One of the goals of meaningful use and all the related federal spending of health IT is for EMRs to improve care coordination. But the current reimbursement system that’s heavy on fee-for-service encourages software developers and users alike to focus on documentation of billable events rather than coordination of care, a new study finds.
Read more on EMRs and care coordination
The Centers for Medicare and Medicaid Services (CMS) announced today a proposed outline for Meaningful Use criteria, in accordance with EMR implementation provisions under the Health Information Technology for Clinical and Economic Health (HITECH) Act, part of the American Recovery and Reinvestment Act (ARRA) of 2009. These specify some of the guidelines by which physicians can receive incentives of up to $44,000 per provider, over 5 years, beginning as early as 2011.
Stage 1 criteria (the first of 3 total) would cover 25 meaningful use objectives (and 23 for hospitals). These are listed under modules known as Health Outcomes Policy Priorities such as Improving quality and patient safety (use of drug-allergy interaction checks, use of ePrescribing, maintaining active medication list, etc.), Engaging patients and their families in their health care (e.g., provide patients with a copy of their health information), Improving care coordination (e.g., exchanging key clinical information among authorized entities), Improving population and public health (e.g., capability to submit data to immunization registries), and Ensuring adequate privacy and security for personal health information (through the use of appropriate EMR technology).
The implementation of Stage 1 meaningful use standards would begin in 2011. Stage 2 (which would essentially expand upon certain aspects of Stage 1) and Stage 3 (which would deal with achieving improvements in conditions of a national high-priority nature and population health outcomes) would follow later.
While this certainly doesn’t clear things up completely for the individual physician, every piece of information that trickles down from Washington is eventually analyzed and translated for all parties which have a vested interest in the process. Hopefully, resources such as this can help doctors stay informed and as up-to-date as possible.
If you have any comments or questions, please post them here. If we don’t know the answer we’ll certainly try to find someone who does.
EMR Implementation – How do you stack up against your colleagues?
We’ll post the results in a week or so.
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One of my partners asked if our practice could use free GMail instead of replacing our old and failing mail server (not free) and having to purchase the licensing for the Microsoft software (definitely not free). 
When I looked into it, it turned out to be a bit more complicated than just deciding between a free mail service or one that has recurring expenses.
You see, with the advent of recent privacy regulations, there are increasing responsibilities being placed on the shoulders of medical practitioners to insure the protection of patient medical information. Before we get down to the details, let’s discuss some terminology:
Privacy vs. confidentiality. According to Gary Kurtz, in an article in the Journal of Healthcare Information Management, privacy is the right of an individual to control disclosure of his or her medical information. Confidentiality is the understanding that the information will only be disclosed to authorized personnel. This is what is known as a “need to know” basis.
Information Security. Since patient information will be increasingly common in a digital-only format, loss of electronic medical records could have an adverse impact on patient care. So it is up to the guardian of that information, typically the physician, to ensure that there are proper procedures for protecting both the safety and the integrity of that data.
The data safety relates to such issues as access to the information with minimal downtime, proper backup of the data with redundancy, and a disaster recovery plan which is regularly tested.
Integrity refers to processes which insure a true, uncorrupted and legal record. Most EMR systems maintain what is known as an audit trail, which tracks every change made to a record, when and by whom. Without an audit trail, it would be nearly impossible to tell if a patient’s record had been altered. Imagine a physical chart written on a dry-erase whiteboard – changes could be made at any time without discovery.
That said, the two main issues of information security relate to Who is controlling the information and Who has access to the information.
Who controls the information. Previously we discussed the two main types of EMR systems available: server-based and web-based. In server-based systems, the patient data is typically located on a computer or server in the doctor’s office. The upside: the doctor has ultimate control over the information. The downside: the practice is responsible for maintaining the security of the patient records, something which most medical practices have little experience with.
In a web-based system, the doctor accesses the EMR system via the internet, and the data is located off-site, usually on the server of the EMR vendor or a third party. The upside: these entities usually have a lot of experience with information technology security processes as well as the resources to implement them. The downside: the information may be stored on the same server as information from other medical practices; there is the potential for the information to be accessed by someone other than an authorized party. In addition, loss of the internet connection means loss of access to your patient files.
Who has access to the information. As stated above, access to patient information should be on a “need to know“ basis. There may also need to be additional provisions for restricted types of visits such as patients with HIV, mental health issues, or those undergoing drug treatment.
HIPAA (the Health Information Portability and Accountability Act) determines how patient health information may be shared electronically. So a medical practice would need, according to HIPAA language, to insure the confidentiality of the patient information not only within its domain, but would also need to take any steps necessary to make sure that third parties who have access to the same information (outside vendors, laboratories, consultants, etc.) maintain confidentiality as well. This could even be carried, in the extreme perhaps, to anyone who potentially has access to patient records, such as cleaning service companies or maintenance contractors. A practice would be well-advised to sign Business/Vendor Associate Agreements for HIPAA compliance with these companies. You can find many examples of these online that you can use.
Other potential gaps in information access include:
So, going back to our story about GMail…for a medical practice to use GMail for its email service, it would need to enter into a Vendor Associate agreement with Google Inc. and require Google to adhere to the practice’s procedures and policies for privacy of patient information (and every medical practice that used GMail would have to do the same). Needless to say, Google is highly unlikely to agree to signing these types of agreements with possibly thousands of doctors, and be potentially exposed to significant liability.
It doesn’t matter if your practice is just a single doctor at one location, or numerous physicians across multiple satellite offices. Either way, even before you can implement an EMR system, you’ll need to start by developing your system infrastructure.
Although typically a contractor will take care of the network wiring for your office network, it is still a good idea to be familiar with some issues related to network wiring as well as terminology so you don’t get taken advantage of. Consider using a contractor who has been certified by the Building Industry Consulting Service International (BICSI), as this certification is the standard for contractors who deal with complex data and voice cable installations.
Some of the specific issues with which you should be familiar include:
Wiring: Typical Cat5e network wires have either a T568A or T568B standard. Select either, and be sure everything is wired to the same standard. The Cat6 wire standard is newer and more expensive, possibly a bit much for most medical practices. Copper wires between telephone communications closets shouldn’t contain segments over one hundred meters. Consider using fiberoptic cable for wiring over longer distances, as these cables can move more information and aren’t as vulnerable to interference and lightning. Fiberoptic, however, is more expensive.
Wireless: Are you considering wireless networking, also known as WiFi? If so, you will have to select a standard: either 802.11a, 802.11b, 802.11g, or 802.11h. Some newer standards provide higher data transfer speeds, but cost significantly more. The wireless standard that you choose should depend on whether you’re running a thin or fat client ( see Designing the Office Network for more about thin vs fat clients. Also, beware of interference from such common devices as cordless phones and microwave ovens.
Overwire: Most existing buildings are wired above the ceiling. Wiring is then dropped down the walls. When wiring, I would recommend ‘double drops,’ as the largest cost of wire installation is the labor. You will thank yourself later when you want to add more network devices (scanners, printers, diagnostic equipment, etc.), as these additional network connections will already be there.
Cooling: Network and server equipment create heat, and tend to shut down when over-heated. Plan for this by being sure that you have adequate cooling – you may want to consider installing a small, dedicated air-conditioning unit.
Electrical connections: It’s a standard IT practice to have a certified electrician install isolated circuits for your network and servers – usually the outlets are orange so you can tell them apart.
Security: Don’t forget about security! Make the wiring closet secure, and remember that anyone with access to this closet can dismantle your network at any time.
Multiple locations: You’ll have to create a WAN, or wide-area network, to make a connection between remote office locations, so do your research and check out all your options. Larger metropolitan areas will generally have more options available for wide-area networks.
Fiber Backbones: Local utilities commonly maintain a fiber backbone which they allow businesses to access. These fiber backbones allow for high bandwidth rates between office locations (10-100Mbps) at a reasonable cost.
Local Phone Service: Meet with your local telephone sales people and service technicians. They understand the offerings in your geographic area. Some of the key points to discuss are:
The costs of network infrastructure are much lower in new buildings. Apart from easier (and less costly) installation, the ability to oversee the network wiring in a building under construction is an advantage for clear design. Unfortunately, the majority of practices are located within existing buildings, so sound design and forethought in planning will help save your practice excessive costs and headaches later.
Regardless of whether or not you use an EMR system, 
you may already have computerized billing and scheduling. And if you have multiple computers at your practice, most likely these computers operate on some sort of network. Even if you are not the ‘technical’ person in your practice, you should understand the designs and capabilities of computer networks, especially when a complex, multi-user EMR system is finally put into place.
Below are some basic principles of computer network design you should be familiar with:
Networking Basics (WAN, LAN, or MAN?)
Certain network hardware and system software may be incompatible with some EMR and EPM systems. Obviously, you should know this in advance. If you plan on adding users to your network at a later time, it’s often better to buy multi-user licenses rather than individual retail software packages. You can connect computers and printers in a practice on a Local-Area Network, or LAN. The LAN can link up with other local area networks via wireless connectivity. But be sure to check with the vendor of the EMR software to insure that it can operate on a wireless network.
A Wide-Area Network (WAN) can connect other smaller LANs, or Metro-Area Networks (MANs). Large practices can use these WANs to connect multiple satellite offices over a wide geographic area, for example.
The most recognized WAN is the Internet. The Internet can also create the possibility of an Intranet, or a private Internet, on which employees can communicate and collaborate with each other, regardless of where they are located. For such a system to function well between dispersed offices, a hi-bandwidth connection is a must in order to maintain smooth operations. We use an Intranet for such things as employee manuals, a practice Wiki, staff newsletters, photo sharing, and educational materials.
Bandwidth and Topology
Data capacity, or network Bandwidth, is often measured in bits-per-second (bps). In most cases connection rates range from 56kbps to millions of bits per second. Even so, the rates achievable may be limited by the hardware or sometimes even the software used. Overall speed on the network can be drastically reduced when many users are trying to use the system at the same time. If network speeds are slow because the hardware is underpowered or the network design is bad, ‘fast’ connection speed rates promised by the internet service provider won’t really mean much.
Network Topology is also important. Topology is the ’shape’ of the network, as in the wiring between a series of computers. This topology should have a clean, intelligent design and not simply daisy-chaining PCs in a random, haphazard way. Optimal topography may mean more wires, but this can contribute to overall system resilience from failure due to a weak spot. Otherwise, if one part of the network fails, the entire network could collapse as a result. Proper topography protects against this sort of situation with redundancies. A network consultant should recommend a good balance between expandability and redundancy.
Wiring
In most cases, a practice running an EMR system will employ hard-wired computers connected to a server. However, some physicians may prefer to input data via a wireless device, as this can be carried throughout the areas in a practice. However, wireless networks present some new points to address:
Signal
Wireless devices have less-than-expected ranges when functioning in an office with many walls. Many consumer-level devices may be inadequate for the needs of a medical practice network. And they may suffer from interference due to common appliances such as microwave ovens or cordless telephones.
Bandwidth
The useful speed on your local network can be limited by the speed of your wireless connection, even if your LAN has good bandwidth rates.
Wireless Security
A hacker can destroy your network if it isn’t protected. Even simple wireless access points need to have built-in security. This is especially important in the age of HIPAA compliance.
Firewall
And speaking of security, you can protect yourself further by having what is know as a firewall. These are software programs, either stand-alone or as part of a hardware device, which protect private networks against intrusion from the outside world. These have become relatively inexpensive for the small business, especially compared to the cost of a successful network attack.
Fat or Thin Clients?
Should you employ laptops (fat clients) that directly run software and connect to your network via a wireless connection? Or, should you run the software virtually with a network appliance (thin client) via a remote connection? With wireless networks, disconnects are an unavoidable reality. In this case, the thin client lets the software continue to run, and you can later pick up where you left off. A broken connection on a fat client may cause a software crash. On the other hand, the latter has certain other capabilities such as running video programs.
If you talk to anyone who is involved in the electronic medical records (EMR) industry, one of the biggest points of discussion is what is known as “Meaningful Use of EMR.” 
What started as a well-intentioned (by some) effort to establish standards for EMR software systems has morphed into political jockeying by corporations, consumer watchdogs, and others.
The US Dept of Health and Human Services (HHS) outlined these criteria for Meaningful Use of EMR:
1) Improve quality, safety, efficiency, and reduce health disparities
2) Engage patients and families
3) Improve care coordination
4) Improve population and public health
5) Ensure adequate privacy and security protections for personal health information
And although each of these has defined goals followed by specific objectives and measures for the years 2011, 2013, and 2015, these still sound a bit ambiguous. Many industry experts, however, expect these to be more fine-tuned as the dates approach, but medical practices will have to stay informed to keep ahead of the curve.
Financial Incentives
As part of the ARRA (American Recovery and Reinvestment Act of 2009), financial incentives will be given to those physicians whose practices demonstrate “meaningful use” beginning January, 2011.
The incentive payment, according to CMS, is equal to 75% of Medicare-allowable charges for covered services in a given year, and maxes out as follows:
For those practices who are early adopters of the technology and hit the threshold for meaningful use in 2011 or 2012, the first year payment would be $18,000. Note that this only applies to Medicare; there are additional incentives for healthcare providers who have a certain threshold of Medicaid patients and/or who practice in a rural area. The threshold for office-based pediatricians is lower, and so they would be more likely to qualify for those additional funds.
[table courtesy of SoftwareAdvice.com]
Even considering the fact that EMR implementation may cost anywhere from $10,000 to $50,000 per provider, these incentives would certainly make that investment more palatable.
Those practices that procrastinate, however, will be penalized with cuts in Medicare and Medicaid payments:
So, how do you know if you qualify? According to the health IT blog NetDoc, to be a “meaningful EHR user”, a physician must satisfy three criteria:
Some physicians have told me that because there isn’t a final definition of what is considered “certified EHR technology” they are just going to wait. Big mistake. Most health care IT experts working on and advising on this issue feel fairly strongly that the Office of the National Coordinator for Health Information Technology (ONCHIT) will set CCHIT (Certification Commission for Health Information Technology) criteria as the standard for EMR certification.
CCHIT is a non-profit organization funded by various corporations and groups such as the American College of Physicians and the American Academy of Family Physicians, and was recognized by the US Dept of Health and Human Services (HHS) as a certifying body in 2006.
Some critics, however, charge that CCHIT is a shill for the Healthcare Information and Management Systems Society (HIMSS), the healthcare industry’s membership organization focused on healthcare IT. Although made up of both corporate and individual members, these critics feel that their goal is to corner the market for certain major EMR players. Nevertheless, unless or until there is an alternative, most EMR vendors are using CCHIT certification as the benchmark.
In addition to the EMR certification criteria, the ONCHIT is expected to adopt an initial set of standards and implementation specifications by the end of the year 2009.
Timeline
So, is too late to implement EMR in your practice and still qualify for the financial incentives? Well, that depends on the size of your practice, type of specialty, and how motivated your doctors and staff are to go paperless. Just don’t expect to run down to Office Depot, buy an EMR program and launch it the next day (although there is talk about WalMart getting into the EMR business, but we’ll leave that story for another day…)
According to MBA HealthGroup, these are some reasonable time frames to expect for EMR Implementation:
[timeline courtesy of MBA HealthBlog]
Smaller groups and solo doctors may be able to purchase a more basic, “out-of-the-box” EMR system and more quickly adapt their workflow to the system, rather than vice versa in the case of larger medical practices. But, the one thing you can count on with EMR implementation is that you can’t count on anything – that is why some sort of timeline is important [see EMR Implementation Rollout].
What this boils down to is that those practices that have already started implementing EMR will have a good shot at getting those higher financial incentives. On the other hand, physicians who have been wishing that the whole idea of EMR was just a fleeting fad may not only miss out on these incentives but may also face cuts in their reimbursement.
Questions? Comments? Post them below
There are many benefits associated with having a computer office network, regardless of whether you are ready to implement electronic medical records (EMR) or not. For example, what may begin as a helpful suggestion from an employee can blossom into a practice-wide tool which can improve overall productivity.
ProtoQue is a program which was developed in response to a problem we were having with our phone triage: we noticed that many patients were not called back in a timely fashion. This program, which is web-based, lets operators register calls automatically. The patient is then subsequently passed off from there to either medical records or a medical assistant. This program manages the ‘chain of custody’ so that the patient doesn’t slip through the cracks. The issue remains open until the problem is resolved. Every time a patient receives a return phone call, a time stamp is created, so our attempts to contact them are documented. The supervisors can use this application to monitor information flow, delegating calls to additional staff if the team falls behind, regardless of where they are located. We no longer have patients waiting until the next day to have their concerns addressed by our staff. Even though our EMR system, like most, has a messaging feature, we still find this program to be more robust and have continued to use it for over three years.
In addition to the phone triage program, we have designed some in-house programs that help us manage specific tasks, and which would not be possible without our computer network:
If you have any comments, please post them here. You can also post any questions you might have about some of our software tools.
In order to implement important changes at your practice, you must gain buy-in from the staff. The executive search firm Korn/Ferry International cites a lack of employee buy-in as one of the most common management mistakes a new executive makes when trying to implement any new strategies or changes. If this executive fails to take the existing culture into consideration, the initiatives often fail.
For example, consider the controlling manager who arrives at a business only to discover that the employees work collaboratively. This combination can lead to significant struggles. Alternately, let’s consider the savvy executive who approaches the situation with an ability to acclimate, and who discovers ways to work in harmony with the existing culture and style at the firm. The latter approach can significantly assist your efforts to gain cooperation from staff when implementing the transition from paper records to electronic medical records (EMR).
Proper planning and the ability to adjust during the process are two tools that can help you avoid the need to pull the plug on your EMR project, with a potentially disastrous economic effect on your practice. The ‘Change Management’ process, which touts navigating change in a careful and systematic way, is a great tool to employ during this time.
Ultimately, every employee needs to buy-in to the change, and for this to occur successfully, a helpful framework is known as the ADKAR model (Prosci):
Have you already implemented EMR in your practice? Did you have issues related to the Change Management? Post a comment below and let us know.
Do you plan on implementing electronic medical records (EMR) at your medical practice? If so, you’re taking on a sizable project. Something this large must stay on a time-line or it may never reach completion. At our practice we experienced some setbacks including back-to-back hurricanes, construction of two new buildings, and hiring of a couple of partners -
all of these events pushed the date of launch back over a year. Even so, having a firm date to ‘go live’ helps get everyone on board, allowing them to team together to engage in what could be one of the more challenging changes in their career.
Choose someone to be the project manager in charge of implementing the project. It could either be someone from staff such as an IT person or supervisor, or you could hire an outside consultant. Next, you want a comprehensive plan which covers the how, who, what, where, when, and why of the project from start to finish. Before going forward on your EMR plans, be sure your assets are ready. It just takes one poorly-prepared component to send well-laid plans down the path to failure.
Regardless of the practice, physicians’ attitudes towards EMR will range from gung-ho optimistic to downright resistant. Whoever is in charge of leading the project must decide when all of the physicians will roll-out on EMR, whether in unison or staggered on various launch dates or locations.
Some doctors may be quite comfortable allowing colleagues to test the waters first; but this may lead to more work and stress for the staff. If one doctor sees a patient using EMR, and the patient returns on a follow-up visit with another doctor using a paper chart, how will the patient’s chart be reconciled?
If there are multiple locations at your practice, you may want to implement EMR at one office before going on to the others. However, if your employees rotate between locations, your training plan must take this into account; if too much time passes between the launches at different locations, training may suffer.
Again, a project this large requires a firm commitment from the top authority at your practice, typically a physician ‘champion’, along with buy-in at all levels. One single voice of negativity from someone in a power position can drag down the entire campaign. A managing partner may have to intervene if the practice discovers that a doctor is actively working against the project – your administrator should not be put in this no-win situation. It’s also important that patients are well-informed of the practice’s goals, so that they are more likely to tolerate the expected delays and hiccups while your team is working out the kinks in the system.
If you’d rather not make the big switch to digital all in one day, you may prefer to see only some patients using EMR. At our practice, we began with new patients requiring complete exams only, to prevent our clinics from grinding to a halt. As these patients gradually return for follow-ups, they continue to be seen using the EMR system. In this way, we were able to launch all locations simultaneously so clinics would not suffer from disparities in employee training and skills. This has also allowed us to gradually ramp up EMR with little effect on productivity.
Other items which shouldn’t be left to the last minute:
Your schedule should include at least a month of intensive training for staff, which concludes well before the launch date. You may have to rotate staff during the day, or train people after hours at the usual overtime rate. Supervisors must have the ultimate word to ensure that the employees are trained to work with the EMR system in a live clinical setting. Naturally, they will need to practice to keep their skills sharp.
Implementing a full-scale EMR system can involve tens, even hundreds of thousands of dollars, potential headaches and lost productivity resulting from a wrong decision.
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