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In part 1, we discussed just what is meant by a meaningful user and in part 2 we touched briefly on some of the changes made in the meaningful use rules from the proposed rules to the final rules. Whereas initially there was an 80% threshold that had to be met for pretty much every objective, after much discussion and consideration, CMS agreed that for some of these measures that was too high a bar to jump.

Here is a nice summary of the final rules thresholds for each of the meaningful use objectives and measures. Thanks to Robin Raiford, RN, from the HIMSS Legislation and Regulation Review Task Force, for providing us with this great resource.

It’s too detailed to see clearly on the website so….

RIGHT-CLICK HERE to download the PDF file

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We are a little over two years into our electronic medical records implementation at the time of this writing. Since we have been performing a gradual rollout, the entire process has been relatively uneventful. Most of the credit for this goes to our chief information officer (technospeak for the head of our IT department) and our practice administrator.scanning to emr

One of the biggest challenges we have been facing is how to convert all of the paper records into electronic ones. Since we started our EMR implementation with just new patients, we initially were entering brand-new data on those patients and there wasn’t anything to convert. But as we started adding established patients – those patients that had an existing paper chart – we had to deal with two issues: how much of the paper chart do we convert to a digital format and how do we make the majority of the existing clinical history available to the physician? Before I tell you what we did, let’s discuss some options for dealing with conversion of paper records to electronic records.

  1. All patient charts are scanned into the electronic medical records (EMR) system. If your practice is running out of physical office space, as we were, this is an attractive option. Unfortunately, it is easy to Read the rest of this entry »

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In part 1, we introduced the different stages of meaningful use criteria as defined by CMS in their final rules, released July 13, 2010. Many practices and hospitals breathed a collective sigh of relief on the one hand, as several criteria had thresholds that were less onerous than were originally proposed. It seems that CMS has been listening.

Thresholds for CPOE and e-Prescribing

For example, as we mentioned earlier, the threshold for meeting criteria for CPOE (computerized physician order entry) is now set at 30%. This means that only 30% of unique patients (not total patient visits) need to have at least one order entered into the electronic medical record system to meet those goals.

Another example is electronically transmitted prescriptions or e-Prescribing. Originally set at 75% of “permissible prescriptions”, this has been dropped to “at least 40%”. This was due in part to objections that (1) some pharmacies are not quite ready to accept e-Prescribing and (2) some patients insist on getting a paper prescription.

Structured Data vs Unstructured Data

Along the subject of prescriptions, an active medication list must be maintained on patients (with the default threshold of at least 80% of unique patients) in the form of “structured data”. Structured data refers to data that can be identified by the EMR system. In other words, Read the rest of this entry »

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On Tuesday July 13, CMS released the final rule for adopting a certified electronic health record (EHR) system.

After listing about 60 acronyms and abbreviations (and it’s impossible to remember them when reading the subsequent text), what follows is approximately 800 pages of proposals, related comments, and final rulings.

All this is to spell out the meaning of meaningful use (which we first touched on in October ), how to be considered an EP (eligible professional) and when said EP can expect to first receive any kind of incentive payment – for the early adopters, the first “payment year” is calendar year (CY) 2011.

When you actually receive the payment could be the end of the following calendar year). Hospitals will typically be incentivized on a fiscal year (FY) basis.

We’ll attempt to digest this compelling tome, one 100-page piece at a time (or so). Keep in mind, though, that this is only what CMS considers “Stage 1″ of the meaningful use criteria. Stage 2 criteria are expected by the end of 2011 and Stage 3 criteria by the end of 2013. The idea is to have an “initial graduated approach to arriving at the ultimate goal”: total enlightenment of EMR, I suppose.

As we previously mentioned, a meaningful user is one who:

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A recent post on the Wall Street Journal’s Health Blog reported on an interview with a professor of law and bioethics who believes that electronic medical records will bring on a whole host of liability issues for medical practitioners. Sharona Hoffman writes in “E-Health Hazards: Provider Liability and Electronic Record Systems,” which appears in the Berkeley Technology Law Journal, that while “the potential benefits of computerization are considerable,” digitized medical systems also “may bring novel responsibilities, burdens and complexities for medical practices,” including a whole new rash of medical malpractice worries.

Some of these worries are legitimate, such as possible “bugs” in software systems which may affect computerized prescriptions or physician orders. Although actual examples of these seem to be hard to find.

Others, on the other hand, sound a little dramatic: “Some systems are so complicated they actually hinder the ability of the doctor [to care for the patient]. Doctors have only about 15 minutes per patient, and more of that time may be spent trying to fiddle with the computer — it can take time away from patient interaction.”

Needless to say, most physicians are bright people. We would expect that they would get a little training before they unleash any device on a patient, whether it is a medical instrument or an EMR system. Professor Hoffman says, “They need to be getting trained if they have an electronic health record system — saying ‘I have a computer so I can figure it out’ [doesn't work]“. This sounds a little bit patronizing. Then again, we all know colleagues who have used something without reading the manual first.

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According to a report on FierceEMR.com, the CMS has announced that by July 14 it will release its final ruling on the EMR “meaningful use” standards which will finally spell out just how healthcare providers can become eligible for the HITECH (Healthcare Information for Electronic and Clinical Health) Act financial incentive payments.

In addition, it will presumably unveil its plan for aligning its Physician Quality Reporting Initiative (PQRI) with the EMR financial incentives program.

“We propose to include many ARRA core clinical quality measures in the PQRI program, to demonstrate meaningful use of EHR and quality of care furnished to individuals,” CMS states in an advanced copy of the proposed reg, CMIO magazine reports. “We propose the selection of these measures to meet the requirements of planning the integration of PQRI and EHR reporting.”

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One of the most common questions we get is, “How to we qualify for the financial incentives for EMR implementation?” Even so, we would think this should be everyone’s number one question. After all, the costs of both the EMR software and the associated hardware are not insignificant. Who is going to pay for all of that? You are.


But what if the government gave you a nice, fat check for your efforts? Say, about $44,000 per provider over the next five years?

Ah, but there is a catch. Or, several catches to be exact. These fall under the area of what is known as “meaningful use“. In order to qualify for these funds, a provider must be able to show he or she has met certain goals or objectives.

Medical Practice Trends has partnered with the folks at SoftwareAdvice.com to give you a guide on How to Qualify for EMR/EHR Stimulus Funds.

Click Here for more information

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As if physicians didn’t have enough to concern themselves with regards to HIPAA, new healthcare legal guidelines are about to make things much more complicated. But first, let’s take a closer look at the regulations regarding the protection of patient information.

Legislation. HIPAA (the Healthcare Information Portability and Accountability Act) has provisions requiring the safeguarding of “protected health information” (PHI). Specifically, this sets out the rules for encryption of the data so that if it falls in the wrong hands, the information is safe and sound. Fair enough. But what kinds of data are covered under this definition? We’ll discuss that a bit later.

Enter the HITECH Act (Health Information Technology for Economic and Clinical Health), part of the American Recovery and Reinvestment Act or Stimulus Bill of 2009. With it comes another set of verbiage regarding protection of PHI data. Now, the HITECH Act itself doesn’t require encryption of the data. It specifies the kinds of encryption that makes the data secure. For guidance on the specific requirements, HITECH punts back to HIPAA.

But what HITECH has done is to allow for sizeable increases in fines for violating provisions of HIPAA for not only “covered entities” such as medical practices, but also for what are known as business associates, those entities such as medical supply vendors who work with covered entities. Practices should be careful with whom they make formal contractual agreements, specifically if those parties have any access to patient information; any infringement on the part of a business associate may bring investigators to your front door.

HITECH also sets more stringent provisions for what are known as breach notifications. Entities who have had data compromised are required to Read the rest of this entry »

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Guest Post
By Dr. Greg Forzley and Mr. Tony Onorad

As health care organizations of all sizes struggle to meet the challenge of electronic health record adoption and meaningful use, one recurring theme is common: How to effectively educate learners on both the new and / or adapted processes resulting from the implementation of the new system and the necessary skills to use the new technologies in order to efficiently execute those processes. Physicians in particular may feel challenged to learn how to use a particular EHR or EMR with the skill and finesse needed to balance patient care activities with the capture of information in the electronic record.

As Dr. David Blumenthal, National Coordinator for Health Information Technology (ONC), succinctly surmised in an April 2009 interview:

“Simply having an EMR system isn’t enough. We need to ensure that physicians can actually use it.”

It is important to understand the distinction between an EMR and an EHR. A clearer definition can be found in the April 28, 2008, report to the Office of the National Coordinator for HIT, “Defining Key Health Information Technology Terms:”

With the recent Federal legislation, it is clear that the focus will be on EHRs and their ability to share information securely across health organizations. In order to meet meaningful use standards and, more importantly, in order to provide more efficient and safer patient care, EHR users must be equipped with the knowledge that they need to successfully use any system they be required to use for patient care.

A key component to an EHR’s success is a clearly defined, measurable, and effective strategic knowledge improvement plan. This is not just an important component of the initial implementation, but critical to the long-term success and vibrant use of EMR technology.

Five major pieces to successful strategic knowledge improvement plans include:

I. Successfully Managing Change
a.  Answer “Why are we doing this?”
b.  Answer “What’s in it for me?”
c.  Articulate the benefits and features.
d.  Purposefully review and communicate the process, including timelines.
e.  Set realistic expectations (we’re not flying to the Moon on Day One).

II. Implementing Readiness and Skills Assessments
a.  Assess current, basic PC and Windows skill levels (not everyone knows what a radio button or a “right” click are). Don’t take the learner’s report of skill level without an assessment verification tool.
b.  Ensure that all learners’ basic skill sets (i.e., Windows and PC) meet a minimum proficiency level prior to go-live training.

III. Designing Knowledge Improvement Approach
a.  Key concept: Implement role-based training – you’re not training your users to be EMR experts; you’re training your learners to provide safer, more efficient patient care using a new system.
b.  Think long term: What is a sustainable model that will yield the most for a diverse set of learners?
c.  Evaluate your options carefully, understanding the cost, implications, and necessary support.
d.  Be prepared to stay in the game: Learning doesn’t stop at go-live. Now what?
e.  How are you going to determine the level of support and communication needed for new processes, system “fixes,” upgrade training, etc.?

IV. Assembling Your Knowledge Improvement Team
a.  Who will train your end users?
b.  What adult learning facilitation skills do they have?
c.  Who will design your knowledge improvement tools (classroom curriculum, eLearning, Knowledge Banks, mLearning, etc.)?
d.  Think long-term: Do you need a full EHR training team, comprised of full-time employees? Is relying solely upon consulting talent wise? A blended approach?

V. Evaluate, Measure, and Realign Your Strategy and Tools
a.  Evaluate training strategy, curriculum, etc., against real-life results.
b.  Address the “pain points” quickly.
c.  Always seek to learn from every encounter and adopt an attitude of continuous improvement.

We’ll explore each component of a strategic knowledge improvement plan in detail in subsequent articles.

****

Dr. Greg Forzley (forzleyg@trinity-health.org) is the Director of Informatics for St. Mary’s Health Care in Grand Rapids, Michigan, and serves as Chairman of the Michigan Medical Society. Dr. Forzley has been instrumental in improving physician adoption of EMR systems and is a champion of improving patient care through meaningful use concepts.

Mr. Tony Onorad (TonyOnorad@OnoradSolutions.com) is the founder of OnoradSolutions, a knowledge improvement consulting firm and has been an innovator in the adult learning field for over fifteen years.

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EMR Update 7 – HIPAA, HITECH, and Protecting Your Patients’ Information
This Issue:

  • What is data-at-rest vs data-in-motion?
  • What do the new HITECH Act provisions mean to your medical practice?
  • What are potential penalties for violating the HIPAA regulations?
  • What proactive measures can you take to protect yourself and your practice?

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