infancy in the developed world as well. Personally, I’ve been trying to kick around some mobile gaming app that would encourage activity (ie. movement). Far too many of us sit in front of our computers all day. Healthcare would be so much better if more people just moved (written as I sit in front of my computer).

EMR, EHR and Healthcare IT News
This site is still very young, but just hit it’s 100,000 pageview mark. That’s a result that I would have never been able to predict. Although, news like the one posted today about the First Medicare EHR Stimulus Checks is something that many find interesting. If you know of other news we should be posting, let us know.

EMR and EHR Screenshots
The most recently announced member of the Healthcare Scene blog network is a website called EMR and EHR Screenshots. There’s still a lot I want to do to improve the interface for viewing the various EMR and EHR screenshots, but I think the concept is really interesting. My goal is to aggregate as many of the EMR and EHR screenshots as I can get. Hopefully that will mean even screenshots from the same EMR and EHR software as it releases new versions of the software. I’d love to have screenshots of CPOE, ePrescribing, scheduling, charting, diagnosing, etc. Basically if you’re interested in knowing what an EMR looks like or what it looked like previously, we’re hoping to provide you that view into an EMR’s development. A lofty vision. We’ll see how many EMR and EHR vendors, doctors, and other users will support it.

See what I mean when I talk about the amazing content that’s being generated. This doesn’t even include the great posts that Katherine Rourke is doing on this blog and my own posts (which could be classified as good or bad).

As I mentioned, I have 6 more blogs to be announced shortly. So, keep an eye on Healthcare Scene to see what will be announced next.

A new study sponsored by the American Hospital Association has concluded that developing an Accountable Care Organization is likely to be substantially more expensive than CMS has projected.  Not surprisingly, the AHA expects buying and managing EMRs and clinician decision support systems to be a major percentage of the added expense.

CMS has estimated it will cost an average of $1.8 million to start and sustain an ACO.  But the AHA dismisses that number as far short of the mark. Its own research, conducted by McManis Consulting, concluded that the actual startup and first-year costs for ACOs range from $11.6 million for a 200-bed, one-hospital system to $26.1 million for a 1,200 bed,  five-hospital system.

The AHA estimates that hospitals will spend anywhere from $2 million to $7 million to buy an EMR, and hundreds of thousands to integrate the system and build a health information exchange.  Not only that, health systems are likely to spend anywhere from $1.5 million to $3.9 million per year to maintain the EMR, manage the integration process and keep building out the HIE.  (My instinct is that the study’s estimates of systems integration and HIE linkages are rather low;  check out page two of the report and let me know what you think.)

If the AHA has it right — and I suspect it does — something is out of order here.  It’s hard for me to imagine how the agency could underestimate health IT costs so significantly, unless there’s some political game afoot here.

I’m not surprised to read that HIT costs are just as heavy a burden as recruiting, managing and and supporting affiliated physicians.  And I’m pretty sure that hospital CIOs aren’t kidding themselves on this front either.

Somehow, though, the Medicare folks have made some rather flawed assumptions and embedded them in the proposed  Medicare Shared Savings Program for ACOs.  If you agree that CMS is on the wrong foot here, I encourage you to submit comments on the proposed rule.  (See the beginning of the document for how to file those comments.) You have until June 6, so have at it!

I love the title of this post since it uses the word change. People when they see change start to get really concerned. For some reason we don’t generally like change. We often like it after the fact, but rarely want to engage in change. I’ll be the first to tell you that implementing an EMR requires change. Anyone who tells you otherwise probably has something to sell you. Certainly some EMR require more change than others, but they all require a change.

The American Medical News put out an interesting article discussing what they said would be 5 ways meaningful use will change your practice. Here’s their 5 ways and my commentary on each of the items:

Patients will be more involved in their care – Certainly meaningful use has some requirements that encourage the sharing of clinical information with the patient. I expect in future meaningful use stages we’ll see even more sharing of the clinical information with the patient. However, I don’t really see this sharing as translating to a more involved patient. Tons of people miss incorrect charges on their bank account and credit card statements and they have all that information. I’m sure the same will happen as patients get access to this information. Many won’t care to look and many of those that do look won’t have much of an idea what they’re looking at.

With this said, there is a general movement to the active and involved patient. Combine the easy access to health information (good and bad information I might add), the easy social interactions amongst patients (ie. asking your friends on Facebook), and other changes we see in society and the patients will be more involved going forward. I just don’t see meaningful use being a huge driver for this.

Doctors will find it easier to see how they’re doing – Ummm…this seems way off base to me. First, because it’s pretty hard to define “how they’re doing.” So, it makes it hard to talk about. Let’s just focus on the meaningful use measures. Does anyone really think that tracking the meaningful use measures is going to make a doctor better at what they’re doing? Can they really be used to measure how well a doctor is doing? I guess I just don’t think meaningful use is the right “report card” for doctors.

Physicians will collaborate more with other doctors – Stage 1 definitely does little to help this happen more efficiently. We’ll see if stage 2 or 3 takes it much farther. Although, if stage 3 takes it too far, I imagine many will opt out of showing meaningful use for stage 3 since the payouts are so small at the end of the EHR incentive money.

Long term, having an EMR will facilitate collaboration and information sharing amongst doctors. However, we don’t have the highways for that information built yet.

Physicians will pinpoint practice inefficiencies – This feels a little like the second one to me. However, it’s worth also pointing out that I think it would be a very difficult argument to make that meaningful use somehow makes a practice more efficient. I could certainly make an argument (which I’m sure many would love to argue against) that an EMR can make a clinic more efficient, but not meaningful use.

Physicians will need a firmer grip on data security – MU stage 1 has little HIPAA requirements and I don’t expect MU stage 2 and 3 to change that. There are some privacy and security requirements in the EHR certification that try and take data security and privacy in an EMR to the next level. Also, the HITECH act has provided some “teeth” to the enforcement of HIPAA which it never had before. I still think we need a few more clinics to get “bitten” by it to really understand what the requirements are going to be and how they’re going to enforce it.