Welcome to EMR and EHR

I find it interesting that I was sent another EMR YouTube video. No doubt YouTube can be a great tool for getting the word out, but so far the views on EMR videos are pretty low. However, I must admit that this video by GE Healthcare is much more interesting than the previous meaningful use video I posted. Plus, they focus on physicians number 1 concern: productivity and reimbursement. Take a look for yourself.

We’re getting more and more meaningful use details each day. No one should say that there isn’t a lot of information out there about meaningful use. Yet, I’m guessing there are still a LOT of physicians who still know little about meaningful use. McKesson’s even created this YouTube video explaining the Meaningful Use Final Rule. I can think of a few million YouTube videos I’d rather watch, but if you prefer video to reading, this video does give a general overview of many of the meaningful use final rule details:

UPDATE: Check out another meaningful use video that is definitely more exciting than the previous video (albeit with a little less content). However, it’s under 3 minutes and has music to keep it light and interesting. Thanks for sharing it Michelle. Although, I do wish I could embed the video on here.

A recent Information Week article on EHR adoption had the following quote:

“I think the number one driver [of ambulatory EHR adoption] is the change in reimbursement, the fact that it is becoming so complicated to document the process of care to get paid by the government as well as commercial payers,” said Nancy Fabozzi, a senior industry analyst at Frost & Sullivan and the report’s author. “Everybody thinks that fee-for-service is doomed and we have to have a new system of reimbursing physicians for the quality of care instead of the quantity of care because costs are exploding.”

In an interview with InformationWeek, Fabozzi said another reason for the adoption of ambulatory EHRs is that many providers have practice management systems that are old and need to be updated as they move to ICD-10 and HIPAA 5010 requirements.

It won’t be news to most of you that it’s not government incentive that is driving adoption of EHR software. The market forces are much stronger than any sort of stimulus. Although, the retarding forces of an unknown stimulus are starting to wear off and we should see EHR adoption pick up again soon.

Today we got news of the new ONC-ATCB EHR certifying bodies: CCHIT and Drummond Group. However, this is really just the start of the EHR certifying bodies. ONC released that “Applications for additional ONC-ATCBs are also under review.”

One of those possible additional ONC-ATCB EHR certifying bodies is Weno Healthcare. This EMR Daily News guest blog post (Thanks Michelle for pointing it out) asserts that Weno Healthcare has submitted their application to be an ONC-ATCB EHR Certifying body. They also offer this interesting insight:

Until recently, only one body was promoted to do this testing and certification. Because of no competition, their prices were out of the ballpark for smaller technology companies who may have built the better and cheaper mouse trap for doctors and hospitals, but could not afford the fees for certification. The technology companies that certified their products earlier are not considered certified by the new rules today, so all technology vendors must go through an ONC-ATCB in order to be re-tested and certified, if they choose to do so.

If Weno is approved as an ONC-ATCB, more technology vendors can afford the testing and certification fees. Weno savings can be as much as $19,000 for complete EHRs. These savings will certainly provide physicians and hospitals with more cost effective certified technology options to choose from. Again, competition is a good thing because it brings prices down and quality up.

Comparing the Weno Healthcare EHR certification price above with the CCHIT and Drummond Group EHR Certification prices, it’s going to be really interesting. That puts the costs of EHR certification (not counting software development costs) at:
Weno Healthcare: $14,000-18,000
Drummond Group: $19,500
CCHIT: $33,000

Of course, this assumes that Weno Healthcare becomes an ONC-ATCB and that the prices don’t change. I won’t be surprised if they do change. Plus, there could be other EHR certifying bodies.

There are a TON of meaningful use resources for those physicians and clinics interested in showing meaningful use of an EMR in order to get the EMR stimulus money. Here’s one such resource that I thought gave a nice summary of what’s required. Here’s a small sample of the content they offer about meaningful use:

Core Set Measures

• Use CPOE (Computerized Physician Order Entry) to order medications for more than 30% of all unique patients with at least one medication in their medication list.
• Enable drug-drug and drug-allergy interaction check functionality on the EHR for the entire reporting period.*
• Maintain an up-to-date problem list of current diagnoses for 80% of all patients. If there are no problems, indicate no problems are known.
• Maintain an up-to-date list of active medications for 80% of all patients.
• Maintain an up-to-date problem list of medication allergies for 80% of all patients.
• Generate and transmit prescriptions electronically for 40% of prescriptions written by the provider.
• Record demographics for at least 50% of patients.*
• Record and chart changes in vital signs for at least 50% of patients.*
• Record smoking status for 50% of patients 13 and older.*
• Report ambulatory clinical quality measures to CMS.*
• Implement one clinical decision support rule relevant to the provider’s specialty.
• Provide at least 50% of patients with an electronic copy of their health information, upon request, within 3 business days.*
• Provide at least 50% of patients with clinical summaries of their office visit within 3 business days.*
• Perform at least one test of the certified EHR technology’s capacity to electronically exchange key clinical information.*
• For the EHR and its related IT network, conduct a security risk analysis and implement security updates as necessary; correct security deficiencies.*

Menu Set Measures

• Enable drug-formulary checking functionality and have access to a formulary for the EHR reporting period.*
• Incorporate clinical lab-test results into the EHR as structured data for at least 40% of all lab test results.*
• Generate at least one report listing patients with a specific condition.*
• Send reminders to 20% of all patients, 65 years or older, per patient preference for follow-up care.*
• Provide at least 10% of all unique patients timely access to health information within 4 business days of the information being available to the provider.*
• Provide patient-specific education resources to at least 10% of all unique patients.*
• Perform medication reconciliation at least 50% of the time for patients transitioned from another setting of care.
• Provide a summary care record for at least 50% of patients for patients being transitioned to another setting of care.
• Perform at least one test of the certified EHR’s capability to submit electronic data to immunization registries.*
• Perform at least one test of the certified EHR’s capability to submit syndromic surveillance data to public health agencies.*

*These functions may be performed by nursing, administrative or IT staff

It is expected that EHR vendors will provide the capability to generate much of the above mentioned information within their software and they will also assist physicians in conducting data exchange testing.

Anthony sent me the following slides which I think tell a really interesting story about EHR (or maybe I should say lack of EHR). I’m sure many of you will enjoy it.

The Washington Times recently had an article by Tevi Troy and Dr. Jason D. Fodeman about the EMR Stimulus program which talks about how the program might be counterproductive to its goal. The final paragraphs are an interesting perspective:

Unfortunately, Congress and the administration have decided to prioritize “getting it done” over “getting it right.” Other than being able to bring those signs saying “Project funded by the American Recovery and Reinvestment Act” that pop up across the nation’s highways to our hospitals sooner, there does not appear to be much benefit from this approach.

It will take much more than bombarding hospitals with extra computers and complicated, expensive software for health information technology to attain its true promise. It will require the right computers with the right software with properly trained support staff and physicians who know how to use them. All this takes time to establish and time to work out the kinks.

Unfortunately, for whatever reason, the administration is unwilling to devote the time and would prefer to roll the dice and pick up the pieces later. The administration’s rush to establish an interoperable health information technology network may very well prove counterproductive. It easily could waste money, endanger patients and, possibly, do irreparable harm to the technology’s reputation.

I’ve been preaching some of these things for a while, but it’s interesting that the mainstream media is finally starting to pick up the story.

I’d only caution that we not confuse the EMR stimulus with EMR. EMR is no doubt the future of healthcare IT. It’s just important to consider if EMR stimulus is the right approach to getting people to use as the article says “the right computer with the right software.”

It seems like about every 6 months some new organization comes out with a new EMR buying guide. Physicians are looking for every way possible to narrow down the search amongst the 300+ EMR vendors.

Today David Swink sent me this new EMR Buyer’s Guide that InformationWeek is planning to put together. Unfortunately, they don’t really say how much they plan to charge for the EMR buyer’s guide or whether they’re going to get paid by the EMR vendors for the referral or what. We’ll see what they actually put together.

It’s just amazing the prices that many of these EMR buying guides charge for the information or even to be listed in the EMR buying guide. I’m not against people applying a business model to get paid for the work they do. It’s just that far too many of these guides charge a lot more than the value they actually provide to the user.

Plus, there are a number of free EMR selection services which I think do a better job than all of the EMR buyer’s guides I’ve seen. EMR Consultant and Medical Software Advice being 2 examples. They have a larger (often MUCH larger) database of EHR vendors to choose from, and they narrow that list down better than most of the EMR buying guides. Oh yes, did I say they’re FREE.

Just be careful what you buy. You don’t always get what you pay for.

It’s been a couple weeks since the news came out that Microsoft was shutting down its operations and sales for Amalga HIS. It always felt awkward for me to see Microsoft purchasing a software that was so specific. It just didn’t make sense to me for Microsoft to go after this type of specific product.

John over at Chilmark Research has a good post with his reasons why Amalga didn’t work well for Microsoft. I’m still pondering his comment that the EMR market is mature. However, his take away is a very good one:

Performing a viability assessment on a potential vendor may not reduce one’s risk. Even a big, viable company such as Microsoft may change its mind on occassion and chose to exit a market.

The only clarification I’d make is that a viability assessment does not equal evaluating if the company is big and viable. I cover this topic in my EMR selection e-Book and in these two posts. Not to mention this post on open source (free) EMR software viability.

I think the viability assessment is useful and essential. Just don’t make the simple assumption that large means viable. Ask Misys users about that one.

In another great comment from BobbyG (who works for a REC), he talks about the realization that states have the option to opt out of doing the Medicaid part of the EMR stimulus if they want. The following is the full explanation of the discovery and why they’d make such a decision. Plus, it highlights the challenge of understanding all the regulations around the HITECH act.

Here’s just one example of the difficulty you run across. Yesterday we were on a CMS conference call MU incentives presentation in which they said that states’ participation on the Medicaid side was “voluntary.”

We all went “WHAT?! How did we miss that?”

Sure enough: on the CMS website you see “The Medicaid EHR incentive program is voluntarily offered and administered by States and territories. States can start offering their program to eligible professionals (EPs) as early as 2011″

“voluntarily”, “can start”

Not “shall” or “must”.

Now, we knew from the IRF that (paraphrasing here) “there is no statutory basis for the manner via which states disburse incentive payments” but it somehow escaped us that states could simply opt out entirely.

I went back to the ARRA legislation itself (on the assumption that the FR cannot, beyond operational implementation mechanics, mandate additional requirements not in the legislation). Beginning on page 375 you see “Subtitle B—Medicaid Incentives SEC. 4201. MEDICAID PROVIDER HIT ADOPTION AND OPERATION PAYMENTS; IMPLEMENTATION FUNDING.”

You get to page 380 and then only see stuff about the administrative and reporting “requirements” for states getting the “FFP” money (Federal Financial Participation).

And that’s it.

I searched ARRA from beginning to end and found NO explicit wording that states’ Medicaid participation is “voluntary.” You just have to infer it from the Section 4201 language.

What is one potential adverse upshot? Your REC could be signing up a boatload of providers coming in on the Medicaid side, and if your state opts out, well you now have what’s known as “Reputation Risk” writ large (not to mention a torpedo below the waterline in your Ops plan and its milestone payments assumptions).

Why would a state opt out? Because they are only federally funded for 90% of their “reasonable” administrative expenses for the EHR incentive program. They have to find the other 10%. My state (NV) is currently wrestling with a three BILLION dollar budget gap. Similar relative woes exist elsewhere in statehouses (can you say KAHL-EE-FOR-NEEYA?).

You better know where your state stands before recruiting Medicaid providers if you’re a REC or a consultant or VAR, etc.