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Updated FAQs on Participation in EHR Incentive Programs

Posted on October 1, 2015 I Written By

John Lynn is the Founder of the 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 and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

To keep you informed of the latest information on the Medicare and Medicaid EHR Incentive Programs, CMS has recently updated three FAQs providing clarification on how to attest to certain objectives and measures.

(FAQ 9690) Question: When reporting on the Summary of Care objective in the EHR Incentive Program, which transitions would count toward the numerator of the measures?

Answer: A transition of care is defined as the movement of a patient from one setting of care (hospital, ambulatory, primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another. To count toward the Summary of Care objective for providers sharing access to an EHR, the transition or referral may take place between providers with different billing identities such as a different National Provider Identifier (NPI) or hospital CMS Certification Number (CCN) … Read the full FAQ

(FAQ 11984) Question: If an eligible professional (EP) in the EHR Incentive Programs is part of a group practice that has achieved ongoing submission to a public health agency (PHA), but the EP himself/herself did not administer any immunizations to any of the populations for which data is collected by their jurisdiction’s immunization registry during their EHR reporting period, can he/she attest to meeting the measure since they are part of the group practice that is submitting data to the registry?

Answer: If a provider does not administer immunizations, they should not attest to the measure; they must claim the exclusion. If a provider does administer immunizations, but did not have any for a particular EHR reporting period, they are not required to claim the exclusion as long as they have done any necessary registration and testing and are reporting when they do have the data to report.

(FAQ 8231) Question: While the denominator for measures used to calculate meaningful use in the EHR Incentive Programs is restricted to patients seen during the EHR reporting period, is the numerator also restricted to activity during the EHR reporting period or can actions for certain meaningful use measures be counted in the numerator if they took place after the EHR reporting period has ended?

Answer: The criteria for a numerator is not constrained to the EHR reporting period unless expressly stated in the numerator statement for a given meaningful use measure. The numerator for the following meaningful use measures should include only actions that take place within the EHR reporting period: Preventive Care (Patient Reminders) and Secure Electronic Messaging.

For all other meaningful use measures, the actions may reasonably fall outside the EHR reporting period timeframe but must take place no earlier than the start of the reporting year and no later than the date of attestation in order for the patients to be counted in the numerator, unless a longer look-back period is specifically indicated for the objective or measure. This FAQ relates to prior program years and has been archived as of April 10, 2015.

EMR-EHR Safety Watchdog Unlikely To Emerge Soon

Posted on August 13, 2012 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

Yesterday, we at got a letter from the organization behind, a patient safety organization allowing people to anonymously report EMR-related safety events, stating that the site was shutting down.  PDR Secure LLC gave little information on the closure, other than to say that it was relinquishing its PSO status.

Curious, John and I took a closer look at the matter. The only other organization which seemed to allow for reporting of EMR-related safety incidents, (“S” capitalized for clarity), seems to have disappeared since it was first launched late last year.

So while Google searches aren’t perfect, it does appear that at the moment, there’s no official source to which providers, hospitals or other interested parties can report patient safety incidents related to problems with an EMR/EHR.

It’s worth noting that the FDA seems quite concerned about establishing EMR safety regulations. In fact, agency members have been in discussion for years on the topic, spurred by reports of HIT-related malfunctions. “Because these reports are purely voluntary, they may represent only the tip of the iceberg in terms of the HIT-related problems that exist,” Dr. Jeffrey Shuren of the agency’s Center for Devices and Radiological Health told Congress in 2010.

But so far, the agency hasn’t issued any regs. My feeling is that FDA leaders are stalling (prompted in part, I’m guessing from indirect lobbying pressure) on getting such a system started, as it’s definitely going to irritate some very deep-pocketed HIT players out there.

As FierceEMR editor Maria Durben Hirsch noted in an excellent recent column, there’s more than one way the private sector could take up the role of EMR safety watchdog, such as:

*  Creating a one-stop site where users and others can report on their experiences with EMR systems, a step the AMA has apparently considered

*  Launching a new watchdog agency, run by HHS, which would oversee EMR registration, monitor for health IT-related mistakes and investigate adverse event reports.  According to Durben, Congress likes this idea — which was proposed by the Institute of Medicine — but that there’s been no action yet.

Bottom line, it seems that reporting on adverse EMR events is a very unpopular idea in many quarters, or at least a political hot potato.  I suspect someone, perhaps HHS or even the POTUS, is going to have to hammer EMR reporting into place if it’s going to happen anytime soon.

101 Tips to Make Your EMR and EHR More Useful – EHR Tips 76-80

Posted on August 4, 2011 I Written By

John Lynn is the Founder of the 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 and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

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

80. Make certain the leader of your project’s support team is a physician
I’d say this is true in about 98% of the cases. In some very rare cases, you might be able to get away with a strong practice manager as the leader of the project. However, in most cases you’re going to need a physician driving the bus. This physician leader is going to be the person who helps you get buy-in for the EMR project. Without this buy-in, your EMR project is on very shaky ground.

79. Evaluate the Process FIRST!
One of my favorite comments about technology is that it exacerbates any current issues. It’s like taking a magnify glass on any process issues you may have and makes them into really big problems. So you definitely want to take care of any bad processes before you do your EMR implementation.

78. Make certain reporting is easy and flexible.
Reports are becoming more and more important. Meaningful use is basically one big report (and some process changes I guess). Medicaid and other insurance companies need reports and their demand for information is just going to increase over time. Plus, you EHR’s reports can be the key to you running a successful medical practice. They can point out areas that you can improve your practice. Make sure they have strong reporting capabilities that don’t require a special consultant or phone call to support to run every time.

77. Find out which Enterprise Content Management (ECM) systems integrate to the EMR.
This tip is more for hospital systems. Most ambulatory EHR systems do a pretty good job of document management. Plus, if they don’t most ambulatory clinics couldn’t pay for an ECM anyway. Either way, you need to take into account how you’re going to manage all the paper documents you still get and likely scan into your systems.

76. Do site visits
The benefits of a site visit have been mentioned at least a half dozen times already in this series of 101 tips and we’re only a quarter of the way through. That should be reason enough to do site visits. Site visits provide the first hand knowledge of how an EHR is used in a real practice. Plus, it lets you ask questions from someone who’s been through the EHR process. This connection can really pay off later if you go with that EHR vendor, because they can be a reference for when you have practical questions about your EHR as well.

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.

Types of EMR Reporting

Posted on April 28, 2011 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manager 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, a role he recently repeated for a Council member.

Guest Post: Carl Bergman of SilverSoft, Inc. is a principal of

My wife and I play a game called Write Only Files. The only rule is who’s first to notice that something’s been stored never to be retrieved. They come in all sorts of places. I once visited a nursing home that dutifully kept all the residents jewelry in a closet, but without any IDs. It didn’t matter; the owners never came back to claim them.

EMRs are not as dismal, but sometimes I think all we talk about is how to put data in an EMR without dealing with how to get it out. You’d think that the entire function of an EMR is to put in and retrieve single patient records.

Yet, a versatile, intuitive reporting system is absolutely necessary. Not only can it answer questions that paper systems cannot approach, but it also can produce insights into both medical and financial issues fundamental to a practice.

Stage 1 has changed some of this by requiring reporting on populations, not just retrieving single patient records. To deal with this, vendors have put on a full court press to modify their systems for Stage 1 reports. Their efforts, which often required new capacities, point out how neglected EMR report writers have been.

The need for more sophisticated and user oriented report writers is only going to increase. Stage 2, ACOs and other HIE initiatives will make even greater demands not to mention increased use of EMRs.

These external demands will be complimented by user demands for more information about the practice both medically and financially. Meeting these demands are a mixed bag of current systems. Some products will grow into these new roles while other vendors will need to rethink their approach or fail.

Current EMR report writers fall into three basic groups, of which only one can fulfill their role. These are:

•      Wired Reports. These EMRs don’t have a real report writer; instead, they have single purpose “push button” reports for specific purposes. Users have little or no control over what they find or present. A typical report might show no show patients for a day.

•      Parameter Reports. A step up from wired reports, these allow users a fair degree of control over what the report finds and some control over formatting. For example, the user may choose sorting order. These are often built in a tools such as Crystal Reports. Depending on the development effort, the result may be a robust tool. However, the use of third part tool can have major drawbacks. These include:

     o   Rigidity. Modifying a report may require an on site programmer or paying the vendor

     o   Cost. The user often has to pay for the tool, its annual license and maintenance. If there are problems, the user may be caught between the EMR vendor and the tool vendor.

     o   Conflicts. These tools are generalized applications designed to work on many different systems not just the particular EMR. Problems can range from not having the desired function to the tool ending support for the application type.

     o   Learning Curve. Users will have to master both the EMR and the tool’s way of doing things.

•      Built In Report Writers. These are designed as an integral portion of the system. These overcome the problems of the other two classes; assuming they are built to meet a variety of reporting tasks. Even if a report writer can carry find and sort the desired data, it must also meet other requirements. For example, if the FDA issued a bulletin requiring practices to notify all their patients who have Crohns disease and take acetaminophen. The report writer should be able to identify these patients, email or prepare letters to them.

Even if an EMR has a crackerjack system, its mission can still fail if it does not have access to all practice financial data. Systems with a single database can do this. Those that link or coordinate the EMR database and the practice management db have a harder, but possible task. Those systems that have separate, uncoordinated, datatbases are out of luck regardless of how good the individual report writers may be. If a report writer can’t cross the EMR and PM line, it is not taking full advantage of practice data. Each time it can’t produce the needed reports it’s creating write only files for my collection.