Archives for: October 2011
One Size Does Not Fit All
The American Health Care System is a diverse landscape, with many different specialties. In addition to assorted specialties, there are also many different types of practices. The US healthcare system includes solo-practitioners, small groups, large groups, and hospital systems.
With all of the diversity in our healthcare system, should it come as a shock that most Electronic Health Records (EHR) software sold is relatively uniform across specialty and practice size? There are over 900 certified EHR vendors. To be fair, some do focus more on certain specialties or certain practice sizes. However, EHR companies know that they can best take advantage of economies of scale and scope by selling many units of similar products.
Let’s compare the EHR and Automotive industries. Despite the large number of certified EHR vendors, there are a few large companies that dominate the EHR market. They will offer some amount of customization in their software, just like how major auto companies will have different choices for color, interior, audio systems, and other options packages.
Just like most cars today, these EHRs are good products that most physicians could use with some degree of success. However, they may not be the overall best fit. Perhaps there is not enough headroom. The turning radius might not be tight enough to park in urban areas. There may be too much cargo capacity, or not enough.
There are probably thousands of variables providers should consider when test driving an EHR. While they may be able to “drive across town” in a mass-produced EHR, it may not be the best fit for their practice. Enter the custom-engineered EHR. XLEMR is like a hot rod shop. We focus on smaller volume, custom EHR software designed to meet our clients’ needs and go fast.
We forge an intimate, long-term relationship with our clients to produce a custom EHR solution that meets their needs from day one. We consult heavily with our client on the design; many times we incorporate forms from their own paper charts. We hold their hand through the implementation and training phase. We work with them like partners to achieve meaningful use funds.
One size does not fit all. If your practice is a specialty neglected by the big EHR vendors, please contact us. We would love to hear from you. If you work for a more common specialty, and have not been able to find the right EHR, we would love to hear from you also.
GE recently notified users of two Centricity products about meaningful use reporting issues that could prevent successful attestation. The HITECH Act offers financial reimbursements to medical practices and hospitals that adopt certified Electronic Health Records (EHR). Practices must meet meaningful use guidelines in order to qualify for the money.
The issue GE discovered affects Centricity’s ability to log and report compliance with certain meaningful use measures. According to articles on the topic, issues exist with race, ethnicity, smoking status, and educational resources. Reporting problems may prevent successful attestation.
GE recommends their clients double-check their numbers to make sure they are accurate, and to refrain from attesting until after GE deploys updates. GE instructs users who have already attested to run reports once the updates are in place. GE users should also check in with their Regional Extension Center (REC) representatives for further recommendations.
GE is a respected company with quality software; even they are susceptible to errors. I have been working with the developers here at XLEMR on our meaningful use reporting module. I can testify that the calculations involved are numerous and complex. Any practices attesting meaningful use should check and double-check their reports regardless of their EHR vendor.
EHR users should be in constant communication with their REC. Interpretation of some requirements, such as clinical summaries, seems to change over time and vary between states. With the amount of money at stake, up to $18,000 for stage one, practices should go over each measure with their REC and make sure their attestation plans will work.
Please feel free to contact us if you have any questions about meaningful use, reporting, or how you can participate in the HITECH stimulus package.
The Office of Inspector General at the Department of Health and Human Services is gearing up to examine practices that receive meaningful use payments. Their 2012 plan targets fraud and abuse within the HITECH incentive program. Specifically, the OIG wants to ensure any practice receiving payments actually met all the meaningful use criteria.
The HITECH Stimulus package reimburses physicians for purchasing and implementing certified electronic health record (EHR) technology. Physicians under the Medicare program can receive up to $44,000 with $18,000 in the first year. The Medicaid program offers a total of $64,000 per provider, with $20,000 in the first year. The OIG feels that practices may be tempted to cheat with this much money at stake.
Providers should make sure their EHR tracks their meaningful use measure compliance. It is a good idea to run compliance reports daily, so you can identify any shortfalls and correct for them immediately. Store your meaningful use reports in a safe place in case you hear from one of the OIG auditors.
In addition, OIG will continue to review evaluation and management (E&M) service payments to providers. Providers select appropriate E&M codes based on the complexity of their patient’s condition and the extent of their treatment. Documentation, whether paper or electronic, must be able to support the E&M code selected.
Cloned records, or documentation that is the same across multiple encounters, are one of the main problems the OIG faces. EHR software may make it easy to produce clone records if data entered persists from visit to visit. Providers must be careful to change items that no longer apply to the current visit.
EHRs are great tools, but providers should make sure they are complying with meaningful use and E&M requirements. Documentation is the key to compliance. If you have questions about EHR documentation, meaningful use, or E&M requirements, please feel free to contact us.
You may have heard the term “telemedicine” lately in the blogs and news articles. In case you are wondering, “telemedicine is the ability to provide interactive healthcare using modern technology and communications.” Today we will discuss some modes of operation and benefits of telemedicine.
Telemedicine typically has two modes of operation, those being real-time or store and forward. Real-time treatment is the most common. All parties are present and communicate at the same time. Real-time treatment may be used for in or outpatient specialty consultations or supervision of physician assistants or nurse practitioners.
Store and forward is the other way to use telemedicine. Physicians use this mode when all parties are either not available or not required to be present at the same time. Still images, video, voice and text are recorded and then transmitted to the remote provider for analysis at a later time.
Telemedicine has many benefits, but chief among them are the ability to decrease the cost of care and increase the convenience of treatment. Rural practices benefit from telemedicine by connecting with specialists or other providers without having to fax or mail paper charts or refer patients to distant offices. Likewise, benefit because their access to care is more immediate, without having to travel a long way.
However, many providers have rejected telemedicine because they were unsure how to bill for services rendered in this manner. According to CMS, you can bill for telemedicine services the same way you would bill for a normal in-office procedure or consultation. The difference is that you will need to add a “GT” modifier to indicate the service was performed remotely. The originating facility may also bill for a facility fee. Please download these PDF files for more billing information from CMS: http://www.cms.hhs.gov/Transmittals/downloads/R43BP.pdf, http://www.cms.hhs.gov/Transmittals/downloads/R790CP.pdf
We are excited about telemedicine. We feel that it can benefit many specialties, but may be particularly useful to those in the long term care and home health industries. If you are interested in learning more about telemedicine and how it may be able to help your practice, please let us know. We would love to hear from you.
Today’s post is inspired by John Lynn’s blog EMR and EHR. Yesterday, his staff posted a blog about data breaches and cited some interesting examples of related stories in the news. Due to the increased HIPAA fines and risk exposure, it is a topic that is worth repeating.
The blog made two points we wish to re-iterate. First, most breaches are due to theft or human error, not mysterious hackers. Second, breaches of paper records are much worse than electronic breaches.
Theft or human error causes the majority of data breaches. If you take a look ONC’s wall of shame website, you will see that is the case. Basically, this means that thousands of dollars of security software can easily be made useless without adequate education, training and policies.
Training is important because it educates employees on their roles, responsibilities, and procedures. Better training could have prevented at least one recent breach where a hospital contractor posted protected data to a website designed to help college students with their homework.
Encryption is an important tool to protect mobile devices. Laptops, tablets, and smart phones are at high risk for loss or theft. Using standards-based encryption to protect your mobile devices will prevent your data from falling into the wrong hands.
Paper records are much more vulnerable than electronic records. This seems counter-intuitive for a couple of reasons. First, electronic data breaches get all the press. Second, electronic data is much easier to copy. However, electronic data is also much easier to protect with access controls, encryption and other means. Paper records, on the other hand, are not easily protected. They also do not require any special hardware or software to read. Most of the time, paper records are not even stored in a locking cabinet.
Data breaches are a serious issue. Practices should be sure to exercise due diligence to prevent data breaches and avoid fines for HIPAA non-compliance. Technology, policy, and education work hand in hand to keep your practice secure.
Do the consistency of History Notes lead to audit issues?
I was asked today by a practice manager if the Drop-Downs that control the language on the History Note make notes look "too similar" and if this is an Audit Risk? Do you have any experience with this kind of issue?
The Centers for Medicare and Medicaid (CMS) required physicians to submit at least 25 electronic prescriptions between January 1 and June 30th. Approximately 100,000 physicians complied with the requirement. However, there were about 100,000 other physicians who failed to submit enough prescriptions.
Physicians who did not submit enough electronic prescriptions during the reporting period will be subject to a 1% pay decrease in 2012. CMS extended the deadline until November 1st to apply for a hardship waiver. The extension does not give physicians additional time to e-prescribe, only additional time to apply for a waiver.
The waiver gives physicians a pass if they work in an area without access to high-speed internet, or if local pharmacies do not accept electronic prescriptions. CMS has created new exemptions for physicians registered to participate in the HITECH stimulus program, physicians unable to e-prescribe due to local, federal, or state law, write a limited number of prescriptions, or have insufficient numbers of eligible patient visits during the reporting period.
Physicians wishing to apply for an exemption must register online with CMS. Keep in mind, CMS will not notify practices in advance if they are subject to penalties. The practice manger must keep track. The application process is different for individual physicians and group practices. Click this link to the AMA website for details: http://www.ama-assn.org/amednews/2011/09/12/gvl10912.htm#s3
Oops! You Missed it!
Monday, October 3rd was the last day for 2011 that physicians and eligible professionals can begin their meaningful use attestation for the Medicare track of the HITECH Stimulus Program. The Medicare track pays eligible providers up to $44,000 each, and requires a 90-day attestation period where providers must meet all of the meaningful use criteria.
If you missed the deadline, don’t panic. You can still participate in the Medicare stimulus track. However, your attestation period will roll over into 2012, and you will receive your payments once your attestation period is over. Payment for the first year of Medicare is $18,000.
However, if your practice sees any Medicaid patients, you may be able to qualify for the Medicaid track. Your practice must see 30% Medicaid patients by volume. So far, most states allow Medicaid as primary, secondary, and tertiary insurance. You should have your billing staff run reports and see if you are close to 30%.
Medicaid does not require a 90-day attestation period. Instead, you just have to purchase or otherwise acquire a certified EHR system. Once your Regional Extension Center (REC) representative approves, you will receive payment in a few weeks. Payment for the first year of Medicaid is $20,000.
If you would like more information on Medicare or Medicaid stimulus, or EHR systems, please contact us at firstname.lastname@example.org.