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HIPAA Compliant Email: some proactive strategies

HIPAA Compliant Email: some proactive strategies | EHR and Health IT Consulting |
Like so many other things with HIPAA compliance, there’s not one, singular answer that addresses the question of what constitutes HIPAA compliant email. However, the options addressed below represent a collection of first-line strategies that go a long way toward addressing HIPAA email regulations.

Be the expert on the topic of HIPAA compliant email on behalf of your patients. This means making sure you have appropriate notices visible, both on-line and in the real world, warning patients about the potential security risks of transmitting protected health information (PHI) using email over the non-secure portion of the Internet. For instance, many practices include a page for submitting questions to the office via email. Consider posting a statement that warns about security prominently on that page, such as:

“Please keep in mind that communications via email over the internet are not secure. Although it is unlikely, there is a possibility that information you include in an email can be intercepted and read by other parties besides the person to whom it is addressed.

Please do not include personal identifying information such as your birth date, or personal medical information in any emails you send to us. No one can diagnose your condition from email or other written communications, and communication via our website cannot replace the relationship you have with a physician or another healthcare practitioner.” Document the patient’s consent to receive communication by email. Don’t assume that because your patient sent an email requesting PHI or sharing PHI, that he or she understands the risks of sending or receiving such emails. Consider using a form like this “Emergency Contact Sheet” ...
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EHR and Health IT Consulting
Technical Doctor's insights and information collated from various sources on EHR selection, EHR implementation, EMR relevance for providers and decision makers
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Monitoring ICD-10 Post-Implementation Issues

Monitoring ICD-10 Post-Implementation Issues | EHR and Health IT Consulting |

Planning and execution efforts toward successful ICD-10 implementation have been the largest resource-intensive undertaking by healthcare in decades. The last couple of years have enlisted dedicated planning by government agencies, healthcare plans, EHR vendors, and health information educators in facilitating the transition from ICD-9 to ICD-10.

The cost of ICD-10 preparation was a valid concern for healthcare. Physicians and other qualified healthcare providers were impacted financially with making initial capital investment in certified EHR systems. The cost of initial training for their private clinics or group practices added to expenditures. Time and resources have been allocated to electronic data exchange testing over two fiscal years in anticipation of possible system interface and program incompatibilities. Concurrently, healthcare professionals had prepared for the code system changes by participating in provider-to-vendor testing while EHR companies, clearinghouses, and healthcare plans have been focused on vendor-to-payer data transmission.

The healthcare industry had ample time to analyze the factors that currently affect efficient and uninterrupted quality healthcare, but have healthcare providers anticipated the factors that will affect their practices after implementation?

A national effort to transition to a new and improved, but vastly different coding system inevitably affects various groups and multiple healthcare transactions. As a result of inaccurate data capture and delays in medical billing, it is critical that providers and administration examine how ICD-10 impacts patient care and reimbursement.

There are different factors that contribute to inferior health data reporting and to delays in provider cash flow:


1. EHR keywords tend to mimic the alphabetic index of the code book and are not set up in user-friendly clinical terms. Physicians and other qualified healthcare providers may have difficulty in locating the most specific and accurate ICD-10 code when using keyword search and look-up tools in their EHR.

2. Physician documentation practices may not correlate to main terms and subterms in which the ICD-10 code book or electronic code books are organized, making it more challenging for coders or other designated staff members to find the most appropriate code based on the completed notes.

3. Lack of physician engagement and the decision to not seek training in ICD-10 documentation lends itself to inconsistencies of code assignments from one healthcare provider to another. Many EHR products carry over the diagnosed conditions in the patient's current and past medical history. Other providers from the same practice may choose to assign these same ICD-10 codes previously noted in the record. Even if the providers were to decide to assign their own code and not carry over the previous ones, the lack of uniformity in the practice not only implies that there are coding errors being made, but that the data collected by insurance carriers, independent research groups, government agencies, and public health organizations is not a valid representation of current illnesses. Additionally, incorrect data exchanged across electronic systems is useless information and potentially harmful to the patient's health when shared with outside healthcare providers and facilities involved in the care of the same patient. The movement toward ICD-10 was fueled by a critical need to improve the quality and effectiveness of patient care. Inconsistent and inaccurate data quality thwarts this purpose.

4. General Equivalent Mapping (GEMs) resources are intended to provide the most approximate equivalent code from ICD-9, cross-walked to each possible ICD-10 code. The translation is not a perfect one because ICD-10 includes a plethora of information that previously had not been part of the ICD-9 code description. For example, ICD-10-CM introduces combination codes that detail the underlying disease and current manifestation, routinely seen in diabetes affecting other organ systems. The new coding system has established several new concepts and features for

ICD-10 diagnostic codes, allowing providers to:

• Include information on laterality

• Identify if it is the patient's initial encounter

• Identify the gestational trimester in which the disease process was diagnosed (including the severity of illness)

• Include the external cause

• Expand on the description of injuries, fractures, complications, adverse effects, and poisonings to now include very particular information, such as:

– The Gustilo grade of an open fracture

– If underdosing or noncompliance is due to medication cost-reduction

– If the provider is treating a pregnant patient for a particular condition that first developed during the mentioned trimester and not the episode of care that she presented for

– If the resulting complication resulted intraoperatively or postoperatively

While GEMs serve as a time-saving tool, the matching ratio from ICD-9 to ICD-10 is most frequently not a perfect 1:1 correlation. Most ICD-9 codes will map out to multiple possible options for correct ICD-10 code selection. Exclusive reliance on the GEMs will lead to incorrect code submission on billing claims.


1. The medical profession continues to be reimbursed on our current fee-for-service (FFS) system. National and Local Coverage Determination policies issued by CMS list and detail the diagnostic codes for symptoms and conditions that necessitate commonly performed diagnostic or therapeutic procedures. These acceptable diagnostic codes support the ordering or performing of any diagnostic tests or treatments. Incorrect ICD-10-CM assignment increases the number of "medical necessity" denials for CPT and HCPCS II procedures billed by physician practices.

2. CMS released data on healthcare providers, clearinghouses, and billing companies that participated in their July 2015 end-to-end testing with MACs and DMEs. Medicare published information stating 29,286 claims were received, but only 25,646 were accepted. Additionally, 52.7 percent of all submitted claims were professional services from healthcare providers, 2.6 percent of claims denied by CMS were due to submission of invalid ICD-9-CM codes, and 1.8 percent were due to invalid ICD-10 codes. This 4.4 percent denial rate was higher than the 3 percent reported in April's end-to-end denials. Health information managers (HIM) and providers spent 36 years learning how to assign three-digit to five-digit codes for a complete code selection. Now, providers and coders have to correctly select the required number of alphanumeric characters — anywhere from three characters to seven characters. Denials for invalid code submission further delay provider reimbursement.

3. Code assignment errors increase with untrained clerical and ancillary staff responsible for reviewing billed codes. Coding errors include: incorrectly assigned unspecified codes, codes of lesser specificity, missed diagnostic codes, and symptoms. This is especially critical for practices engaged in the HCC Risk Adjustment coding incentives in which captured data for severity of illness and comorbidities is directly tied to annual financial incentives for the practice.

4. The nearly quintuple growth in available diagnostic codes presents challenges when physician practices redesign their encounter form or superbill. Practices have to be selective about which commonly used diagnostic codes will be featured on the superbill for quick reference and which will be excluded.

5. Medical coders increase the number of queries addressed to healthcare providers for incomplete documentation and unspecified diagnostic conditions. While this is most likely to occur in the inpatient setting, physician practices with in-house medical coders will have billing claims held until the providers adequately respond to clarification requests.

6. Productivity rates decrease because of the increased time required to document properly for specific codes. Medical coders and HIM professionals take additional time to accurately locate and sequence the appropriate codes based on documentation. The increase delay in billing the professional claims increase the number of days in A/R and adversely affect the practice's cash flow. Independent providers and provider practices had been advised to budget for the anticipated financial impact at least six months prior to implementation.


Several measures should be taken in order to streamline the transition in medical practices. Examination and revision of internal policies and processes is essential to ensuring that quality patient data is captured, while maintaining compliance in billing practices.

1. Provider practices should seek assistance from the EHR vendor.

• Vendors are best equipped to provide training and can also instruct office managers on how to run reports detailing the 50 most commonly used diagnostic and symptom codes in the practice.

• EHR companies can effectively re-label many diagnostic codes so that the keyword or main term appears as the clinician deems natural, and not necessarily as the medical coder is trained to look them up in the alphabetic index of the code book.

2. Practices should rely on industry resources for proper coding guidance.

• The American Hospital Association (AHA) publishes quarterly guidance on ICD-9-CM and now ICD-10 code assignment. Many challenging coding questions have been posed to the AHA by medical coders and the responses are available and organized by ICD-9 and ICD-10 codes.

• CMS has publicly released physician guidance on ICD-10-CM coding in multiple medical specialties. Information tips are available to registrants of their listserv. Also, the "Road to 10" online resources are specifically designed to assist physician practices in raising awareness and promoting physician engagement, as well as offering free training for physicians and other healthcare providers.

• The National Center for Health Statistics (NCHS), an agency under the Centers for Disease Control, has additional resources. NCHS offers official guidelines on proper ICD-10-CM and ICD-10-PCS code assignment.

• The ICD-10-CM/PCS Transition Workgroup is an online community forum hosted and managed by the NCHS (on phConnect Collaboration for Public Health) to assist physicians in this implementation (visit for more information).

• The American Health Information Management Association (AHIMA) offers a number of physician coding resources, including an "ICD-10 Toolkit" developed in 2012 which still proves relevant and instrumental today (visit for more information).

• The AMA has printed and electronic ICD-10 publications on coding and documentation intended for providers. They offer online and live training for physicians.

Practices will need training and retraining after reevaluating post-implementation operations. Staff members come and go and providers may take medical posts in other organizations. Consistent and high-quality data reporting is essential and will directly impact practices as our healthcare industry phases out the FFS model and moves toward a value-based payment model. Practices should be making provisions for educational reinforcement after ICD-10 implementation, and should strongly consider the benefits of employing certified medical coders and HIM professionals.


The financial health of physician outpatient practices is affected by accurate ICD-10 coding. Just as importantly, patient health outcomes are directly tied to proper coding. Proper planning is key to compliance and optimal revenue management.

Continuing education and employment of certified coders will minimize coding errors. Close monitoring of the revenue cycle and reassessment of internal processes will help identify gaps. Utilizing industry resources is a cost-effective means of improving processes. All of these combined are ingredients in the best recipe for post-implementation success.

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Exporting EHR Data to Excel Improves Finance Reporting

Exporting EHR Data to Excel Improves Finance Reporting | EHR and Health IT Consulting |

EHR and practice management (PM) systems come with built-in reporting capabilities but digesting all that information can be overwhelming. However, leveraging the power of Excel to sort and manipulate the data stored in your EHR can help you spot trends faster and implement steps to drive revenue growth.

“Excel is a great way to slice and dice your practice management data so you can really use it to improve,” says Nate Moore, CPA, MBA, an independent consultant and coauthor of “Better Data, Better Decisions: Using Intelligence in the Medical Practice.” “Excel allows you to filter, trend, and get your arms around reams of data.”

Excel offers an interactive tool called pivot tables that allow users to quickly sort, filter, and manipulate data, says Moore, who moderates the Excel Users Medical Group Management Association Community, an online resource for practice administrators. It gives users much more flexibility than an EHR, which typically offers a limited number of canned reports.

For example, your PM system can probably produce a general report on your collection rates at the front desk at the point of service. But a pivot table would allow you to slice that data in a variety of ways, such as individual employees’ collection rates by location or time of day.

In addition, you can connect Excel to the server where your data is stored so you are always working with the most current numbers, says Moore. That allows you to quickly run the same types of reports with updated data.

“A lot of practice administrators don’t run reports as often as they’d like because they take so much time to run and analyze using the PM and EHR,” says Moore. “Using Excel streamlines the process, making it more likely that reports will actually get produced.”

Moore offered a few examples of how pivot tables might be used to dig deeper into financial reports and zero in on potential problems:

1. Focus on overdue accounts. A general report on aging accounts receivable from your PM system might contain hundreds of pages, making it difficult to focus on specific trends. Exporting that data into pivot tables allows you to zero in on problem areas, such as claims overdue by 60 days categorized by insurer.

2. Gage productivity. If your compensation system is based on productivity, you can look at work relative value units by individual providers or during certain time periods.

3. Monitor workflow. Larger practices can monitor and compare activity at different locations. For example, how many patients did one employee register at a specific location vs. another employee at a different office?  How many appeals or claims did each individual employee process at each office?

4. Analyze your patient base. Using a basic pivot table, you can see all of your new patients in a given year categorized by month of visit, referring physician, diagnosis code, insurance, or clinic location. Analyzing the data reveals trends, such as how many patients each physician saw in each year over the past five years.

5. Group data. You can group data to spot referral trends. For example, how many commercially insured patients did one group of referring physicians refer to each individual provider in your practice, for each of the past five years?

BI4Results's curator insight, November 10, 9:33 AM

Really, exporting to Excel? This process should be a fully automated self-service BI solution!

ICD-10 Success for Large Practices, Problematic for Small

ICD-10 Success for Large Practices, Problematic for Small | EHR and Health IT Consulting |

Several weeks following the implementation of the ICD-10 code set, the progress of the transition appears to vary according to size of the practice. While many large practices are reporting success with the transition, some smaller ones are reporting difficulty.

According to a blog post by the Coalition for ICD-10, many of the group’s members -- which happen to be larger healthcare providers -- are reporting great success with the transition. Many, like Centegra Health System, credit this success to the ample time for preparation they received.

“Centegra Health System was prepared for a smooth ICD-10 transition after two years of careful planning. Our information technology systems have been updated and our educational plans were deployed to help with the initial roll-out,” said Centegra’s Executive Vice President, Chief Financial Officer, and Chief Information Officer David Tomlinson.

Additionally, some coalition members stated that their success on October 1st is due in large part to their early implementation of the code set.

“Northwest Community Healthcare’s transition to ICD-10 has been smooth. This is due, in part, to our early clinical rollout of ICD-10 with our Epic Go-Live date of May 1, 2015,” said President and Chief Executive Officer of Northwest Community Healthcare Stephen Scogna.

Other members of the coalition, such as insurer Blue Cross Blue Shield of Michigan, reported a few bumps in the road amidst a generally smooth transition.

““BCBSM’s ICD-10 implementation went very smoothly. Call center volumes and overall inquiries are very low. Professional and facility claims are processing as expected. A few issues noted, which we are resolving, but nothing major to report,” the insurer said.

BCBSM also reported that it was the first private insurer to reimburse the hospitals it serves.

“Received kudos from our hospitals stating that BCBSM was the first payer to pay ICD-10 claims and these claims are paying as expected. Hospitals are not reporting any major issues. Other Payers (Priority, Cigna, Aetna) are reporting the same experience in that they are not seeing any major issues.”

However, this success is in contrast to what some other smaller providers are reporting. The impact of ICD-10 on smaller providers is a little bit more weary as these providers have fewer resources to work with.

For example, Linda Girgis, MD, FAAFP, told that due to how small her practice is -- she and her husband are the only physicians in the family practice -- its workload has grown much larger. This work includes changing patient problem lists from ICD-9 codes to ICD-10.

"The doctors are doing it right now," she says. "I'm doing it as I come across different patients, but definitely it's adding time on to the workday."

Smaller practices are especially affected by ICD-10 troubles because much of their revenue comes from the Centers for Medicare & Medicaid Services (CMS), and the agency has been reportedly unreachable throughout the transition.

"My biller tries to call every day. Since October 1, they have messaged that they are down due to technical difficulties so it's impossible to get through to any person there,” Girgis said.

Not receiving CMS payment is problematic for small practices like Girgis’ because those payments may amount to almost 30 percent of hospital revenue. While a larger hospital, like those mentioned above, may be able to do without 30 percent of its revenue for a month or two, this kind of issue could be potentially detrimental for a practice like Girgis’.

"Big organizations, hospitals, and groups can go a few months without 30 percent of their reimbursement coming in. But for small practices, that can be devastating," argues Girgis.

CMS set a timeline for rolling out ICD-10 payments, stating that those claims would be reimbursed within the first 30 days of the new code set. As that 30-day timeline draws to a close, small practices will be waiting to see if their claims are reimbursed.

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EHR Interoperability Limited in Integrated Care Facilities

EHR Interoperability Limited in Integrated Care Facilities | EHR and Health IT Consulting |

EHR interoperability has been brought to the forefront lately as various health organizations and government agencies push for nationwide health information exchange. Furthermore, as integrated healthcare and care coordination become fixtures in the healthcare delivery industry, interoperability of systems between different kinds of practitioners shows itself to be critical.

A recent study by Maribel Cifuentes, RN, BSN, Melinda Davis, PhD, Doug Fernald, MA, Rose Gunn, MA, Perry Dickinson, MD, and Deborah J. Cohen, PhD, discussed how EHRs operated in 11 practices that were integrating the delivery of primary and behavioral healthcare. The researchers found that when behavioral health and primary care begins to integrate, the two kinds of practitioners brought separate EHR systems with them. This caused challenges and subsequent workarounds and solutions associated with EHR interoperability.

The study took 11 integrated practices in the Colorado area and gathered data regarding how EHRs worked for their needs, the challenges practices faced, what kinds of workaround strategies practices developed, and what kinds of long-term solutions the practices identified in order to promote care coordination over an EHR.

One of the challenges many of the integrated practices faced was that the EHRs were not necessarily designed to collect a certain kind of data. For example, in a primary care facility that hired several behavioral health counselors (BHCs), the facility’s EHR may not have been conducive to collective behavioral health data.

Second, EHRs generally lacked templates for primary care physicians and BHCs to develop coordinated care plans.

Third, many EHRs were not interoperable with each other, hindering primary care physicians and BHCs from working together in delivering coordinated care. The EHRs were also not compatible with tablet devices that were used to collect behavior health information in the waiting room prior to appointments. These tablets were used to present questionnaires that would provide behavioral health data. However, the lack of interoperability between these devices and EHRs made it so the data collected in the questionnaire could not easily be uploaded into the EHR.

The study reports four workarounds that were developed in the face of these challenges. First, as stated above, when the primary care and behavioral health practices first integrated, the physicians often had their own separate EHR systems. In order to make sure both systems had patient information, physicians had to manually enter the data into both EHRs. While this method may have been effective in ensuring patient information was stored in both EHRs, it was not particularly time or financially effective.

Second, medical assistants had to manually scan printed documents into EHRs. While this method may have also been effective, it presented several time and financial issues. Furthermore, the scanned documents were often harder to find in the EHR, hindering the physician from delivering care to patients in a timely manner.

Third, practitioners relied on patients and other physicians to recall patient information. This workaround was not effective because patient and physician memory was neither reliable nor accurate. One physician reported having to recall patient information that was told to him several weeks before meeting with the patient. Due to the amount of time that had passed since he had last discussed this patient, he was unable to determine what kinds of services the patient needed. This resulted in the patient taking tests that had already been administered.

Fourth, practitioners employed “freestanding tracking systems,” such as spreadsheets, that were not a part of the EHR. For example, one practice stored information regarding adolescents taking selective serotonin reuptake inhibitor medications in an Excel spreadsheet. Although this was widely used amongst the practice, it took enormous effort from practitioners to maintain, and the information on the spreadsheet was not easily integrated into the EHR.

By the end of the study, researchers observed that practices began moving past workarounds and toward more long-term solutions to their challenges in order to make their integrated practices more sustainable in the future. The researchers noted that these solutions were created by each practice’s own HIT teams and required their own funding. Three key solutions amongst the participating practices emerged.

First, many practices created their own customized EHR templates. These templates existed within their pre-existing EHR systems, and simply added more fields for data entry that would be more suitable for practitioners’ needs. However, developing these templates was an arduous task.

“Creating customized EHR templates was time consuming and required dedicated HIT staff working collaboratively with BHCs and primary care providers,” the researchers reported. “Practices that did not have access to these resources were not able to create customized templates as readily, or had to pay EHR vendors to do so.”

Second, some practices purchased EHR upgrades and reported several improvements from doing so, including increased interoperability, enhanced reporting templates, and more interfaces for integrating primary and behavioral health care.

However, EHR upgrades were considerable financial investments for practices. Practices were not allowed to upgrade their EHRs using the money allocated to them by participating in the study, so the upgrade needed to be a part of the individual practice’s investments. This financial burden made it so only five of the 11 participating practices were able to upgrade their EHRs.

The final emerging solution was the union of two EHRs. At the start of the study, four of the 11 participating practices were using two different EHRs -- one for behavioral health care and one for primary care. By the end of the practice, three of them were in the midst of merging those two EHRs, and one had built an interface that extracted data from multiple EHRs and stored the data in one place. While these solutions were quite complicated and costly, they were the most effective in overcoming interoperability challenges.

Despite the advances these practices made, the researchers maintained that integrated providers may still face hurdles in the future.

“EHR systems are not yet optimally designed to meet the needs of practices integrating behavioral health and primary care,” the researchers stated. “Our study found that EHRs generally lack features essential to support key integration functions such as documenting and tracking longitudinal data, working from shared care plans, and template-driven documentation for common behavioral health conditions such as depression.”

The researchers provided guidance on how to improve EHR use in integrated care situations, stating that perhaps systems need to start being designed for integrated care, as should different incentive programs.

“In the future, HIT systems should be intentionally designed, in cooperation with clinicians; to support and enable these integrated care functions, as well as the different modes of communication and care coordination tasks that occur between multi-professional members of integrated teams,” the researchers maintained.

Furthermore, the researchers stated that more financial incentives should be provided to allow practices to make these kinds of changes. Although several EHR and interoperability incentive programs exist, none of them provide incentives that would help practices change their EHR systems to make it more usable in an integrated practice.

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AHA Explains Industry Challenges for EHR Interoperability

AHA Explains Industry Challenges for EHR Interoperability | EHR and Health IT Consulting |

EHR use presents many healthcare benefits, including coordination of care and increased patient engagement. However, , the lack of EHR and health IT interoperability is posing a serious threat to other healthcare initiatives, according to a recent report published by the American Hospital Association.

The report, entitled Why Interoperability Matters, discusses the various aspects of the healthcare industry and care delivery that are negatively impacted by a lack of interoperability. Among those aspects include care coordination, patient engagement, and public health and quality measures reporting.

Care coordination

The exchange of health information is critical for the coordination of care, according to AHA. When patients receive care from multiple different providers, physicians should be able to securely send relevant patient information to the practicing physician. However, that tends not to be the case because EHR systems are not interoperable and cannot exchange information.

Furthermore, care coordination and successful interoperability are vital for provider finances. As accountable care organizations and bundled payments continue to grow more prevalent, the AHA maintains that interoperability and the ability to see all of the care a patient in receiving is crucial in preventing unnecessary treatment.

Patient Engagement

Patient engagement and the shared decision-making between providers and patients is critical in achieving the aims of the healthcare industry, the authors of AHA report maintain. Further, patient engagement is a central part of federal regulations on using an EHR. However, the agency states that many patients are unable to access their electronic health information, hindering the practice of patient engagement.

“The real problem is that the vast majority of patients cannot access their health information in a holistic, meaningful way. Instead, they must go to each of their providers’ patient portals and download unintegrated data. Making sense of this, particularly for patients with multiple chronic conditions who frequently have many health encounters a year, is difficult,” the report states.

Public Health and Quality Measures Reporting

EHR use also provides the opportunity for enhanced public health reporting. Because patient data is aggregated on one, electronic system, healthcare professionals can track healthcare trends and analyze information about population health. But without adequately interoperable systems, that process is significantly hampered.

“Hospitals are happy to report this data to improve public health but must contend with a wide variety of reporting formats and transmission technologies to do so, including faxing, mailing, e-mailing, web forms and secure file transfer protocols,” report reads.

This cumbersome process results in wasted time and resources. Similarly, practices face issues with quality measure reporting. Quality measures reporting is another federally mandated practice for EHR use, however without properly interoperable systems, health systems face challenges.

Interfaces and HIEs as solutions

Healthcare providers have created a few solutions to this interoperability problem, including interfaces and health information exchanges.

Interfaces are programs that allow a facility’s EHR to pass along information from one system to another, yet practices face challenges when using interfaces for more than one provider.

“ health care, each interface currently is like a snowflake: it must be built to meet the unique requirements between two providers and cannot be reused,” the authors explain.

Because practices would need to adopt multiple interfaces, they are not always a financially stable solution to interoperability.

Like interfaces, health information exchanges (HIEs) have presented themselves as potential solutions to interoperability problems. Although HIEs can be successful in securely transmitting health information between providers, they too are quite costly. Furthermore, AHA explains that many HIEs are installed via federal grants, and that when the grants run out, many practices are unable to maintain their HIEs.

Health IT standards need more specificity

Although there are a set of standards identified for the use of EHRs and other health IT, they are not specific enough to be effective, the authors note. Creating uniformity in how data is collected and stored on an EHR, however, would be a drastic step forward for interoperability, the report states. Increased health IT standards would cause data to be input in the same way across the healthcare delivery spectrum, making information sharing more feasible.

Although the authors acknowledges the potential that health IT standards have in increasing interoperability, the agency maintains that much work in defining those standards and developing other platforms needs to be done before the industry can achieve nationwide interoperability.

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AAFP: Health IT Industry Should be Closer to EHR Interoperability

AAFP: Health IT Industry Should be Closer to EHR Interoperability | EHR and Health IT Consulting |

Although the Office of the National Coordinator for Health IT (ONC) recently released itsInteroperability Roadmap, the American Academy of Family Physicians (AAFP) does not believe that is enough to achieve nationwide EHR interoperability in a timely manner.

In a recent letter addressed to National Coordinator Karen DeSalvo, MD, MPH, MSc, AAFP’s Board Chair Robert Wergin, MD, FAAFP expressed his and the organization’s dismay at the slow progress of nationwide interoperability.

“Our members and the AAFP are very concerned with the very slow progress toward achieving truly interoperable systems. Furthermore, we strongly believe there is need for increased accountability on industry and decreased accountability on those who are using their inadequate products,” wrote Wergin.

According to Wergin, care coordination, patient engagement, and population health management all need greater support through increased interoperability. However, at the rate the healthcare industry is moving with regard to interoperability, those goals are not expected to be achieved soon. To change this course, Wergin says the industry needs more action rather than more planning. Additionally, providers and organizations that are playing their parts in increasing interoperability need more support.

“We need more than a roadmap; we need action. First, it is our belief that without significant changes in the way health care delivery is valued (e.g. paid) then it will not matter how many standards are created, how many implementation guides are written, how many controlled vocabularies are fortified, or how many reports are created; we will still struggle to achieve interoperability. Any roadmap for interoperability needs to ensure payment reform toward value based payment, in addition to the technical work. This aligns the health care business drivers to the achievement of true interoperability.”

Wergin argued that certified EHR systems are a contributing factor for this slow growth toward nationwide interoperability. In 2007, he said, the AAFP was responsible for creating a set of standards for healthcare summary exchange. However, despite the adequacy of those standards, Wergin reported that practitioners still experienced difficulty in exchanging information due to incompetencies of EHR systems. Because the EHR systems cannot interpret the data that is being exchanged between systems, physicians are finding themselves manually inputting data from one system to another.

“Instead, physicians must view the documents on the screen, just as they would a fax, to find the important information. Then they must re-key that information into their EHR if they want to incorporate some of the summary information into the patient’s record,” Wergin explained.

Wergin described an urgent need to transform interoperability. If practices are expected to achievemeaningful use and other incentive-based models, interoperability needs to be a high priority for the health IT industry.

“Everyone including technology vendors, hospitals, health systems, pharmacies, local health and social service centers and physicians, must come together as a nation to achieve the interoperability levels laid out in this roadmap at a more rapid pace,” Wergin wrote.

Comparing the push for interoperability to President Kennedy’s push to get to the moon, Wergin states that the health IT industry should be able to achieve its goals in the same 10-year timeframe that Kennedy did. By 2019, Wergin stated, the entire healthcare industry should be using completely interoperable systems.

“We should be much closer to our goal and it should be accomplished within ten years (2019),” Wergin wrote. “The AAFP is dedicated to continue our work to achieve interoperability which is fundamental to continuity of care, care coordination, and the achievement of effective health IT solutions.”

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Epic Systems Tabbed to Expand Hold of Ambulatory EHR Market

Epic Systems Tabbed to Expand Hold of Ambulatory EHR Market | EHR and Health IT Consulting |

Epic Systems is in the driver's seat compared to other ambulatory EHR vendors and poised to take control of an even larger portion of the outpatient EHR market, according to a recent survey of more than 170 ambulatory care facilities.

Conducted by peer60, the report shows Epic to control close to 20 percent of the ambulatory EHR market several points ahead of its main competitor Cerner Corporation, which owns less than 15 percent.

The authors of the report base their predictions for Epic's growth on the perceived market dominance of the Wisconsin-based EHR vendor — that is, "mindshare." Epic and Cerner are neck and neck among ambulatory care facilities in this area, hovering around 32 percent.

"As has been the case in past years, Epic’s and Cerner’s aggressive positions will continue to gobble up pieces of the ambulatory pie currently occupied by vendors that have struggled to stay relevant in this space," the report states.

Also likely to make gains are athenahealth and eClinicalWorks whose mindshare ranges between 14 and 20 percent:

The other half of the market share and mindshare story and equally impressive is athenahealth’s and eClinicalWorks’ significant mindshare figures at approximately eight and five times their current market share in the overall ambulatory EHR market, respectively. This indicates these vendors are finding significant ways to positively connect with providers.

According to the authors, the disparity between market share and mindshare indicates a need for EHR vendors to improve their standing among ambulatory care providers, a caveat being that EHR vendors focusing on independent facilities have less to lose because many ambulatory centers base their EHR selection on hospital EHR selection.

For these independents, Epic and Cerner trail NextGen based on market share, the latter holding close to 20 percent of the marketplace. As for mindshare, NextGen's prospects are not good "considering they occupy no space in the future plans of independent ambulatory providers," the authors contend. Meanwhile, eClinicalWorks is set to make major gains among these ambulatory care settings well ahead of both Epic and Cerner.

Factoring in to future ambulatory EHR selections will be EHR vendor recommendation scores from providers. On average, ambulatory providers are more likely than not to recommend their current ambulatory EHR technology to others — 6.2 out of 10. The scores for individual EHR vendors is not made public, but five vendors scored above the 6.2 mark with one scoring as high as 9.3.

What will likely influence ambulatory EHR selections are solutions to the top challenges for provider EHR users. The top EHR challenges are missing EHR functionality (55%), lack of EHR usability (42%), and support of a practice's strategic objectives (30%).

Despite these responses, the ability of EHR vendors to make inroads in the ambulatory care setting will be difficult. A vast majority of respondents (85%) are not actively looking for EHR replacement technology. This is the case for both hospital-owned and independent ambulatory facilities.

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How Improving Physician EHR Use Can Benefit the Diagnoses

How Improving Physician EHR Use Can Benefit the Diagnoses | EHR and Health IT Consulting |

Although physician EHR use has many benefits, including increased care coordination and patient engagement, issues with interoperability and health information exchange sometimes hinder the diagnosis process.

Such was the case with the first Ebola patient in Dallas, Texas last year. According to a post by Dean Sittig, PhD, and Hardeep Singh, MD, MPH, there are various different EHR practices that could have been done that may have potentially changed the outcome of the patient’s Ebola diagnosis.

Sittig and Singh based their theories on an Institute of Medicine (IOM) report that made suggestions for best practice uses for EHRs that would make diagnosis easier and more precise. According to the authors, had some of these practices been in place during the time of Ebola Patient Zero’s hospital visits, his diagnosis may have been more effective.

First, Sittig and Singh discussed the care coordination benefits of EHRs and how they may not have been fully utilized at the time of Ebola Patient Zero’s first emergency room visit. Although Ebola Patient Zero’s medical and travel history were taken by the ER nurse, that information was not passed along to the ER doctor, something which may have been prevented had different EHR practices been in place.

We recognize that there are many other ways to improve teamwork but in this day and age a major component of making teams function well is having EHRs that support teamwork and communication. Unfortunately, EHRs are not inherently designed this way and substantive ‘real-world’ usability testing is needed in order for them to do so,” wrote Sittig and Singh.

The authors suggest that EHR interfaces could improve both nurse and physician workflows in such a way that care coordination and teamwork would be better facilitated. For example, note-taking screens should not necessarily distinguish between physician notes and nurse notes, Sittig and Singh suggest. Instead, all members of the care team should be privy to all of the patient’s medical history.

“The ability to review every patient’s complete medical history in a longitudinal manner is a key factor in making an accurate and timely diagnosis. EHR screen designs could be greatly improved if they were shared among all EHR users, regardless of vendor,” the authors wrote.

Furthermore, Sittig and Singh discuss certain misuses of EHR technology. For example, the authors suggest that perhaps EHR quality measures and incentive programs should not always require nurses be tasked with gathering information regarding patient flu vaccination history. The authors maintain that although it is impossible to know whether this change in workflow would have improved Ebola Patient Zero’s diagnosis, it is a commonly acknowledged fact that certain required EHR incentive measures have an effect on how clinicians communicate with patients.

Sittig and Singh state that Ebola Patient Zero is a case study for all of the work that can be done to improve EHR use in diagnostic settings. These improvements can be made through industry collaboration and the sharing of best practices. Furthermore, the pair states that EHRs need interoperability to allow for collaboration and to help paint a complete picture of the patient’s care. Through the participation of policymakers and industry stakeholders, Sittig and Singh state that EHR healthcare can become safer and more effective.

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Innovative Ways for Small Practices to Invest in Tech

Innovative Ways for Small Practices to Invest in Tech | EHR and Health IT Consulting |

At a time when American providers are offering some of the best care in the world, even the smallest medical practices cannot slip. They must offer top-tier services, while meeting and maintaining compliance with government regulations. This is no small order, and it's made increasingly difficult considering the price tag that comes with integrating cutting-edge technology — in particular, EHRs — into an office, especially for solo practitioners or practices with just a handful of doctors.

While the incentive to invest is greater than ever with the ongoing meaningful use program, the cost of implementation is still pricey. Physicians working in the smallest practices have to get creative when trimming technology expenses.


"Maintaining an electronic health record system is our largest expense," says pediatrician R. Frerichs of North Raleigh Pediatric Group. His practice isn't an isolated case. According to a survey in Medical Economics from February 2014, 45 percent of physicians spent more than $100,000 on EHR systems including service, hardware, software, training, and consulting. However, there are ways to shrink that number considerably.

It is easy to feel overwhelmed by options available in the marketplace. Practices on the hunt for tech investments must be mindful of what is specifically needed. "There is a want to measure everything without knowing why or what to do with the measurements," says Kyle Wailes, senior vice president of physician services at the Ft. Lauderdale, Fla.-based technology solutions provider, Intermedix. "A smart and focused practice can avoid much of this by determining must-haves ahead of time and knowing exactly what is needed when purchasing technology."

In addition to searching for the product that best matches a practice's needs and work flow, there is value in adopting open source products. Dozens of open source software programs have been developed for the medical industry with data security and usability at the forefront, says Greg Scott, owner and operator of Infrasupport Corporation, an IT consulting firm in Eagan, Minn. With open source software, physicians don't have to become IT experts, since someone else developed the software and the additional features. They do have to be willing to explore technology built using an open source model by accepting patches, new features, and other support built by an interested community. Any potential inconvenience is likely to be offset with the cost savings, which can be as much as 80 percent compared to proprietary competition, Scott says.

Similarly, practices should seek out "disruptive vendors" — those working on the innovative edge of mainstream technology — because they typically have lower gross margins, smaller target markets, and simpler products, experts say. Though the products and services may not appear as attractive as existing solutions when compared against traditional companies, the cost is often cheaper, says Austin Kirkland, principal and founder of healthcare management services consultancy Outperform, LLC, based in Falls Church, Va. "Many businesses have developed software tailored to suit specific specialties or to operate with less robust features, lower development costs, and reduced operating overhead," he says. "As a result, they are able to offer their products at a better price point to specific buyers than their larger competitors, so shopping for the right solution can save money."

Once practices have made the initial investment for EHR and practice management systems, there are ways to manage the ongoing costs associated with overseeing them. The unfortunate truth is that technology requires constant upgrading to remain efficient and compliant, which of course, comes at a cost. Instead of hosting technology infrastructure onsite at a practice, medical offices should consider migrating most (if not all) technology services to a cloud services provider or third-party data center. Doing so requires an initial upfront cost, but service fees are generally paid monthly at a predictable, scalable rate. Additionally, this frees medical practices from worrying about hardware failures or updating software because managing those responsibilities falls to a third-party vendor.


Despite doing due diligence to select the best and most cost-effective products and maintenance options for a small practice, the fact is that someone still has to pay the bill for technology.

One of the best things practices can do is find support within a larger group of physicians. Frerichs says his participation in a practice management group called Raleigh Durham Medical Group (RDMG) has been a critical factor in his ability to manage costs for his practice. "The power in numbers allows us to negotiate deals for pricing that I would not be able to attain alone," he says. For example, he adds, collaboration through RDMG allowed them to obtain optimal pricing for purchasing an EHR. Furthermore, when the need to replace or update equipment arises, the group provides flexible financing options.

Flexible financing also allows physicians to relieve some of the weight that comes with buying technology outright. For practices that don't have credit available to take term loans — or those that simply choose not to — leasing options are available. This ensures practices have cash on hand to pay for consumables, payroll, fees and taxes, and other necessities, says Jim Phelps, CEO of Beaverton, Ore.-based equipment financier, Capital Equipment Leasing, and it keeps a line of credit open for other needs. Leasing also removes the permanence that comes with an outright product purchase, allowing companies to upgrade or change technology with minimal cost. "Software and hardware can be leased on a turn-key basis, allowing the practice flexibility as needed to move at the end of a lease and to avoid upfront capital needs," Kirkland says.

Though hardware and software can be leased, other products can as well. Phelps' company has leased digital X-ray, sonogram, and MRI machines, and exam tables. "We can lease any equipment that is not 'body invasive,'" he says.

Investing in technology, whether hardware and software, diagnostic equipment, or other necessary products and services, is a given in the medical industry. Small practices must be innovative to keep on top of advances in the industry, because the ultimate bottom line is providing the very best care to each and every patient.

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CMS Administrator Welcomes Providers to ICD-10 Compliance

CMS Administrator Welcomes Providers to ICD-10 Compliance | EHR and Health IT Consulting |

On October 1, the healthcare industry began ICD-10 compliance after countless months of preparation. In a CMS post, Deputy Administrator and Director of the Centers for Medicare & Medicaid Services (CMS) welcomed providers to ICD-10 and provided words of guidance to industry stakeholders on the transition day.

According to Cavanaugh, it may take a little while before CMS is able to assess how the transition to ICD-10 is proceeding. The reasons for this are twofold: first, most providers do not file claims on the same day as a service has been provided, and second, it takes a few weeks for CMS to process Medicare and Medicaid claims.

“Even after submission, Medicare claims take several days to be processed, and Medicare -- by law -- must wait two weeks before issuing  payment. Medicaid claims can take up to 30 days to be submitted and processed by states,” Cavanaugh wrote.

It is most likely that CMS will be able to assess ICD-10 progress following the first complete billing cycle. This is consistent with other CMS claims. In aconference call with industry stakeholders which took place a week before the October 1 deadline, CMS Principal Deputy Administrator Patrick H. Conway, MD, MSc, confirmed the same timeline for checking ICD-10 progress.

Until then, Cavanaugh explained, CMS plans to closely monitor the transition. Furthermore, CMS will be managing problems and questions that are submitted to the ICD-10 Coordination Center, which is staffed by several Medicare, Medicaid, billing, coding, and health IT experts to assist during the transition. In addition to the ICD-10 Coordination Center, Cavanaugh points providers toward other ICD-10 assistance resources, including William Rogers, MD, the ICD-10 ombudsman, and Medicare Administrative Contractors (MACs).

Cavanaugh also discussed the potential benefits of the ICD-10 transition, including the promise of more detailed health data reporting and and better healthcare delivery. By increasing the detail with which medical care is reported, policy changes can be more specific to the needs of populations.

“The change to ICD-10 allows you to capture more details about the health status of  your patients and sets the stage for improved patient care and public health surveillance across our country,” he wrote. “ICD-10 will help move the nation’s health care system to better, smarter care.”

These hopes for ICD-10 have been mirrored by many industry stakeholders, including AHIMA CEO Lynne Thomas Gordon, MBA, RHIA, CAE, FACHE, FAHIMA. Thomas Gordon recently stated howICD-10 will be of great benefit for patients because it will allow for better healthcare innovation due to the extensive detail of health records.

“As an active leader, supporter and advocate for ICD-10, AHIMA is pleased that the greater detail inherent in the code set will reverse the trend of deteriorating health data and tell a more complete and accurate patient story,” she said.

As providers continue with their transition to ICD-10, CMS is expected to report any major issues and provide guidance in fostering the smoothest transition possible.

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Why More Physicians Will Adopt Electronic Health Records

Why More Physicians Will Adopt Electronic Health Records | EHR and Health IT Consulting |

When President George W. Bush issued an executive order in April 2004 to establish the Office of the National Coordinator for Health IT, he had a clear vision in mind: to create a secure, nationwide interoperable network that allows authorized users to access medical records of anyone at anytime and anywhere in the U.S. President Barack Obama knew very well that his plan for providing health insurance to all Americans would not be successful unless it was paired with a plan for controlling the quality and cost of health care services.

Ironically, Bush’s health IT network was (and remains) the instrumental element that guarantees the financial sustainability of Obamacare. It was no surprise that the economic stimulus package of 2009 allocated $25.9 billion for promoting the adoption and use of electronic health records systems among American physicians and hospitals. But a decade and $30 billion later, only half of the U.S. office-based physicians have adopted a basic electronic health records system and a mere 20 percent of them use such software, according to the latest statistics byRobert Wood Johnson Foundation.

Now that the government funds for promoting adoption and use of such records are dried up, what will happen to the rest of doctors who have not ditched their old-school paper charts yet and still keep their patients’ records in a filing cabinet? In the following, I discuss three drivers which together will lead the other half of physicians to adopt electronic health records systems in the near future.

Marketing efforts by vendors

To increase their profit margins, electronic health record vendors prefer to target customers who will either make a large purchase (large health care organizations with multiple users) or are close by and thus do not require expensive marketing efforts. That is part of the reason why many of the physicians who have adopted such systems are affiliated with larger hospitals or are located in populated urban locations. Now that the low-hanging fruits are all harvested, vendors will focus their marketing efforts on small, office-based practices and will ultimately increase adoption rates.

Mergers and acquisitions in the health care sector

With the march toward value-based payment models, new forms of health care organizations will continue to emerge. Some of the individually owned physician offices will become a part of an accountable care organization or will be acquired by a larger health care organization. When these smaller practices join larger ones, they will have to adopt the technologies that are already being used by the larger organization. While electronic health records may not create substantial value for an independent practice, they will be an unavoidable necessity when small practices join larger organizations. Without them, it will be impossible for a large health care organization to coordinate patient care, manage population risks and efficiently submit insurance claims.

Data analytics tools

With a basic electronic health record, a physician can record patient demographics, medications and problems, as well as type in his clinical notes and prescriptions. (No, he cannot electronically send the prescription to the pharmacy.) A physician can also view laboratory and imaging results (only if the record system is interoperable with that of a laboratory or imaging center). That’s it; nothing more. Almost all of the definedfunctionalities of a basic electronic health records system could be achieved by an elaborate Excel spreadsheet. That is why many doctors are still not willing to use them, even for free. Electronic health records by themselves are just cranky databases that only archive data.

However, with the advances in artificial intelligence and decision support systems, the data that was onerously collected by frustrated doctors can now be used to create something meaningful that make doctors’ lives a little easier. The health care industry is gradually getting out of the data collection era and is now entering into the data analysis era. When doctors see tangible benefits of analytics tools such as Isabel and Watson that are based on their electronic health record data, they will flock to such systems powered by analytics tools.

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Four ICD-10 Myths from a Critical Doc

Four ICD-10 Myths from a Critical Doc | EHR and Health IT Consulting |

Have you ever stood near the tracks and listened to a train coming? When the train is far away all you can hear is the distant echo of the whistle. It’s easy to ignore.  As the train gets closer you hear the engine and see the smoke. As the train comes to the station it becomes a thundering, screeching, hissing mass of steel.

If you are close enough, it can even startle you.

With an Oct. 1 start date imminent, the ICD-10 train is getting awfully close. Anyone harboring hopes of Congress rescuing us at the last minute is kidding himself. If your practice is not prepared, there are plenty of health IT companies out there who will gladly take your money to rescue you safely away from the tracks.

The supporters of ICD-10 —bureaucrats, health IT vendors, and medical academicians —have been assuring us this is for our own good. The era of big data in healthcare is coming, so they say, and ICD-10 is the perfect vehicle for collecting the rich, detailed data that will bring the next big age of medicine. ICD-9 is decades old and needs to be replaced by a system which can accommodate the advances in diagnostic acumen of recent years. Privately, these groups ridicule our misgivings and assume that we’ll complain for a while and just get over it.

Last February, Congress held hearings on ICD-10. This was supposed to be the last decision-making step before committing to the program. In reality, it was a choreographed farce designed to suppress the concerns of real-world physicians. The witnesses included two health IT vendors, two lobbyist groups, one academic physician, and two private practice physicians. All but one of the witnesses, the late urologist and president of the Medical Association of the State of Alabama, Jeff Terry, supported ICD-10.  Most of the remaining witnesses either stood to benefit financially from ICD-10 or were insulated from its effects by the academic environment.

But there is more to ICD-10 than the propaganda peddled by supporters.  Let’s look at some of the myths about ICD-10:

1. ICD-9 is outdated and needs to be replaced.  The former is true.  The latter is not.  The structure of ICD-9 (five numeric placeholders) theoretically allows for 100,000 codes.  ICD-9 could have been easily expanded by adding one or two placeholders and allowing letters to be used. This would expand capacity to over two billion codes. It would have allowed horizontal expansion (i.e., the addition of Ebola infection to the appropriate category —a favorite example of ICD-10 supporters) as well as vertical expansion (the breakdown of otitis media into left vs. right).  This could have been done without rendering any ICD-9 codes obsolete. 

2. ICD-10 based big data will improve patient care.  ICD-10 supporters would have us believe that ICD-10 based data will lead to medical miracles falling from the sky.  These utopian fantasies fail to consider the implications of the scientific method.  Medical advancements come only from experiments based on hypotheses.  Hypotheses dictate experimental design, including the methods and structure of data collection.  Lacking any hypotheses, ICD-10 creates a one-size-fits-all data collection method for all fields of medicine.  This makes absolutely no sense.

3. ICD-10 will improve quality of data collection.  I almost believed this until I began to prepare my practice for ICD-10 months ago.  Instead of a rational expansion of diagnoses I found —for my specialty, at least —a haphazard, nonsensical collection of codes created seemingly at random.  I’m not talking about the “burned by water skis on fire” stuff we have all heard about.  I discovered that every code related to ear pathology is obsessively divided into left ear, right ear, or both.  Even “vertigo of central (nervous system) origin,” which by definition does not involve the ears, requires a choice of left or right ear!  But other diagnoses —facial paralysis, head and neck cancers, sinusitis, and others —have no ICD-10 division by side.  The diagnosis of vocal cord paralysis, in which the side of involvement has long been recognized to be clinically significant, is not separated by side.  In fact ICD-10 has fewer codes for vocal cord paralysis than does ICD-9.  Does this mean that ear disorders are more worthy of big data research than sinusitis, head and neck cancer and vocal cord paralysis?  Who decided that?  There is no way, for otolaryngology at least, that such a poorly designed coding system will yield any useful data.  Don’t hold your breath waiting for any big data medical miracles.

4. Third-party payers are ready.  Who are they kidding?  Didn’t CMS claim that was ready two years ago?  How many test payments to providers were sent?  There is no way to adequately test a system this complex before it goes live. Remember that CMS and private insurers have no risk on the table.  If their systems “mysteriously” fail to pay claims, they benefit by keeping the cash they would otherwise have paid out.  On the other hand, physicians will be unable to pay rent and make payroll if payments on claims are interrupted more than a few days.

The only rationale that explains ICD-10 is the desire of its supporters for a top-down, big government, centrally controlled healthcare system that regards doctors and patients as nothing more than cogs in the machine.  The folks at the top fancy themselves worthy of conscripting the rest of us into becoming uncompensated data collectors.  Doctors know that quality of care starts from the bottom, not the top —with a doctor, a patient, an exam room, and a conversation.  At best, ICD-10 will be an expensive distraction that draws money and time away from patient care.  At worst, it will paralyze the health care system.

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CMS Confirms Readiness to Assist During ICD-10 Transition

CMS Confirms Readiness to Assist During ICD-10 Transition | EHR and Health IT Consulting |

The ICD-10 compliance deadline of October 1 is less than a week away, creating a frenzy of preparation amongst coders, billers, and providers. The Centers for Medicare & Medicaid Services (CMS) senior officials recently held a conference call to answer questions regarding implementation, and specifically addressed the issue of CMS as a resource come October 1.

The September 24 call included CMS Principal Deputy Administrator Patrick H. Conway, MD, MSc, and ICD-10’s recently appointed ombudsman William Rogers, MD.

The bulk of the call consisted of a question and answer session which generally revolved around the roll of CMS as a resource for clinician practices experiencing issues with transition. Specifically, many callers were concerned with the potential government shutdown that could occur on October 1 if Congress cannot reach an agreement on the federal budget.

“In the event of a shutdown, we will continue -- and I want to be clear on this -- to pay claims,” Conway said. “We will continue to implement the ICD transition.”

Rogers made it clear that the Medicare administrative contractors (MACs) would still be working in the event of a shutdown, so claims will be accepted and paid during that time.

Conway elaborated on that point during another question, stating that payment systems are an essential part of the Medicare program and would still function in the event of a shutdown.

“In terms of staffing, we do have the flexibility to ensure core operations are operational and in effect,” Conway stated. “And obviously, our payment systems are a core piece of the Medicare program that will continue to be fully operational.”

Conway also addressed the issue of claims processing timelines and how that will affect real-time assessments of the transition. Although it would be ideal for CMS to have a clear idea of the state of the transition as soon as it occurs, Conway explains that due to the typical billing timeline, it will in reality take about one billing cycle.

“The Medicaid claims can take up to 30 days to be submitted and processed,” he said. “This end can take approximately two weeks. The Medicaid claims can take up to 30 days to be submitted and processed. For this reason, we expect to have more detailed information after a full billing cycle is complete.”

The questions on the call revolved around the cost of ICD-10 implementation, especially considering systems upgrades. According to Conway, the cost greatly relied on the specific circumstance of the practice or facility. Rogers shed light on the costs for smaller practices.

“[M]ost smaller practices just use a super bill,” Rogers explained. “t requires a little bit of an expansion of the number of diagnoses on the superbill. But they can easily cross walk their ICD-9 based super bill to an ICD-10 super bill.”

Rogers also assured callers that CMS has ample resources to ensure a smooth transition, and that they themselves will be able to serve as a resource for clinician practices. He explained that he, along with all of CMS, can serve as a major resource for providers who have questions regarding the transition process, and encourages providers to contact the ombudsman email address when in need of assistance.

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Epic Shows Inconsistent EHR Performance Internationally

Epic Shows Inconsistent EHR Performance Internationally | EHR and Health IT Consulting |
Different EHR vendors perform better in various different countries, according to a new KLAS Global Performance Report.

Despite having distinct popularity and success throughout the United States, Epic Systems is not necessarily the top-performing EHR product throughout the globe, according to a recent KLAS report.

The KLAS Global Performance report breaks down user-perceptions of various different EHR systems by region, such as Asia/Oceania, Europe, Latin America, the Middle East, and North America. Results show that although Epic Systems receives high praise throughout the US, and also performs well in Europe, the vendor does not have a stronghold in other regions.

The the best vendor performances in multiple regions, in fact, belonged to Cerner and Intersystems with high performances in Europe, Asia, and the Middle East.

One of the significant barriers vendors face in implementing their systems abroad are state contracts which limit certain functionality. Several companies, such as Cerner and Intersystems, have trouble implementing in Australia due to contractual issues.

Cerner’s implementation in the UK serves as an example of EHR systems that can be successfully implemented provided full adoption and fewer contractual limitations.

Although Epic is not seeing solid performances or high adoption rates in all regions, it is seeing success at larger health systems in other countries. Of the seven international Epic users interviewed, all of them reported full adoption of the systems, and strong functionality and support.

Vendors that do not see success at larger health systems include Allscripts and Phillips. Allscripts users report complications with implementation and support, while Phillips states that it faces difficulty garnering larger users to adopt their systems.

Cerner has garnered the most success throughout Europe, with the most ubiquitous successful adoption throughout the entire continent. That said, Epic has nearly 100 percent approval ratings from European users, though they are almost entirely located in one nation (the Netherlands).

As previously stated, Cerner’s clients in Australia are having difficulty with implementation. This is because of the way in which user contracts are established. Reported issues include a need for increased functionality, more system training, and increased systems optimization.

Despite Epic’s inconsistent international ratings, the EHR vendor continues to prove successful in the US. Between Epic’s many users’ awards, as well as Epic’s own honors, the vendor maintains its foothold as a health IT giant.

At the start of this year, Epic was awarded KLAS’s “Best in KLAS” award. Specifically, Epic won out in the Best for large ambulatory management category, among eleven other product awards.

Additionally, Epic won out in a recent Peer60 study of the physician-ranked most innovative EHR systems. Among the C-suite executives surveyed in the study, Epic won out as the overall best EHR system in operation. The vendor was also selected as one of the most intuitive and easy-to-use models on the market, and the top choice for CIOs.

Cerner and its users were also successful in the US this year, receiving KLAS’s best small ambulatory EHR award for 2014. Cerner also received two other KLAS awards in 2014.

In the aforementioned Peer60 study, Cerner was ranked as one of the most intuitive models on the market, as well as a top choice for COOs.

Perhaps most notably, Cerner was recently selected as the choice EHR for the Department of Defense EHR modernization project in partnership with Leidos Partnership for Defense Health. The partnership, which is currently valued at approximately $9 billion, was a significant feat for the EHR vendor.

“The Leidos Partnership for Defense Health is honored to have partnered with the Military Health System for nearly three decades, and we are committed to continuing our work in support of its mission to improve the health and medical readiness of our military,” Leidos representatives said in a public statement. “Our team stands ready to lean forward with the DoD to implement a world class electronic health records system.”

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Adapting to Flexibility in the Age of the EHR

Adapting to Flexibility in the Age of the EHR | EHR and Health IT Consulting |

I love traveling for a variety of reasons. One of the biggest is the ability to meet a diverse group of people who start as strangers and become friends. On a recent trip to San Francisco, I had breakfast with an IT professional working in the banking industry. Our conversation turned to the proliferation of data in both of our worlds, and how it can complicate the analysis and productive use of that data.

I have worked as a PA for more than 34 years, and have witnessed a dramatic transition of how we collect and view patient health records, from paper records and manual charting to the modern EHR and computerized physician order entry (CPOE) systems.

In my travel buddy’s banking world, similar to the medical world, data management is an expensive proposition. The size and complexity of the data expands exponentially every year. Software is the interface between professionals in our fields, allowing us to interpret and record information into this burgeoning database.

It has dawned on me on more than one occasion that the weak link in this whole system is the end user, and this is true for every industry. I have observed over the years the age diversity of physicians, PAs and others providers directing patient care within the healthcare system in the U.S. Prior to computers and digital data, we all charted the same way. The only tool that we all had was pen and paper. This has changed dramatically over the past ten years.

A number of policy changes on the federal level, as well as the Affordable Care Act, have driven a rapid transition to the EHR at every level of the healthcare system. A combined carrot and stick economic stimulus has been the force behind this transition. It has, at times, been challenging from a provider standpoint. I imagine that it has been the same from the corporate level.

I can only address the view from the trenches. What used to be a uniform documentation system has moved into one in transition. We don't allow anything but CPOE in our hospital. However, we still allow handwritten progress notes. Administration has moved gently in this area in order to cater to some providers’ lack of computer skills. While everyone is different, having practiced healthcare for many years, technology adoption can fall into several transitive groups.

Today’s recent medical professionals are highly computer literate, and have never touched a paper record, and never will. They can research a patient problem, FaceTime with their friends, text, and handle e-mail all at the same time, from a variety of devices.

Then, there is a middle group who have grown up in the computer era and have decent computer skills. They remember the paper era, but see the promise of the digital age and are able to keep their heads above water in the burgeoning digital age.

The last cohort is my age group, those nearing retirement who have spent the majority of their careers in medicine in the paper age. Many in this age group find managing technology to be a frustrating endeavor. However, with challenges and transitions come opportunities and I have seen many baby boomers and hospitals adapt to leverage more holistic systems. It simply takes patience and a little bit of flexibility.

That said, we have to be gentle in our expectations of the transition towards a digital world. Big organizations, like the one running the hospital in which I work, have deployed many resources towards easing the transition towards the EHR that are available 24/7.

Unfortunately, some providers in private practice might not be so lucky, and find themselves having to go it alone. Assisting all those at every level of EHR skill and ability is imperative toward full implementation of the EHR.

Patience is an important virtue in this transition. Nothing this difficult and complex can be done easily or quickly. However, by being reasonable and rational about the problem that we are trying to solve — being flexible and ensuring we are building tools that will ultimately allow us to better serve our patients — will help with the solutions towards dealing with the mountain of data that is burying every industry in the nation, service or otherwise.

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Are EHR Vendor Contracts Hindering Patient Safety Research?

Are EHR Vendor Contracts Hindering Patient Safety Research? | EHR and Health IT Consulting |

Adhering to patient safety standards is of vital importance when using an EHR, which is why proper review and research among different systems are critical for innovation. However, are supposed gag clauses in EHR vendor contracts inhibiting this kind of review and research?

A recent Politico article written by Darius Tahir presents considerable research into the matter. According to Tahir, EHR users are being completely prohibited from sharing adverse events and negative feedback regarding their EHRs. This stems from different gag clauses included in EHR vendor contracts, and seriously affects innovation that can help improve patient safety.

But HealthAffairs article by Kathy Kenyon, JD, MA, tries to clarify many of the legal implications of EHR vendor contracts, and discusses the realities of the “gag clauses.”

According to Kenyon, gag clauses in EHR vendor contracts do not necessarily prohibit users and researchers from offering negative feedback regarding their EHR systems. However, as soon as users or researchers include a screenshot of an EHR screen in their critique, they are breaching the “gag clauses” that actually deal with protecting intellectual property.

Kenyon states that many EHR vendor contracts include clauses that prohibit users from publically sharing screenshots of the EHR while reviewing the product without vendor permission. These clauses exist to protect the intellectual property of EHR vendors.  However, they are actually quite vague and unclear, giving vendors the power to prohibit potentially vital research that could improve the EHR for patient safety.

The true ‘gag clause’ problems with EHR vendor contracts appear to be related to the confidentiality and intellectual property terms, which are overbroad and unclear, and limits on ‘authorized uses’ of the EHR, as those terms apply to research and reporting that requires access to the EHR and use of screenshots,” she writes.

Furthermore, when researchers are able to access screenshots to share information for system improvement, vendors are given a high level of control regarding what system information is released. This potentially prevents unbiased information from being published, hindering the improvement process.

“As long as researchers must ask vendors for permission to do research or to publish screenshots, and as long as vendors can deny permission for any reason, including not liking the results, there is a serious danger that research will be designed and findings presented in ways that garner vendor permission,” she writes.

Kenyon points out that these clauses exist to protect the intellectual property of EHR vendors. The vendors are concerned that should information regarding the look and functionality of their software be released to the public, other vendors may steal these features. This would cause vendors to lose “competitive advantage,” Kenyon says, and would hurt the business of the EHR industry.

Kenyon says that many EHR users state that this fear of vendors is not entirely well-founded considering the ease with which competitors are able to gather information regarding a certain EHR.

“ is not that hard to discover what different EHRs look like. For vendors hoping to improve their EHRs by ‘stealing’ from others, waiting for research with screenshots to be published would be an exceptionally inefficient way to do so,” she writes.

Furthermore, many physicians maintain that no price can be put on the safety of patients, Kenyon reports.

Kenyon maintains that under existing contracts, the provisions made to protect intellectual property are not functional for researchers. To increase patient safety while using EHRs, different standards are going to have to be implemented, Kenyon suggests.

“Stakeholder groups for patient and EHR safety, including parties to EHR contracts, should share interests in making health IT safety-related research and reporting as easy as possible,” Kenyon explains. “EHR vendor contracts should reflect as much consensus on these issues as is possible.”

She continues to provide suggestions for the construction of future EHR vendor contracts, stating that there should be no gag clauses, but rather clauses that encourage research and encourage reporting of adverse outcomes. By identifying these areas for improvement in EHR vendor contracts, research and adverse event reporting may potentially help increase patient safety.

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ICD-10 Compliance a Struggle for Some Physician Practices

ICD-10 Compliance a Struggle for Some Physician Practices | EHR and Health IT Consulting |

October 1 has come and gone, and nearly two weeks in to ICD-10 compliance most of the healthcare industry is relatively mum on the transition to the newer clinical diagnostic and procedural code set. More than likely, healthcare organizations and professionals are busy enough adapting to ICD-10 and its more specific set of codes.

That’s not to say some are not speaking out or in support of ICD-10 compliance.

Two recent weekend reports in the Florida’s Crestview News Bulletin and Maine’s Bangor Daily News paint two very different pictures of ICD-10 compliance at the two-week mark.

Apparently, some physician practices in the Florida panhandle are going through the motions in adapting to the federal mandate for ICD-10 compliance which began back on October 1. Brian Hughes reports that medical offices are encountering difficulties with the code set.

“Large practices and medical companies, such as Peoples’ Home Health, usually have coders on staff. Their only job is to enter the numbers into billing records and insurance reimbursement forms,” he writes. “For smaller offices like Dr. Herf’s and Mir’s, the increased coding tasks take away staffers’ time with patients.”

Betty Jordan, the manager of physician practice of Abdul Mir, MD, views ICD-10 as more of a hindrance than a help.

“It requires so much extra work. If my doctor treated someone for rheumatoid arthritis, there’s hundreds of codes. It’s got to be specific,” she told the Crestview News Bulletin.

“It is horrible for a primary care doctor,” she further revealed. “For a specialist, they deal with the same things over and over. For us in family practice, we see all kinds of things. It’s overwhelming.”

For an administrator at the practice of David Herf, MD, the challenge of ICD-10 compliance is the result of increased specificity being married to an increase amount detail.

“It’s really, really detailed,” Andrew Linares told the news outlet. “Instead of just saying, ‘cyst of the arm or trunk,’ you have to get really specific.”

For one of the physician practices, adapting to ICD-10 is akin to learning a whole new language.

The climate in Maine appears much sunnier regarding ICD-10 compliance. Jen Lynds reports high levels of preparation among Maine healthcare organizations and professionals leading to a smooth transition.

“Health care providers across the state began working Oct. 1 with a new system of medical codes that has them describing illnesses and injuries in more detail than ever before, and officials from hospitals and medical associations said earlier this week that they are prepared for the challenge,” she writes.

According to Gordon H. Smith, the Executive Vice President of the Maine Medical Association, complaints are scarce as are ICD-10 implementation delays. Director of Communications for the Maine Hospital Association reports the same situation.

That being said, leadership at Eastern Maine Medical Center are preparing for transition-related productivity decreases for coders and billers used to the previous code set. However, things are still proceeding as planned.

“Our transition to ICD-10 has gone very smoothly here at Eastern Maine Medical Center,” Director of Coding and Clinical Documentation Improvement Mandy Reid told the Bangor Daily News. “We are using nine contract coders through outside vendors to support the ICD-10 go-live, and we secured them several months ago to be prepared. We also have added three positions in the outpatient area to help support growing volume, as well as ICD-10 coding.”

The lesson learned so far is that a clinical practice’s ability to invest in ICD-10 preparation (e.g., training) correlates to its present-day confidence in ICD-10 compliance.

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NIST Ties Limited EHR Usability to Patient Safety Risks

NIST Ties Limited EHR Usability to Patient Safety Risks | EHR and Health IT Consulting |

The National Institute of Standards and Technology (NIST) has issued new guidance for ensuring patient safety by improving EHR usability.

The results from a technical evaluation, testing, and validation of EHR usability list three "major critical risk areas: the EHR data identification, EHR data consistency, and EHR data integrity.

"Ultimately, the data from this study demonstrate that during safety-critical tasks and times, patient safety is negatively affected, in part because mistakes and critical use errors occur more frequently and because users are highly frustrated, and thus more likely to employ workarounds, such as relying upon supplemental artifacts, e.g., paper ‘shadow charts’ or whiteboards," the authors conclude.

The NIST report identifies a handful of ways EHR problem areas contribute to inadequate patient care:

  • clinically relevant information being unavailable at the point of care
  • lack of adequate EHR clinical documentation
  • inaccurate information present in the clinical record
  • inability to retrieve clinical data

Based on empirical analysis of inpatient and ambulatory EHR use, the NIST document proposes three EHR usability enhancements that EHR technology incorporate to eliminate or reduce risks to patient safety.

The first centers of how critical patient identification data is presented. According to NIST, this information should be presented in a reserved area. The authors of the report recommended reserving the upper left-hand corner of all screens or windows and remain persistent regardless of scrolling or navigation throughout the EHR. Additionally, they hold that a patient's name appear with last name first, followed by first and middle names, modifiers, data of birth, age, gender, and medical record number (MRN) number. For EHR mobile technology, the NIST guidance allows for the presentation of this information horizontally to maximize screen space.

The second enhancement calls for the use of visual cues to "reduce risks of entering information and writing orders in the wrong patient's chart." The enhancement would prevent EHR users from entering information into multiple charts simultaneously as well as visually different between read-only and editable charts. Under this guidance, EHR users would have to deliberately enable the software to move between charts and maintain unrestricted access and provide clear cues when an EHR user moves between charts.

The third and final enhance places an emphasis on supporting the effective identification of "inaccurate, outdate, or inappropriate items in lists of group information by having information presented simply in a well-organized manner." The NIST document contains several examples:

3.1 Lists of patients assigned to a particular clinician user should be presented in consistent, predictable locations within and across displays and print-outs and the content should not vary based on display location.

3.2 The status of a note and order as draft as compared to final shall be clearly indicated on appropriate displays.

3.3 Clearly indicate the method by which the system saves information, whether auto-save or requiring deliberate action to save, or combinations thereof.

3.4 Inputted information should be automatically saved when a user transitions from one chart to another.

3.5 The language used should be task-oriented and familiar to users, including being consistent with expectations based upon clinical training.

3.6 Enable a user to easily order medications that have a high likelihood of being the appropriate medication, dose, and route. The likelihood is increased when displays are tailored to specialty-specific user requirements, comply with national evidence-based recommendations, are in accordance with system, organizational, unit, or individual provider preferences specified in advance, or are similar to orders made by the same physician on similar patients, on the same patient in the past, or providers with similar characteristics.

3.7 Support assessing relationships of displayed information and allowing users with appropriate permissions to modify locations and relationships for inaccurately placed information, including laboratory results, imaging results, pathology results, consult notes, and progress notes. This includes information within a single patient’s chart as well as information placed in the wrong patient’s chart. The information about the time and person that made the change should be viewable on demand.

On top of these recommendations, the guidance provides two use cases to illustrate the components of EHR usability testing in identifying and mitigating potential patient safety risks in both inpatient and outpatient settings. 

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Ensuring Quality Throughout the Evolution of Clinical Documentation

Ensuring Quality Throughout the Evolution of Clinical Documentation | EHR and Health IT Consulting |

Throughout my HIM career, I have seen many different methods of capturing clinical documentation. We are always looking for solutions to get accurate and complete clinical documentation into the medical record in a timely manner with minimal disruption to the provision of care. The processes for gathering documentation have evolved with advances in technology and HIM professionals have been very involved in ensuring the quality of the documentation.

When I first began working in an HIM department, we had a Transcription department with hospital-employed transcriptionists and a management team devoted to medical transcription. Quality reviews were performed regularly and the transcriptionists had an ongoing relationship with the physicians to provide feedback and get clarifications. As part of this department, there were file clerks in charge of filing the transcribed documents onto the paper medical records throughout the day and into the night. When I think back on these practices, it seems like an entirely different lifetime from today’s practices yet it really wasn’t that long ago.

Over time, transcriptionists began to disappear from hospitals as the task became outsourced. Vendors have offered to do the job for less cost and they guaranteed a high quality rating of the transcribed reports. However, transcribed reports often still come back to the medical record with blanks and anomalies that must be corrected by the dictating clinician which can delay the documentation reaching the chart. It’s important to review documents to make sure there are no obvious errors that may have been misinterpreted by the transcriptionist or the back-end speech recognition system.

Many are still relying on outsourced transcription as a major source of capturing documentation but this is evolving as EHRs have created new opportunities for documentation. EHRs provide documentation tools such as templates to import data into the notes and allow for partial dictation for the narrative description. The negative side of this is that copy and paste is used frequently due to the ease of grabbing documentation from the rest of the EHR and pasting it into the note to save time. Clinicians using copy and paste may not realize that the information could be outdated or it could be against company policies. This now requires quality reviews to monitor the use of copy and paste and the relevance of the documentation to maintain the integrity of the medical record. This should be incorporated into chart audits or other quality review processes.

Front-end speech recognition tools are popping up frequently as an additional tool to capture documentation. A concern with this is the shift from having quality reviews performed by the transcriptionist to now relying on the clinicians to edit their documentation as they dictate. Many are creating positions in HIM departments to perform quality reviews on the documentation to not only ensure the documentation is in the record in the adequate timeframe but making sure the documentation is accurate for each patient. It will be interesting to see how clinical documentation continues to evolve as new methods of capturing documentation are developed and deployed. No matter how the information gets into the medical record, HIM professionals still have the ultimate responsibility to ensure the quality of the documentation for patient care and appropriate reimbursement.

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For Stage 2 Meaningful Use Attestation, Pick a Larger EHR Vendor

For Stage 2 Meaningful Use Attestation, Pick a Larger EHR Vendor | EHR and Health IT Consulting |

Larger EHR vendors tend to make better partners in achieving Stage 2 Meaningful Use, according to a recent study by Peer60. The study, which discusses insights and trends in EHR vendors, sought to identify the which vendors play a bigger and more supportive role in providers’ work to achieve meaningful use.

According to the report, users of notable vendors such as Epic, Cerner, and Allscripts stated that these technology partners delivered adequate support for their efforts to meet meaningful use. Among these vendors, many users also reported being in the midst of attesting to Stage 2. Epic also had several respondents report that it was not an adequate partner in Stage 2 attestation, but given the high volume of users Epic engages with, the positive reviews significantly outweigh the negative.

Other vendors did not receive such favorable reviews, according to Peer60. Among those is McKesson, who received nearly double the percentage of negative reviews as positive ones. McKesson also has a substantial number of users who report still being in the process of attesting Stage 2. A few smaller vendors also received negative meaningful use reporting reviews, including NextGen and Practice Partners (which is owned by McKesson).

Of the practices surveyed, nearly 90 percent of them have either achieved Stage 2 or are in the middle of attestation. Fifty-six percent of respondents had successfully completed Stage 2 attestation, and 34 percent were in the thick of attesting. Only 10 percent had not successfully attested, and Peer60 reports that about half of those who had not been successful “simply don’t have the proper model to receive enough benefits to bother attesting.”

This report comes out after CMS released data regarding meaningful use registration and participation. Given that data, it appeared as though the delay in the release of the meaningful use modificationrules was hindering program growth. According to CMS, meaningful use enrollment stayed stagnant between the months of May and August. Medicare eligible professional (EP) enrollment also remained relatively the same between May and July, and skyrocketed in August. Likewise, eligible hospital (EH) enrollment stayed consistent between May and July and made a notable jump in August.

Now that the Stage 2 Meaningful Use Modifications Rule has been released, the rate of EHR Incentive Program enrollment may increase. Because the modified rule eliminates unnecessary and cumbersome requirements, as well as shortens the initial reporting period to 90 days, it is expected that more providers will enroll in the program and will be able to achieve success.

However, success could potentially be better facilitated by an EHR vendor that is more supportive and provides a product that works better with meaningful use. As such, EHR vendors may need to adjust their practices in helping providers meet meaningful use guidelines in order to remain competitive in the EHR market.

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A Coding Tool that Supports the Needs of Providers

A Coding Tool that Supports the Needs of Providers | EHR and Health IT Consulting |

It happened. The switch flipped and on Oct. 1, our healthcare system went from around 14,000 diagnostic codes to 68,000 codes with the final implementation of ICD-10. No “Y2K”-style catastrophe. No computer system meltdowns.

We will now be watching for the long-term effects of this change. Will the processing of payments for healthcare services in the United States be adversely affected by this transition? We won't know the answer to this for some time.

As the EHR guru for my private practice, I have been responsible for the transition on the local level. This means making sure that our software is up to date and ready, and our various billing documents and their associated procedures are ready to communicate ICD- 10 information to our billers.

Additionally, as an EHR "superuser" on the medical staff of my community hospital, I watched transition issues and steps very closely in preparation for the transition. I have to say that I have been pleasantly surprised with both the administration of the hospital, as well as with the IT folks and on-site EHR vendor staff, in making this transition as painless as possible.

I have written before about how, in this phase of EHR development, the EHR has focused on the needs of the system (i.e. meaningful use, billing, etc.) and not the needs of the providers in making the process of documenting our care as smooth and easy as possible. In the most recent major upgrade to the industrial strength EHR system, significant strides forward were achieved in making the providers’ lives easier.

The first was to make customizable specialty view landing pages that facilitated EHR use to document patient encounters in a very linear and intuitive process. I have been documenting patient care with the EHR for more than three years now, and this one change was a huge step forward in using my time efficiently on rounding in the hospital.

The second major change in the hospital's EHR was simplifying the coding tool. From within the landing page, you just click on diagnosis, and start with a simple search term like "breast neoplasm." This immediately presents you with vertical lists in columns, from left to right. As you make choices in the columns (e.g., disease specifics, anatomical location, laterality, etc.) the choices rapidly narrow, and the coder lets you know through visual clues when there is sufficient information for a complete ICD-10 code. Whoever designed this deserves a medal.

I have worked with physicians and showed them how to use the landing page, as well as the diagnosis tool, and early and late adopters have both been able to adjust their way around the software quickly - indicating a sign of intelligent, user-friendly design.

I have been told by the vendor support staff that the new focus on supporting the needs of the providers will bring tablets and tools to the floor of the hospital, which will make the end user experience much better, time efficient, and useful. This has not happened just yet – one step at a time - but I remain bullish on the promise of the EHR.

I'm hopeful that the world of the EHR is moving to a new phase; a phase that focuses more on making the processes of documenting patient care easier, faster and more intuitive. Good data flows uphill, and makes the other outputs of the EHR more cohesive. The coming weeks, months, and years will ultimately tell the tale of this transition to ICD- 10, but I’m hopeful that it will ultimately give us the information and data we need to make a difference in the healthcare system and in the lives of our patients. 

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AMA Urges CMS to Give Hardship Exemptions for Meaningful Use

AMA Urges CMS to Give Hardship Exemptions for Meaningful Use | EHR and Health IT Consulting |

As the waiting game for the Stage 3 Meaningful Use final rule and Stage 2 modification rule continues, the American Medical Association (AMA) is calling on the Centers for Medicare & Medicaid Services (CMS) to start taking actions to account for their delay. According to a recent press release, AMA is asking CMS to make an automatic hardship exemption due to the delay in the final rule’s release.

According to AMA President Steven J. Stack, MD, many physicians with the AMA are concerned that they will not be able to meet meaningful use standards because the details of the Stage 2 modification rule have not yet been released.

“The AMA has regularly stressed that CMS must finalize Meaningful Use modifications well ahead of Oct. 1 to provide the time that physicians need to plan for and accommodate these changes, yet CMS has continued to delay finalizing this rule,” says Stack. “As a result, many physicians who were counting on this flexibility will be subject to financial penalties under the rules currently in place.”

An automatic hardship exemption would exempt providers of financial penalties if they are not able to meet certain meaningful use standards. CMS developed hardship exemptions for providers who can demonstrate that adhering to meaningful use rules would cause a considerable hardship. AMA maintains that the considerable delay in the final rule is viable cause for an automatic hardship exemption.

The AMA is not the only organization expressing distress over the meaningful use final rule. Many entities, such as the Medical Group Management Association (MGMA) are calling on CMS to extend the meaningful use reporting period due to the delayed final rule.

The organization is concerned that medical groups will not have time to report for the final 2015 reporting period if not given adequate notice of the new EHR Incentive Program modifications.

MGMA stated that even if the modifications rule had been announced in early September, providers still would not have had adequate time to adjust workflows for the final reporting period beginning on October 3. Instead, MGMA suggested CMS extend the reporting period to either the first 90 days of 2016, or the final 90 days of 2015.

Other entities, such as the College of Healthcare Information Management Executives (CHIME), have simply urged CMS to release the modification final rule sooner. CHIME, in addition to several other co-signing industry stakeholders, states that CMS withholding the final rule is preventing providers from having adequate time to prepare to the program modifications.

CHIME reiterated that many industry stakeholders commend CMS’ efforts to refocus meaningful use standards, but feels as though inadequate time is being given to providers to make their own adjustments in time for the October 3 final reporting period.

As the final reporting period is mere days away, CMS will need to release the final rule for the meaningful use modifications soon, or many providers will be left unable to meet the final reporting deadline.

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Senator Gives 5 Reasons to Delay Stage 3 Meaningful Use

Senator Gives 5 Reasons to Delay Stage 3 Meaningful Use | EHR and Health IT Consulting |

Joining the group of critics of Stage 3 Meaningful Use, Senate Chairman of the Committee on Health, Education, Labor, and Pensions (HELP) Lamar Alexander (R-TN) urged the administration not to move forward with the rule in a statement before administration officials, according to a press release.

Alexander advocated against implementing Stage 3 Meaningful Use rules, stating that doing so would be a detriment to the administration’s goals of providing better and more coordinated care for patients. Using that logic, Alexander stated that there was no downside to taking their time in developing an effective and manageable rule, while giving providers adequate time to achieve Stage 1 and Stage 2 Meaningful Use.

Alexander continued by underscoring the importance of the meaningful use programs in achieving broader goals within the healthcare industry, such as goals for precision medicine and transitioning Medicare payments to value-based payments. Because of the high-stakes surrounding meaningful use, Alexander argues that it needs to be developed carefully in order for it to be effective and successful.

In his testimony, Alexander listed five reasons why the administration should delay the Stage 3 rule:

Stage 2 Has Not Yet Been Successful

First, Alexander explained how Stage 2 Meaningful Use has not yet been successful, citing the statistics that a mere 12 percent of physicians and 40 percent of hospitals have managed to achieve Stage 2 success. It would make more sense, Alexander argues, to pause Stage 3 implementation and allow providers more time to comply to Stage 2.

Medicare Payment Issues Meaningful Use Penalties

In Medicare’s transition from fee-for-service payments to value-based payments, the program has put a priority on providers meeting meaningful use standards. Because of this, providers will face harsh penalties if standards are not met. To that end, Alexander explains, it is important that providers be given ample time to properly meet these standards.

Industry Leaders Also Recommend a Stage 3 Delay

Alexander states that the general consensus that he has gathered amongst prominent providers is an overall fear of Stage 3 rules.

“Physicians and hospitals have said to me that they are literally ‘terrified’ of stage 3, because of the complexity and because of the fines that will be levied,” he explains.

Stage 3 Requirements May Actually Hinder Interoperability

A leading goal for the administration includes the interoperability between EHR systems. However, a recent GAO report which Alexander commissioned stated that many industry stakeholders find thatmeaningful use rules hamper interoperability. This is because they concentrate on achieving program requirements rather than on effectively achieving interoperability.

The Final Rule Should Match the Legislation’s Primary Goals

When developing the meaningful use programs, the administration identified seven goals for the program. Alexander argues that meaningful use rules should match and enhance these goals. The seven goals include:

  1. Decreasing unnecessary physician documentation;

  2. Enabling patients to have easier access to their own health records;

  3. Making electronic health records more accessible to the entire health care team, such as nurses;

  4. Stopping information blocking

    1. This could be described as intentionally interfering with access to my personal health information;

  5. Ensuring the government’s certification of a records system means what it says it does;

  6. Improving standards; and

  7. Ensuring the security and privacy of patient records.

Alexander suggests a timeline that would begin with phasing in Stage 2 Meaningful Use modifications, aiding providers in achieving that step of the overall program. From there, Alexander suggests the administration phase in subsequent stages “at a rate that reflects how successfully the program is being implemented.”

Alexander has advocated for delaying Stage 3 Meaningful Use before. Recently, he and Senator John Thune cosigned a letter to HHS Secretary Sylvia Matthews Burwell. In the letter, the two request that the final rule for meaningful use not be implemented until January 1, 2017 at the earliest. This letter, along with Alexander’s testimony before the administration, are just two examples of congressional resistance to the final rule.

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EHR Integration Target of DoD EHR Modernization Subcontract

EHR Integration Target of DoD EHR Modernization Subcontract | EHR and Health IT Consulting |

The Leidos-led team that won the Department of Defense Healthcare Management System Modernization (DHMSM) award — that is, the DoD EHR modernization project — has made another addition to its squad for the purposes of health IT integration and health information exchange.

The Leidos Partnership for Defense Health now includes Orion Health as a subcontractor, the health IT company announced Monday.

"Orion Health is proud to be part of the Leidos Partnership for Defense Health, the team that has been selected as the best value solution for the DHMSM contract," President Paul Viskovich said in a public statement.

"Together, our qualified and experienced team is working with the Department of Defense to deliver a world class interoperable electronic health records solution for our nation’s armed forces, their families and beneficiaries," he continued. "We look forward to the work ahead and are committed to improving access to comprehensive healthcare data in order to facilitate improved clinical outcomes for our deserving men and women in uniform."

According to the statement, the partnership is looking to take advantage of the company's health IT integration engine to facilitate the exchange of health data between the DoD Cerner EHR and the health IT systems of non-military healthcare organizations and providers.

Last month, the Leidos Partnership for Defense Health added Clinovations Government + Health to spearhead the team's training of "clinicians, nurses, clinical advisors and clinically-trained technical personnel to help the delivery team ensure the resulting solution is finely tuned for the military’s medical environment."

The focus now appears to be shifting to the technical nuts and bolts of ensuring that health data flows inside and outside the Military Health System, a decisive factor in the Leidos bid winning the DHMSM contract.

"Cerner’s demonstration of wide-ranging provider interoperability on multiple, different platforms were the huge differentiator over Epic’s garden-walled methodology to system user data sharing," Black Book Managing Partner Doug Brown told when the contract was awarded.

As part of the Leidos-led bid, Cerner beat out rivals Epic Systems and Allscripts for the project that could approach $10 billion when all is said and one.

According to research published by IDC Health Insights, financials also proved to be a key differentiator between the Cerner- and Epic-backed bids.

"The DoD's requirements are unique, which makes comparisons difficult, but pricing was surely a critical factor in the DoD decision," the research organization stated. "IDC Health Insights views the pricing of the winning bid as having come in quite low when compared with commercial EHR contracts in recent years. This gives the DoD the potential to realize higher ROI from its EHR investment than is likely possible at many private health systems."

The company will be hosting its annual user conference next week and new details about the DoD EHR modernization project are likely to emerge.

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Why Our Independent Practice May Be at Its End

Why Our Independent Practice May Be at Its End | EHR and Health IT Consulting |

We are many things: husband and wife, doctor and administrator, and parents. When you first meet us we appear pretty vanilla, but in fact, in our lives, when we come upon two metaphorical roads diverged in a wood, we often choose the one less traveled by. This month, on September 9, we celebrated 15 years of marriage and took time to reflect on our path so far and where we think we're going next.

Here are a few unusual choices we've made along our path so far. We met on in 1999 when very few people did that. We got engaged only six months after meeting and married nine months after that. Uncle Sam paid for Terence's medical school education which meant we spent the first six years of his career — and our marriage — as an active-duty military couple. The Air Force took us away from our home state of Massachusetts; we lived three years in Dayton, Ohio, and the next three in Albuquerque, New Mexico. In 2006, we opened our solo pediatric micro-practice even though everyone, including our accountant at the time, told us it couldn't be done. And in 2008, we met a beautiful four-and-half-year-old little boy whom we adopted a year later.

From 2006 to 2014, our micro-practice model worked well for us. We enjoyed an average income for primary-care pediatricians in our area all while maintaining work-life balance and giving patients long appointments that run on time. We also continually received high marks on patient satisfaction surveys and performed very well on the quality measures set by our independent physician association (IPA). And, because we were small and flexible, it was easy for us to adapt to changes, like integrating behavior health, into our model. It's not that small practice ownership has even been simple, but until recently we could make it work.

Our model in 2015, though, has stopped working as well. Understanding why our revenue is down, over 20 percent, is pretty easy and almost all due to the consolidation of insurance companies. To be clear, our problems are not at all uncommon; we see many primary-care peers, in all sorts of different practice models, suffering for the same reason. We are losing confidence that any independent practice model has the power to survive against the oligopoly of powerful insurance payers.

The pressure to abandon independence, and along with it the many benefits to ourselves and our patients, is increasing exponentially. The day is drawing near when we must choose between the road everyone else is taking —namely to abandon independence — or find a more creative road less traveled. For now, we appear to be on a single-lane, one-way highway to selling out without an off ramp to stay independent in sight.

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