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Meaningful Use Is Dead?

Posted on January 29, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Over on EMR and HIPAA, I got the following passionate response on my post titled Meaningful Use Created A Big Need for Certified MAs that I thought many readers on this site would enjoy.

In the EP world, MU is dead. There are some larger groups, especially primary care still struggling to overcome the huge hurdles of MU2, but most I know have given up and running for the hills. There is a ginormous gap between what ONC is peddling in terms of numbers and real MU use.

This is good example of another hidden cost of trying to MU. We have some excellent MA’s, and I could not tell you which are and are not certified. Makes no difference. Sadly, CMS and ONC, do not realize that they are literally driving EPs from accepting Medicare patients, especially us specialists. And once we are gone, or severely limit new patients with Medicare, we are not coming back.

So the 17 times in 11 years fix for SGR, PQRS, VBM, MU, CPQ, ICD10, HIPAA, RAC audits, sequester cuts, etc. Its too much cost. clicking, paper work to take care of these patients. We actually had a serious discussion with our hospital about cutting back severely on doing Medicare total knees and hips next year due to all this. And the hospital initiated the conversation. So its not just us, even EHs are looking into this.

We all know that CMS and ONC want something, anything in terms of numbers to report anything to Congress, but this is the wrong way to do it. Again, everyone out there that is sitting in their cubicle Monday morning quarterbacking our care for these patients, will be very sad, very soon as we will just stop seeing them.

You can see by the numbers, if 250,000 EPs are taking the first MU hit this year, just wait until the rest give up. EPs can see that MU does not equate to better care, safer care, or more efficient care. We all may use an EHR, but could care less about attestations and audit risks and counting numerators/denominators forever. Again now that at least half the EPS are out, the rest will be right behind.

CMS and ONC need to realize that penalties NEVER work. Incentives like the heady days of MU1, got people to try EHR, but the costs are now piling up, big time. Everyone wants their piece of the pie. But as the incentives have gone away and the clerk like data entry has gone up, EPs have left the program. And are never, I mean never, coming back.

This provider makes an interesting assertion about meaningful use being dead. Do you think that MU is dead?

I thought this post’s timing was interesting given the announcement that CMS is changing the meaningful use stage 2 reporting period to 90 days. Correction…they intend to change it, but I think we all see that it’s going to happen. Just let the rule making process take it’s course.

Before this announcement, I would have largely agreed that meaningful use was pretty close to dead. I know some people have sifted through the meaningful use stage 2 attestations and have said it’s better than we thought, but I think those are the early birds and not the majority. With this announcement, I think the majority will take a much deeper look at taking on MU stage 2. If CMS can simplify some things, I could see many participating to get the incentive money, but to also avoid the penalties. Penalties aren’t the end all be all for doctors, but they represent a big chunk of money for many doctors.

I’d love to hear your thoughts. What are you seeing in the trenches?

ONC Annual Meeting – Who’s Going?

Posted on January 28, 2015 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

ONC’s Agenda – February 2-3, Washington, DC

Next Monday, ONC holds its annual meeting in downtown DC. I’m going, one small advantage of living here. Here’s the agenda. To see day two, click on the agenda header.

I’m particularly interested in these topics:

  • Adverse event reporting,
  • Interoperability standards,
  • Meaningful Use program’s future, and
  • Usability.

Looking at the agenda, I should stay busy with one exception. There isn’t much on usability. The word’s only on the agenda once. Not a surprise since ONC has pretty much relinquished any role to the vendors.

How important do you think the ONC meeting and also the ONC run Healthdatapalooza now that meaningful use has kind of run its course? Will these two meeting gain steam and influence or will organizations start to go other places? I’ll be interested to watch that trend as I attend the event.

If you can’t attend, you can follow on various webcasts and twitter. If you do plan to attend, I’d love to see you there. To email me, click on my name in my profile blurb, or at carl@ehrselector.com.

What Happens When An EHR Vendor is Acquired?

Posted on January 12, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

With meaningful use money running out, and as the EHR industry matures, we’re going to see more and more consolidation in the EHR market. Many EHR vendors are going to start running out of money. Other larger EHR vendors are going to want to try and buy up market share. In some ways this has already begun. See Greenway being purchased by Vitera Healthcare Solutions and Cerner acquiring Siemens to name some of the larger ones that have happened recently. Although, anyone that’s been a user of Bond EHR (people still miss that EHR software), Allscripts MyWay, Misys, etc etc etc knows the challenges of when your EHR vendor gets acquired.

While your EHR being acquired by another EHR vendor is almost never a good thing for your EHR software’s future, L Nelms visited this post on EMR and EHR News and offered an even worse story of an EHR being acquired and the fallout the doctors felt. I’ve removed the name of the vendors since the principle could apply to many vendors that get acquired.

After completing Stage one of Meaningful Use, I am now dropping out of the whole damn thing. This decision is based entirely on my continued dissatisfaction with the EMR program I chose. I started using EHR Vendor A in 2012. As many know, EHR Vendor A was subsequently bought by ABC corporation who refused to honor the original contract which promised no additional fees. ABC corporation, knowing that they had customers “right where they wanted them” — knowing that switching programs would incur tremendous costs and disruption to the practices’ work flow, immediately imposed a $250.00 monthly “support fee”, requiring automatic payments from the customers credit card. I do not know what constitutes “support” from this company, as I had problems with the program and attempted to contact them numerous times from Nov 19, 2014 to Dec 9, without a SINGLE reply in any form from them. On Jan 1, 2015, they increased this fee to $300.00.

They continue to inundate us with newsletters telling us how wonderful they are, including an alert urging us to “respond today” to arrange to get the new certified software installed. This was sent on Christmas Eve! They warned us repeatedly that we must be using the new software ON Jan 1,2015, in order to meet MU. What they didn’t mention until the day before the install, was that there is a “one-time installation fee of $99.00″ (charged immediately, of course, to you credit card).

I asked if I could do the install myself and was told “yes, but we’re not really charging for the install, we’re charging for the SQL server update (which actually can be done oneself ). But I was told I had to pay. And now, the new certified software, which is COMPLETELY different from the previous version, is a nightmare. It is agonizingly slow, painstakingly labor intensive, and heaven forbid I should require tech support who, on top of being nowhere to be found, are so disrespectful (the last one one I spoke to actually said — when I expressed my dissatisfaction with not being able to get my data when I terminate my contract — “well we didn’t force you to buy our program”

Which doesn’t explain why I feel so violated…..

I should clarify that my data from EHR Vendor A is “available”: after many cryptic replies from them over several days, I was finally told that I can access the data from the server, but then — and you all know the story– I must take out a second mortgage on my home to have the data converted to some semblance of a usable format. This may not be illegal (only because the the recklessness of the companies has not yet been regulated), but it is certainly of questionable ethicacy

I think this is a fear that many doctors have when selecting and purchasing their EHR software. It’s why many of them still choose to go with the big name EHR vendors. Stories like this one scare doctors away from a small EHR vendor with an uncertain future. Although, I’ve written previously about the uncertain future of large EHR vendors as well.

The EHR industry should do better than this. I hope this story is an aberration, but I’m afraid we’re going to see more and more stories like it as the EHR industry consolidates. There will still be many good EHR actors out there that are appalled by these stories like I am. Hopefully, more and more doctors will find those good actors who are sincere in their efforts to provide a quality product with a quality user experience for the doctor. They’re out there, but bad actors like what’s described above give the good apples a bad name.

The New Congressional Rider: Unique Patient ID Lemonade?

Posted on January 8, 2015 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

Note: Previous versions referred to Rand Paul as the author of the first congressional rider. That was in error. The first rider was authored by then Representative Ron Paul. I regret the error. CB

Last month, I posted that Ron Paul’s gag rule on a national patient identifier was gone. Shortly, thereafter, Brian Ahier noted that the gag rule wasn’t dead. It just used different words. Now, it looks as if we were both right and both wrong. Here’s why. Paul’s rider’s gone, but its replacement, though daunting, isn’t as restrictive.

The gag rules are appropriation bill riders. Paul’s, which began in 1998, was aimed at a HIPAA provision, which called for identifiers for:

…. [E]ach individual, employer, health plan, and health care provider for use in the health care system. 42 US Code Sec. 1320d-2(b)

It prohibited “[P]lanning, testing, piloting, or developing a national identification card.” This was interpreted to prohibit a national patient id.

As I noted in my post, Paul’s language was dropped from the CRomnibus appropriation act. Brian, however, found new, restrictive language in CRomnibus, which says:

Sec. 510. None of the funds made available in this Act may be used to promulgate or adopt any final standard under section 1173(b) of the Social Security Act providing for, or providing for the assignment of, a unique health identifier for an individual (except in an individual’s capacity as an employer or a health care provider), until legislation is enacted specifically approving the standard.

Gag Rule’s Replacement Language

Unlike Paul’s absolutist text, the new rider makes Congress the last, biggest step in a formal ID process. The new language lets ID development go ahead, but if HHS wants to adopt a standard, Congress must approve it.

This change creates two potential adoption paths. Along the first, and most obvious, HHS develops a mandatory, national patient ID through Medicare, or the Meaningful Use program, etc., and asks congress’ approval. This would be a long, hard, uphill fight.

The second is voluntary adoption. For example, NIST could develop a voluntary, industry standard. Until now, Paul’s rider stopped this approach.

NIST’s a Consensus Building Not a Rulemaking Agency

NIST’s potential ID role is well within its non regulatory, consensus standards development mandate. It could lead a patient ID building effort with EHR stakeholders. Given the high cost of current patient matching techniques, stakeholders may well welcome a uniform, voluntary standard. That would not solve all interoperability problems, but it would go a long way toward that end.

Congress has loosened its grip on a patient ID, now its up to ONC, NIST, etc., to use this new freedom.

Assessment Released of Health Information Exchanges (Part 1 of 2)

Posted on January 6, 2015 I Written By

Andy Oram is an editor at O'Reilly Media, a highly respected book publisher and technology information provider. An employee of the company since 1992, Andy currently specializes in open source, software engineering, and health IT, but his editorial output has ranged from a legal guide covering intellectual property to a graphic novel about teenage hackers. His articles have appeared often on EMR & EHR and other blogs in the health IT space. Andy also writes often for O'Reilly's Radar site (http://radar.oreilly.com/) and other publications on policy issues related to the Internet and on trends affecting technical innovation and its effects on society. Print publications where his work has appeared include The Economist, Communications of the ACM, Copyright World, the Journal of Information Technology & Politics, Vanguardia Dossier, and Internet Law and Business. Conferences where he has presented talks include O'Reilly's Open Source Convention, FISL (Brazil), FOSDEM, and DebConf.

Like my Boston-area neighbors who perennially agonize over the performance of the Red Sox, healthcare advocates spend inordinate amounts of time worrying about Health Information Exchanges (HIEs). Will the current round of exchanges work after most previous attempts failed? What results can be achieved from the 564 million dollars provided by the Office of the National Coordinator since 2009? Has the effort invested by the government and companies in the Direct project paid off, and why haven’t some providers signed up yet?

I too was consumed by such thoughts when reading a reported contracted by the ONC and released in December, “HIE Program Four Years Later: Key Findings on Grantees’ Experiences from a Six-State Review. Although I found their complicated rating system a bit arbitrary, I found several insights in the 42-page report and recommend it to readers. I won’t try to summarize it here, but will use some of the findings to illuminate–and perhaps harp on–issues that come up repeatedly in the HIE space.
Read more..

Looking Back at 2014: Thermidor for Health Care Reform?

Posted on December 29, 2014 I Written By

Andy Oram is an editor at O'Reilly Media, a highly respected book publisher and technology information provider. An employee of the company since 1992, Andy currently specializes in open source, software engineering, and health IT, but his editorial output has ranged from a legal guide covering intellectual property to a graphic novel about teenage hackers. His articles have appeared often on EMR & EHR and other blogs in the health IT space. Andy also writes often for O'Reilly's Radar site (http://radar.oreilly.com/) and other publications on policy issues related to the Internet and on trends affecting technical innovation and its effects on society. Print publications where his work has appeared include The Economist, Communications of the ACM, Copyright World, the Journal of Information Technology & Politics, Vanguardia Dossier, and Internet Law and Business. Conferences where he has presented talks include O'Reilly's Open Source Convention, FISL (Brazil), FOSDEM, and DebConf.

As money drains out of health care reform, there are indications that the impetus for change is receding as well. Yet some bright spots in health IT remain, so it’s not yet time to announce a Thermidor–the moment when a revolution is reversed and its leaders put to the guillotine. Let’s look back a bit at what went right and wrong in 2014.
Read more..

Who is Adopting EHRs and Why: ONC Turns up Some Surprises

Posted on December 15, 2014 I Written By

Andy Oram is an editor at O'Reilly Media, a highly respected book publisher and technology information provider. An employee of the company since 1992, Andy currently specializes in open source, software engineering, and health IT, but his editorial output has ranged from a legal guide covering intellectual property to a graphic novel about teenage hackers. His articles have appeared often on EMR & EHR and other blogs in the health IT space. Andy also writes often for O'Reilly's Radar site (http://radar.oreilly.com/) and other publications on policy issues related to the Internet and on trends affecting technical innovation and its effects on society. Print publications where his work has appeared include The Economist, Communications of the ACM, Copyright World, the Journal of Information Technology & Politics, Vanguardia Dossier, and Internet Law and Business. Conferences where he has presented talks include O'Reilly's Open Source Convention, FISL (Brazil), FOSDEM, and DebConf.

A high-level view of the direction being taken by electronic health records in the U.S. comes from a recent data brief released by the Office of the National Coordinator. Their survey of physician motivations for adopting EHRs turns up some puzzling and unexpected findings. I’ll look at three issues in this article: the importance of Meaningful Use incentives and penalties, the role of information exchange, and who is or is not adopting EHRs.

Incentives and Penalties
The impact of the Meaningful Use bribes–sorry, I meant incentive payments–in the HITECH act are legendary: they touched off a mad rush to adopt technology that had previously aroused only tepid interest among most physicians, because they found the EHRs outrageously expensive, saw no advantage to their use, or just didn’t want to leave the comfort zone of pen and paper. The dramatic outcome of Stage 1, for instance, can be seen in the first chart of this PDF.

This month’s data brief reconfirms that incentives and penalties played a critical role during the period that Meaningful Use has been in play. In the brief’s Figure 3, incentives and penalties topped the list of reasons for adopting records, with nothing else coming even close (although the list was oddly chosen, leaving out credible reasons such as “EHRs are useful”).

The outsized role payments play is both strange and worrisome. Strange, because the typical $15,000 paid per physician doesn’t even start to cover the costs of converting from paper to an EHR, or even from one EHR to another. Worrisome, because the escalator (a favorite metaphor of former National Coordinator David Blumenthal) on which payments put physicians is leveling off. Funding in the HITECH act ends after Stage 3, and even those payments will be scrutinized by the incoming budget-conscious Congress.

In addition, Stage 2 attestations have been dismally low. Critics throughout the industry, smelling blood, have swooped in to call for scaling back, to suggest that meaningful use provisions be eased or weakened, or just to ask for a more concentrated focus on the key goal of interoperability.

The ONC knows full well that they have to cut back expectations as payments dry up, although penalties from the Center for Medicare & Medicaid Services can still provide some leverage. Already, the recent House budget has level-funded the ONC for next year. Last summer’s reorganization of the ONC was driven by the new reality. Recent initiatives at the ONC show a stronger zeal for creating and urging the adoption of standards, which would be consistent with the need to find a role appropriate to lean times.

Health Information Exchange
I am also puzzled by the emphasis this month’s data brief puts on health information exchange. Rationally speaking, it would make perfect sense for physicians to ramp up and streamline the sharing of patient data–that’s exactly what all the health care reformers are demanding that they do. Why should somebody ask a patient to expose himself to unnecessary radiation because an X-Ray hasn’t been sent over, or try to treat someone after surgery without knowing the discharge plan?

Actually, most physicians would. That’s how they have been operating for decades. Numerous articles find that most physicians don’t see the value of information exchange, and can profit from their ignorance of previous tests and treatments the patient has received.

And that’s probably why, after taking hundreds of millions of dollars from governments, the heavy-weight institutions called Health Information Exchanges have repeatedly thrown in the towel or been left gasping for breath. At least two generations of HIEs have come and gone, and the trade press is still searching for their value.

So I’m left scratching my head and asking: if doctors adopt EHRs for information exchange, are they getting what they paid for? Redemption may have arrived through the Direct project, an ONC-sponsored standard for a low-cost, relatively frictionless form of data exchange. Although the original goal was to make HIE as simple as email, the infrastructure required to protect privacy imposes more of a technical burden. So the ONC envisioned a network of Health Information Service Provider (HISP) organizations to play the role of middleman, and a number are now operating. According to Julie Maas of EMR Direct, nearly half a million people were using Direct in July 2014, and the number is expected to double the next time statistics are collected next February.

So far, although isolated studies have shown that HIEs improve outcomes and reduce costs, we haven’t seen these effects nationwide.

What Hinders Adoption
Some of the most intriguing statistics in the data brief concern who is adopting EHRs and what holds back others from doing so. The main dividing line is simply size: most big organizations have EHRs and most small ones don’t.

I have explored earlier the pressures of health care reform on small providers and the incentives to merge. Health care technology is a factor in the consolidation we’re seeing around the country. And we should probabaly look forward to more.

Americans have trouble feeling good about consolidation in any field. We’re nostalgic for small-town proprietors like the pharmacist in the movie It’s a Wonderful Life. We forget that the pharmacist in that movie nearly killed someone by filling a prescription incorrectly. In real life, large organizations can pursue quality in a host of ways unavailable to individuals.

One interesting finding in the data brief is that rural providers are adopting EHRs at the same rate as urban ones. So we can discard any stereotypes of country hick doctors letting teenagers set up the security on their PCs.

Lack of staff and lack of support are, however, major barriers to adoption. This is the last perplexing question I take from the data brief. Certainly, it can be hard to get support for choosing an EHR in the first place. (The Meaningful Use program set up Regional Extension Centers to partially fill the gap.) But after spending millions to install an EHR, aren’t clinicians getting support from the vendors?

Support apparently is not part of the package. Reports from the field tell me that vendors install the software, provide a few hours of training, and tip their hats good-bye. This is poetic justice toward physicians, who for decades have sent patients out weak and groggy with a prescription and a discharge sheet. Smart organizations set aside a major percentage of their EHR funding to training and support–but not everybody knows how to do this or has grasped the need for ongoing support.

I certainly changed some of my opinions about the adoption of EHRs after reading the ONC data brief. But the statistics don’t quite add up. We could use some more background in order to understand how to continue making progress.

Does Meaningful Use Inspire Innovative or Mediocre Systems?

Posted on December 12, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I was absolutely intrigued by Dr. Webster’s tweet about the impact of meaningful use (MU) and the types of systems it inspires. I think everyone would agree that MU has done nothing to inspire innovative EHR systems to be created and I think most would agree that it’s mostly fostered the creation of mediocre systems.

I’m not saying that meaningful use has no redeeming qualities. It definitely drove adoption of EHR software. Some of the meaningful use requirements like ePrescribing and CPOE were already moving forward for many organizations and meaningful use threw gas on those fires. I think those will turn out to be really beneficial components to meaningful use.

We could talk about the overall impact of MU (good or bad), but I’m not sure how productive of a conversation that would be. Meaningful Use is the reality of today. So, instead of focusing backwards on something we can’t change, I’m interested to think about what meaningful use could become. For all intents and purposes, that’s going to be called meaningful use stage 3 (unless ONC decides to spend time on a rebranding).

The key question: Could Meaningful Use inspire innovative EHRs and other innovative health IT?

While I’m skeptical of government regulation doing much for innovation, I think there’s a chance that this could happen. The key change will be that meaningful use needs to move away from its prescriptive approach and requirements. Innovation rarely comes from prescriptive approaches to anything.

Instead of being so prescriptive, meaningful use should focus on creating frameworks for which innovation can happen. My initial analysis of FHIR is that this is directionally right when it comes to inspiring innovation in healthcare IT. I need to dig into the details a bit more, but the concepts of creating an open framework for health IT companies to innovate on top of EHR data is what things like meaningful use should incentivize. Reimbursement should help to encourage this type of innovation. HIPAA should be clarified to support this type of innovation.

RHIR is just one example and I’m sure there are many others. It’s an open approach which encourages the right things while not damaging those for which it doesn’t make any sense. To me that’s the major difference between a prescriptive requirements list versus a framework oriented approach.

Do we really care that doctors game the system to be able to meet the 5% patient engagement requirement of meaningful use? What value does that provide the healthcare system if they’re not truly engaging? That’s too prescriptive. I’m all for patient engagement. Doctors are too. However, these prescriptive MU requirements just cause doctors to game the system as opposed to truly engage.

What do you think could be done with MU so that it inspires innovative EHRs instead of mediocre systems?

Open Source Electronic Health Records: Will They Support the Clinical Data Needs of the Future? (Part 1 of 2)

Posted on November 10, 2014 I Written By

Andy Oram is an editor at O'Reilly Media, a highly respected book publisher and technology information provider. An employee of the company since 1992, Andy currently specializes in open source, software engineering, and health IT, but his editorial output has ranged from a legal guide covering intellectual property to a graphic novel about teenage hackers. His articles have appeared often on EMR & EHR and other blogs in the health IT space. Andy also writes often for O'Reilly's Radar site (http://radar.oreilly.com/) and other publications on policy issues related to the Internet and on trends affecting technical innovation and its effects on society. Print publications where his work has appeared include The Economist, Communications of the ACM, Copyright World, the Journal of Information Technology & Politics, Vanguardia Dossier, and Internet Law and Business. Conferences where he has presented talks include O'Reilly's Open Source Convention, FISL (Brazil), FOSDEM, and DebConf.

Open source software missed out on making a major advance into health care when it was bypassed during hospitals’ recent stampede toward electronic health records, triggered over the past few years by Meaningful Use incentives. Some people blame the neglect of open source alternatives on a lack of marketing (few open source projects are set up to woo non-technical adoptors), some on conservative thinking among clinicians and their administrators, and some on the readiness of the software. I decided to put aside the past and look toward the next stage of EHRs. As Meaningful Use ramps down and clinicians have to look for value in EHRs, can the open source options provide what they need?

The oncoming end of Meaningful Use payments (which never came close to covering the costs of proprietary EHRs, but nudged many hospitals and doctors to buy them) may open a new avenue to open source. Deanne Clark of DSS, which markets a VistA-based product called vxVistA, believes open source EHRs are already being discovered by institutions with tight budgets, and that as Meaningful Use reimbursements go away, open source will be even more appealing.

My question in this article, though, is whether open source EHRs will meet the sophisticated information needs of emerging medical institutions, such as Accountable Care Organizations (ACOs). Shahid Shah has suggested some of the EHR requirements of ACOs. To survive in an environment of shrinking reimbursement and pay-for-value, more hospitals and clinics will have to beef up their uses of patient data, leading to some very non-traditional uses for EHRs.

EHRs will be asked to identify high-risk patients, alert physicians to recommended treatments (the core of evidence-based medicine), support more efficient use of clinical resources, contribute to population health measures, support coordinated care, and generally facilitate new relationships among caretakers and with the patient. A host of tools can be demanded by users as part of the EHR role, but I find that they reduce to two basic requirements:

  • The ability to interchange data seamlessly, a requirement for coordinated care and therefore accountable care. Developers could also hook into the data to create mobile apps that enhance the value of the EHR.

  • Support for analytics, which will support all the data-rich applications modern institutions need.

Eventually, I would also hope that EHRs accept patient-generated data, which may be stored in types and formats not recognized by existing EHRs. But the clinical application of patient-generated data is far off. Fred Trotter, a big advocate for open source software, says, “I’m dubious at best about the notion that Quantified Self data (which can be very valuable to the patients themselves) is valuable to a doctor. The data doctors want will not come from popular commercial QS devices, but from FDA-approved medical devices, which are more expensive and cumbersome.”

Some health reformers also cast doubt on the value of analytics. One developer on an open source EHR labeled the whole use of analytics to drive ACO decisions as “bull” (he actually used a stronger version of the word). He aired an opinion many clinicians hold, that good medicine comes from the old-fashioned doctor/patient relationship and giving the patient plenty of attention. In this philosophy, the doctor doesn’t need analytics to tell him or her how many patients have diabetes with complications. He or she needs the time to help the diabetic with complications keep to a treatment plan.

I find this attitude short-sighted. Analytics are proving their value now that clinicians are getting serious about using them–most notably since Medicare penalizes hospital readmissions with 30 days of discharge. Open source EHRs should be the best of breed in this area so they can compete with the better-funded but clumsy proprietary offerings, and so that they can make a lasting contribution to better health care.

The next installment of this article looks at current support for interoperability and analytics in open-source EHRs.

Meaningful Use Audits and the Inconsistent Appeals Process

Posted on November 6, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

If you haven’t had the pleasure of a meaningful use audit yet, consider yourself lucky. They are not pretty, but I’ve never met anyone who actually enjoys an audit. Turns out that meaningful use appeals are even worse than most audits. It’s likely because the meaningful use appeals process are so new and they haven’t figured out their processes. However, if you’re a clinic on the wrong side of a new process, that’s not much consolation.

Meaningful Use expert, Jim Tate, has a fascinating look into the inconsistency of meaningful use appeals. Here’s one story he shares that will kind of blow your mind (or at least annoy and scare you).

“Two Set of Rules”: You are not going to believe this one, but it is true. I was contacted last week by a large practice. Two of their physicians had failed audits. Both appealed and won with the statement from CMS: “This is the final determination notice regarding your recent appeal….Based on our review of your Appeal Filing Request, supporting documentation and the Program policies, we have accepted the documentation your provided to support your appeal. Therefore, CMS upholds your appeal.” Sounds great, doesn’t it? However, two months later they received this from CMS: “CMS has reopened the review of your appeal and supporting documentation along with others from your practice. The documentation provided….is unsufficient to support the appeal and CMS is reversing….the decision to uphold your appeal. As a result, the final CMS decision denies your appeal and upholds the adverse audit finding. This decision is not subject to further appeal.” Is it just me or it this a little bit on the crazy side? They received from CMS a “final determination” that their appeal was upheld and then two months were told the “final determination” was being undone, the appeal would now be denied and “this decision is not subject to further appeal.” Both of the letters were signed by the same CMS official. Is it just me or do we need a little sunlight on the inner workings of this process?

Jim is right that there should be a clear process for meaningful use audits and appeals. It’s interesting that Jim tried to go to DC to visit with CMS about the process. Unfortunately, his request was denied. There’s nothing worse than hitting a dead end and people aren’t willing to listen.

Hopefully CMS will hear this story and act. It’s not fair to any organization to get stuck in a bad process.