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Small Meaningful Use Penalties for Small Practices

Posted on February 17, 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.

Michelle has posted an interesting CMS analysis of the price of EHR penalties for physicians:

CMS reports that the majority of physicians who will be penalized this year for not having met MU requirements will lose less than $1,000 of their Medicare reimbursement; 34% of the penalties will be $250 or less, while 31% will exceed $2,000.

The adjustments will impact approximately 257,000 eligible providers. While no one likes losing money, the CMS penalty “stick” is pretty small compared to the overall cost of implementing an EHR.

Unfortunately her link to the CMS report seemed to be the wrong link. I’d love to dig into the 31% of doctors who will exceed $2000 in penalties. $2000 still isn’t very compelling to most doctors I know, but if it scales from there we could see how many doctors are really going to suffer from the EHR penalties.

What’s also not clear to me is if this includes the PQRS penalties as well. All of the penalties start to add up. I also heard one doctor talk about the feared 22% Medicare cut that’s been delayed for a decade or so (I lose track of the number of years). I’ll be surprised if those cuts aren’t delayed again, but it’s interesting that many doctors fear these cuts even if they’re likely to be delayed. Perception is still very important.

Back to the meaningful use penalties, $1000 penalty is not something most doctors will bat an eye at. Even those who have an EHR are opting out of meaningful use stage 2. The math doesn’t work out for small practices. $1000 of penalties certainly won’t balance the equation either. I expect a very small number of small practices to do meaningful use stage 2. Hospitals on the other hand are a different story.

Teddy Roosevelt and Gerald Ford Quotes

Posted on February 16, 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.

I thought it would be fun to look at some quotes from Presidents on President’s day that might inspire you. I hope you enjoy the following quotes.
Teddy Roosevelt - EMR and EHR

Gerald Ford - EMR and EHR

Telehealth, or ‘How to Ditch the Waiting Room’

Posted on February 13, 2015 I Written By

The following is a guest blog post by Ryan Nelson, Director of Business Development for Medical Web Experts.

Navigating the doctor’s office for a non-emergency can feel like getting lost in a quagmire of lengthy routines. For those who choose to forego the experience for as long as possible, haphazardly browsing WebMD in the middle of the night is no better. This could all change soon.

Telemedicine is on the rise as health insurers and employers have become more willing to pay for online video consultations in recent years. Convenience (imagine not having to leave the comfort of your home for every service!) and positive health outcomes – not to mention significant cost savings for both employers and patients – are propelling online video consultations to the forefront of healthcare strategies.

Convenience
People don’t like driving far, and they don’t like spending 45 minutes in a waiting room only to be discharged in under 15. The average wait time for a doctor’s appointment is 20 days in the US. This is more than enough time to deter patients from booking appointments for conditions that could be minor. Doctors usually don’t get reimbursed for time spent taking phone calls, so they often nix the medium altogether. Virtual doctor visits can fulfill patients’ need for instantaneous advice, closing a potentially dangerous communication gap while opening a new business opportunity for healthcare professionals.

A recent Harris Poll survey commissioned by Amwell found that around 40% of consumers would opt for video appointments for both antibiotics and birth control prescriptions, while at least 70% would rather have an online video visit to obtain a prescription than travel to their doctor’s office. Telehealth also offers a good solution for patients with mobility issues or chronic conditions, and it gives patients and doctors in rural or remote communities more options for receiving and dispensing care.

Health Outcomes
Biomed Central’s systematic review of telehealth service studies revealed that health outcomes for telehealth and in-person appointments are usually similar. About one-third of studies showed improved outcomes and only two indicated that telehealth was less effective. One way that online video appointments can improve health outcomes for the general population is to filter out minor health concerns and free up ER staff to deal with more serious ailments in-house. Additionally, video consultations can make it easier for physicians to track the recovery of discharged patients and to monitor patient adherence in a time-sensitive manner.

Cost Savings
The Amwell survey revealed that 64% of patients are willing to attend virtual appointments, challenging the dated assumption that in-person interactions tend to be perceived as a better experience. Contributing to this popularity is the fact that virtual appointments cost much less than an ER visit and are cheaper than an urgent care center or most face-to-face consults, generally figuring in around $40 to $50.

Biomed Central also found that out of 36 studies, nearly two-thirds showed cost savings for employers and patients. Meanwhile, Towers Watson predicted that the number of employers offering telemedicine will increase by 68% in 2015, which would result in $6B in employer savings.

Consumer Concerns
Consumers are concerned about how doctors can thoroughly examine patients through video, according to Amwell. However, the proliferation of self-monitoring mobile devices that can be used in conjunction with video consultations suggests that doctors may be able to get much of the information they need online. Besides, it can be argued that during most medical appointments a doctor doesn’t have much time to perform a comprehensive examination or truly get to know a patient.

Amwell subjects also questioned how a patient can be certain that he or she is speaking to a real doctor; however, this can easily be addressed by medical web platforms that thoroughly screen physicians and can thus provide adequate proof of their qualifications.

Digital Relationships
Research has shown that online video communication improves patient satisfaction and increases efficiency and access to healthcare for all demographics, at all times. While the medium appeals to people across all age groups, it especially appeals to younger, tech-savvy patients. This demographic tends to prefer instantaneous communication for non-emergencies and is generally comfortable communicating despite physical distance.

Consumers already use technology to communicate with their friends and families. Finally, doctors – another one of every person’s most intimate relationships – can join the ranks.

References:
Amwell
Biomed
Towers Watson

Restructure and Reform Meaningful Use: Here’s a Way

Posted on February 12, 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.

It’s no secret that ONC’s meaningful use program’s a mess. I’m not sure there is an easy way out. In some respects, I wish they would go back and start over, but that’s not going to happen. They could do something to see daylight, but it won’t be either easy or simple. As I‘ll outline, ONC could adopt a graduated system that keeps the MU standards, includes terribly needed interoperability and usability standards, but does not drive everyone crazy over compliance.

MU’s Misguided Approach

ONC has spent much time and money on the MU standards, but has painted itself into a corner. No one, vendors, practioners or users is happy. Vendors see ONC pushing them to add features that aren’t needed or wanted. Practioners see MU imposing costs and practices that don’t benefit them or their patients. Users see EHRs as demonic Rube Goldberg creations out to frustrate, confuse and perplex. To boot, ONC keeps expanding its reach to new areas without progress on the basics.

Most the MU criticisms I’ve seen say MU’s standards are too strict or too vague. Compliance is criticized for being too demanding or not relevant. Most suggested cures tinker with the program: Eliminate standards or delay them. I think the problems are both content and structure. What MU needs is a return to basics and a general restructuring.

Roots of the MU Program’s Problems

It’s easy to beat up on ONC’s failures. Almost everyone has a pet, so I’ll keep mine short.

MU1: Missed Opportunities. MU’s problems stem from its first days. ONC saw EHRs as little more than database systems that stored and retrieved encounters. Data sharing only this:

Capability to exchange key clinical information (for example, problem list, medication list, medication allergies, diagnostic test results), among providers of care and patient authorized entities electronically.

Compliance only required one data exchange attempt. ONC relied on state systems to achieve interoperability. Usability didn’t exist.

MU2: Punting the Problems. ONC’s approach to interoperability and usability was simple. Interoperability was synonymous with continuity of care and public health reports. Every thing else was put off for future testing criteria.

ONC’s usability approach was equally simple. Vendors defined their usability and measurement. The result? Usability’s become a dead topic.

Interoperability

ONC has many good things to say about the need for interoperability. Its recent Roadmap is thoughtful and carefully crafted. However, the roadmap points out just how poor a job ONC has done to date and it highlights, to me, how much ONC needs to rethink its entire MU approach.

Changing ONC

In one of his seminal works on organizations, C. Northcote Parkinson said it’s almost impossible to change a failing organization. His advice is to walk away and sew salt. If you must persist, then you should adopt the heart of a British Drill Sergeant, that nothing is acceptable. Alas, only Congress can do the former and I’m way too old for military service, so I will venture on knowing it’s probably foolhardy, but here goes.

New Basic Requirements

A better approach to MU’s core and menu system would allow vendors to pick and choose the features they want to support, but require that all EHRs meet four basic standards:

  1. Data Set. This first standard would spell out in a basic, medical data set. This would include, for example, vitals, demographics, meds, chief complaints, allergies, surgeries, etc.
  2. Patient ID. A patient’s demographics would include a unique patient identifier. ONC can use its new freedom in this area by asking NIST to develop a protocol with stakeholders.
  3. Interoperability. EHRs would have to transmit and receive, on demand, the basic data set using a standard protocol, for example, HL7.
  4. Usability. Vendors would have to publish the results of running their EHR against NIST’s usability standard. This would give users, for the first time, an independent way to compare EHRs’ usability.

All current EHRs would have to meet these criteria within one year. Compliance would mean certification, but EHRs that only met these criteria would not be eligible for any funding.

Cafeteria Program. For funding, vendors would have to show their EHR supported selected MU2 and MU3 features. The more features certified, the more eligible they’d be for funding.

Here is how it would work. Each MU criteria would have a one to ten score. To be eligible for funding, a product would have to score 50 or more. The higher their score, the higher their funding eligibility.

Provider Compliance. Providers would have a similar system. ONC would assign scores of one to ten for each utilization standard. As with vendors, implementing organizations would receive points for each higher utilization level. That is, unlike current practice, which is all or nothing, the more the system is used to promote MU’s goals the higher the payments. This would permit users to decide which compliance criteria they wanted to support and which they did not.

Flexibility’s Advantages

This system’s flexibility has several advantages. It ends the rigid nature of compliance. It allows ONC to add new criteria as it sees fit giving it freedom to add criteria as needed or to push the field.

It achieves a major advancement for users. It not only tells users how products perform, but it also lets them choose those that best fit their needs.

Vendors, too, benefit from this approach. They would not only know where they stood vs. the competition, but would also be free to innovate without having to include features they don’t want.

FTC Gingerly Takes On Privacy in Health Devices (Part 2 of 2)

Posted on February 11, 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.

The first part of this series of articles laid out the difficulties of securing devices in the Internet of Things (particularly those used in the human body). Accepting that usability and security have to be traded off against one another sometimes, let’s look at how to make decisions most widely acceptable to the public.

The recent FTC paper on the Internet of Things demonstrates that they have developed a firm understanding of the problems in security and privacy. For this paper, they engaged top experts who had seen what happens when technology gets integrated into daily life, and they covered all the issues I know of. As devices grow in sophistication and spread to a wider population, the kinds of discussion the FTC held should be extended to the general public.

For instance, suppose a manufacturer planning a new way of tracking people–or a new use for their data–convened some forums in advance, calling on potential users of the device to discuss the benefits and risks. Collectively, the people most affected by the policies chosen by the manufacturer would determine which trade-offs to adopt.

Can ordinary people off the street develop enough concerned with their safety to put in the time necessary to grasp the trade-offs? We should try asking them–we may be pleasantly surprised. Here are some of the issues they need to consider.

  • What can malicious viewers determine from data? We all may feel nervous about our employer learning that we went to a drug treatment program, but how much might the employer learn just by knowing we went to a psychotherapist? We now know that many innocuous bits of data can be combined to show a pattern that exposes something we wished to keep secret.

  • How guarded do people feel about their data? This depends largely on the answer to the previous question–it’s not so much the individual statistics reported, but the patterns that can emerge.

  • What data does the device need to collect to fulfill its function? If the manufacturer, clinician, or other data collector gathers up more than the minimal amount, how are they planning to use that data, and do we approve of that use? This is an ethical issue faced constantly by health care researchers, because most patients would like their data applied to finding a cure, but both the researchers and the patients have trouble articulating what’s kosher and what isn’t. Even collecting data for marketing purposes isn’t necessarily evil. Some patients may be willing to share data in exchange for special deals.

  • How often do people want to be notified about the use of their data, or asked for permission? Several researchers are working on ways to let patients express approval for particular types of uses in advance.

  • How long is data being kept? Most data users, after a certain amount of time, want only aggregate data, which is supposedly anonymized. Are they using well-established techniques for anonymizing the data? (Yes, trustworthy techniques exist. Check out a book I edited for my employer, Anonymizing Health Data.)

I believe that manufacturers can find a cross-section of users to form discussion groups about the devices they use, and that these users can come to grips with the issues presented here. But even an engaged, educated public is not a perfect solution. For instance, a privacy-risking choice that’s OK for 95% of users may turn out harmful to the other 5%. Still, education for everyone–a goal expressed by the FTC as well–will undoubtedly help us all make safer choices.

FTC Gingerly Takes On Privacy in Health Devices (Part 1 of 2)

Posted on February 10, 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.

Are you confused about risks to privacy when everything from keystrokes to footsteps is being monitored? The Federal Trade Commission is confused too. In January they released a 55-page paper summarizing results of discussions with privacy experts about the Internet of Things, plus some recommendations. After a big build-up citing all sorts of technological and business threats, the report kind of fizzles out. Legislation specific to the IoT was rejected, but several suggestions for “general privacy legislation” such as requiring security on devices.

Sensors and controls are certainly popping up everywhere, so the FTC investigation comes at an appropriate time. My senator, Ed Markey, who has been a leader in telecom and technology for decades in Congress, recently released a report focused on automobiles. But the same concerns show up everywhere in various configurations. In this article I’ll focus on health care, and on the dilemma of security in that area.

No doubt about it, pacemakers and other critical devices can be hacked. It could be a movie: in Scene 1 a non-descript individual is moving through a crowded city street, thumbing over a common notepad. In Scene 2, later, numerous people fall to the ground as their pacemakers fail. They just had the bad luck to be in the vicinity of the individual with the notepad, who implanted their implants with malicious code that took effect later.

But here are the problems with requiring more security. First, security in computers almost always rests on encryption, which leads to an increase in the size of the data being protected. The best-known FTC case regarding device security, where they forced changes for cameras used in baby monitors, was appropriate for these external devices that could absorb the extra overhead. But increased data size leads to an increase in memory use, which in turn requires more storage and computing power on a small embedded device, as well as more transmission time over the network. In the end, devices may have to be heavier and more costly, serious barriers to adoption.

Furthermore, software always has bugs. Some lie dormant for years, like the notorious Heartbleed bug in the very software that web sites around the world depend on for encrypted communications. To provide security fixes, a manufacturer has to make it easy for embedded devices to download updated software–and any bug in that procedure leaves a channel for attack.

Perhaps there is a middle ground, where devices could be designed to accept updates only from particular computers in particular geographic locations. A patient would then be notified through email or a text message to hike it down to the doctor, where the fix could be installed. And the movie scene where malicious code gets downloaded from the street would be less likely to happen.

In the next part of this article I’ll suggest how the FTC and device manufacturers can engage the public to make appropriate privacy and security decisions.

The Paperless Healthcare Startup – lol

Posted on February 9, 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.

One of my healthcare IT friends posted this picture and caption to their Facebook page:

Paper Regulation in a Healthcare World

The past 8 months of my life can be summed up in just under 2k pages of internal documentation and reporting evidence. I’ll be so happy when this is over. Two days and counting…

Yeah, federal regs don’t choke healthcare startups at all. < /sarcasm>

I asked about which regulations (there are so many to choose from) and she said ISO and they also were lucky enough to get slapped with an FDA audit as well.

While not all regulation is bad and in fact some regulations is good, I’m pretty sure that these notebooks will almost never be cracked open. They’ll gather dust on a shelf. Of course, many would argue that the real value was the evaluation process that the company went through in creating these documents.

Regardless, this image is a good illustration of why many tech folks don’t get into healthcare.

Partners Health Care Not to Expand – Can’t We All Just Get Along?

Posted on February 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.

So the deal is off for the mega-medical conglomerate that dominates Boston’s health care scene. Partners Healthcare, which came so close to buying up several competitors, got slammed by a newly installed attorney general and a judge presiding over the merger decision. So big is Partners in health care–and health care in the Boston market–that this news made the lead headline in the Boston Globe on January 30.

Partners may go ahead with the mergers and face a lawsuit, but my guess is that they’ll sense the trending of the political tides and back away. Everyone understands that dominant health care providers tend to raise costs–but what might we have lost in preventing the merger?
Read more..

ONC Healthcare Interoperability Roadmap Infographic

Posted on February 5, 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.

There’s been a lot of talk around the 10 year ONC Healthcare Interoperability Roadmap. I think it’s a really great thing that they’re helping to drive a lot more discussion around interoperability. I’m very interested in doing the same.

For those who want the cliff notes version of the interoperability roadmap, I think this infographic does a pretty good job summarizing it:
ONC Healthcare Interoperability Roadmap Infographic

What do you think of the roadmap? Is it all conjecture and not much substance or will it make a big difference?

#ICD10Matters Meme

Posted on February 4, 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.

I’d seen some tweets and other messages on social media about the #ICD10Matters tweetup that was happening today. It was organized by AHIMA and has HIM professionals all over the country reaching out to their representatives in Congress to encourage them to not delay ICD-10 again. You can see that the Twitter stream for #ICD10Matters has been very active. I’ll be interested to know how many senators take note of all these tweets.

Along with tweets to representatives in Congress, you also have people tweeting great ICD-10 content, but they’ve also started an #ICD10Matters meme with images talking about it. Here’s a look at some of the ones I’ve found entertaining:

I’m not sure how well these images will talk to congress, but they might be able to engage the mass of HIM professionals to engage on the topic. We’ll see the power of grumpy cat in action.