1. Recognize that paper charting systems dictate work flows and even how we think. Paper forms train you to enter data in a certain way. Whether conscious or not, your paper charts will influence how you view prospective Electronic Health Records (EHR) systems. Try to find an EHR that looks similar to your paper charts, but recognize computer-based forms will require you to change.

2. Recognize that paper-based work flows are not as efficient as computer-based systems. Your staff spends a certain amount of time everyday pulling, filing, and even searching for misplaced charts. Add time spent printing, faxing, scanning, collating, and stapling, and realize much of this unnecessary work will vanish with EHR.

3. EHR can eliminate many inefficient work flows and help increase productivity. However, recognize that you will encounter bumps along the road to implementation. Stay the course, and the benefits will be well worth the temporary frustrations.

4. Your practice will have to make a conscious decision to use the EHR. Some may resist for a variety of reasons: lack of computer skills, fear of change, lack of training, etc. Even the best EHR system is worthless if you don’t achieve buy-in and participation from your staff and providers.

5. Achieving buy-in is a complex, yet crucial step to successful implementation. Educate your practice about the benefits of EHR. Get them to look at the inefficiencies of the current paper-based system. Show them ways EHR will make their life easier using specific examples.

6. Make an honest list of your current “pain points,” or inefficiencies, gripes, snags, or other frustrations caused by your paper-based system. Be sure to address these concerns with your EHR vendor. Ask them how their software will address each of your issues.

7. Understand that you may encounter resistance and a desire to return to the old paper-based system during implementation. Determine the specific causes of resistant attitudes and address those concerns openly and honestly. Address any issues during implementation with your EHR vendor. Once your staff knows you value their opinion, they will be more willing to proceed.

8. Be patient and persistent. Recognize that implementing EHR is a non-trivial process. How long it takes depends on the size and complexity of your practice. Make your purchase decision during the first quarter of 2012, so you will have plenty of time to implement your EHR and achieve stimulus funds this year.

9. Constantly look for ways to improve the system. No EHR is perfect. You will encounter some parts of the EHR that need immediate attention before implementation can proceed. The needs of your practice will also change over time. Ask your EHR vendor how they can change their software to meet your immediate and long term needs.

10. Share your success stories with your EHR vendor and your colleagues. Were your providers able to decrease the length of their workday, increase revenues through appropriate coding, or achieve stimulus? Everyone will be excited to hear how you have benefited from your EHR implementation.

If your practice is interested in participating in the HITECH Stimulus program, please join us for a web presentation on how one of our rheumatology practices received Medicare stimulus funds. Sign up on the web at http://www.xlemr.com/webinar.html.

Ryan Ricks
Security Officer
www.xlemr.com</a>

The Centers for Medicare and Medicaid Services (CMS) has paid approximately $1.8 billion in stimulus funds to date. CMS delayed stage two until 2014, giving providers an extra year to take advantage of stage one payments.

One of XLEMR’s clients, Carolina Specialty Care (CSC) in Statesville, North Carolina, has just received payment for year one under the Medicare program.

Please join us for a one-time webinar interview session with Savonna Staton, practice manager at CSC. She will discuss the process for signing up for the stimulus program, implementing a certified EHR system, working with her physicians and staff to meet the meaningful use guidelines, attestation, and receiving payments from CMS.

Our webinar takes place on Tuesday, February 7th, 2012 at 5:00 PM EST. This presentation is free of charge, and open to all clinical and administrative staff. Space is limited so be sure to sign up early on our website at http://www.xlemr.com/webinar.html.

The HITECH Act, which brings us the meaningful use reimbursement program, also has a less well-known purpose: to amend HIPAA law. Experts feared a rapid increase in security breaches as more medical providers switch to electronic health records (EHR). Congress wanted to head off this problem by amending HIPAA law to give it more teeth. Previously, HIPAA has not been well enforced.

Times have changed, and practices should be aware of three main changes to HIPAA enforcement. First, fines have increased from $25,000 to a maximum of $1.5 million for “willful neglect.” Per-incident fines, which were previously $100 are now $50,000 minimum per incident. In addition, HIPAA now requires public confession of data breaches to local media and the CMS website. Finally, HIPAA now authorizes random compliance audits, much like CMS conducts for Medicare and Medicaid payments.

The Office of Civil Rights (OCR), which is charged with enforcing HIPAA, has begun the first round of compliance audits, according to Howard Anderson at Healthcareinfosecurity.com. Round one will focus on 20 organizations, with an additional 120 receiving audits later in 2012. The focus of round one is covered entities themselves, not their business associates. Contrary to popular belief, OCR is not only interested in large groups. Small practices and community pharmacies earning less than $50 million make up 30% of the initial audit group.

Leon Rodriguez, head of the Office of Civil Rights, states “Our first objective is not to go out there and start banging [organizations] with penalties; it’s really to take a good look at them, find out where their opportunities for improvement are and help them improve…” However, that does not mean practices should approach an audit with a cavalier attitude. Rodriguez continues, “I know there are cases where we’re going to find some significant vulnerabilities and weaknesses. And in those cases, we may be pursuing significant corrective action…” including “civil monetary penalties.”

What does this mean for the average small practice? First and foremost, it’s time to pay attention to security. With a potential $1.5 million fine and public notification of breaches at stake, the small practice can no longer afford to ignore the HIPAA security rule. HIPAA compliance is a complex subject, and busy practice managers may not be sure where to start.

The best way to protect your practice is to start with a NIST 800-30 compliant risk assessment. A risk assessment is the first step required by the HIPAA security rule, and not co-incidentally, it is also required for meaningful use. A NIST 800-30 risk assessment will give you a comprehensive, clear picture of your practice and help you move forward with remediation. Please feel free to contact us at info@xlemr.com or through our website at www.xlemr.com</a> if you would like more information on risk assessments or HIPAA audits.

The Department of Health and Human Services (HHS) recently delayed the onset of meaningful use stage two until 2014. The final rules for stage two were supposed to be delivered in June of 2012, with stage two beginning in 2013. Many in the healthcare community felt this was an unrealistic timeline, as electronic health record (EHR) vendors and practices alike would have to scramble to implement the new changes.

HHS agreed to move stage two back to 2014 to allow EHR vendors plenty of time to develop and test their software. Practices will also have more time to deploy updates and come up to speed before attesting. All providers will begin stage two in 2014, regardless of whether they started in 2011 or 2012.

Another huge benefit of the delay is that providers may now receive multiple stage one payments. Providers who adopted in 2011 can receive up to three stage one payments, the original payment for 2011, plus additional stage one payments for 2012 and 2012. Providers who switch to EHR in 2012 are eligible for two payments, 2012 and 2013.

This is a huge incentive for providers to adopt EHR earlier rather than later. The original schedule paid out most of meaningful use reimbursements during stages one and two, with the payments decreasing each year. This new plan makes it even more attractive for providers to adopt early.

If you have not yet adopted EHR, 2012 is the year to begin. The Medicare program requires providers to implement a certified EHR system, and meet the meaningful use criteria for a period of 90 days. Do not under-estimate the work it will take to successfully attest. It takes time to choose the right EHR, implement, and train on the system. Once that is complete, it will take more time for everyone to hit all the meaningful use measures consistently.

Participation in the Medicaid program is easier, although few qualify for the program. Providers must see 30% Medicaid patients by volume; most states will count primary, secondary, or tertiary insurance. If providers meet the threshold, all they have to do is “adopt, implement, or upgrade” to certified EHR software. Successful attestation brings $20,000 per provider under stage one.

We would be happy to answer any questions you have about meaningful use or certified EHR technology. You can email us at info@xlemr.com or contact us through our website at http://www.xlemr.com. Be sure to also contact the Regional Extension Center (REC) in your state. They are in charge of administering the program, and will have the final word on your qualification.