CHIME is the professional organization for chief information officers and other senior healthcare IT leaders.

CHIME has produced a CIO-oriented publication providing details on how organizations should focus their efforts to implement EHR systems that will qualify for stimulus funding payments through the HITECH Act. The 80-page guidebook is available free to the public and can be downloaded here.

Also, the American Hospital Association (AHA) and CHIME have worked collaboratively to create a guidebook for CEOs on the HITECH Act and meaningful use implementation. The handbook entitled, “Health Care Leader Action Guide on Implementation of Electronic Health Records”, provides a readable, actionable, step-by-step guide designed to assist CEOs and other C-suite executives in the EHR implementation process. The 22-page guide is available free to the public and can be downloaded here.

Series of 1917 $1 United States Note
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Posted on Tuesday, August 24th, 2010

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  • All available appointments are full.
  • All staff showed up for their shifts.
  • No one burns toast in the toaster oven and sets off the fire alarm.
  • None of the staff show up to work wearing flip-flops or pink underwear beneath their white scrubs.
  • All patients have been reminded about their appointments so they all show up.
  • Patients calling for same-day appointments are able to be worked-in appropriately.
  • No patients give false information at check-in.
  • Established patients arrive on time with their insurance information and co-pay.
  • New patients arrive on time to complete their paperwork, and give their insurance card, photo ID and co-pay to the receptionist.
  • Patients with x-rays or other imaging studies bring the films or a CD.
  • Patients with fasting appointments arrive having fasted.
  • All patients arrive bringing their bag of medications.
  • Patients in wheelchairs and with difficulty ambulating are accompanied by caregivers.
  • Patients who do not speak English or are deaf have notified the office prior to the appointment and the appropriate technology or interpreters are available for the appointment.
  • Patients with procedure appointments have followed their pre-procedure instructions.
  • Patients with procedures have been pre-authorized by their insurance carrier and their personal financial responsibility has been discussed with them and payment arrangements have been made.
  • Patient eligibility has been checked and those unable to be authorized have been called before their appointment to gain further information about their payer source.
  • If computers go down, there are paper procedures in place to enable staff to continue seeing patients.
  • No patients arrive saying “I forgot to tell you, this is Worker’s Comp/ an auto accident/ a liability case and I was told by my lawyer not to pay anything.”
  • None of the patients pee on a waiting room chair.
  • Neither JCAHO nor any state or federal officers show up.
  • The copiers and faxes all work.
  • No subpoenas come in the mail.
    Letter Carrier Delivering Mail
    Image by Smithsonian Institution via Flickr
  • It’s not your very first day live on electronic medical records.
  • All phone calls are answered before the third ring and no one has to leave a message.
  • No patients walk in the door with severe chest pains and say “I knew the doctor would want to see me.”
  • Patients remember to call the pharmacy for refills.
  • Providers all run on time and seem in particularly good moods.
  • Patients get their questions answered with callbacks within two hours.
  • Someone delivers sandwiches, drinks and brownies to the practice for lunch.  There is enough for everyone.
  • No bounced checks come in the mail.
  • Providers spend so much time in the exam room listening to their patients that the patients leave feeling that every question they had (and a few they didn’t know they had) was answered.
  • Providers circle the services and write the diagnosis codes numerically on the encounter form, remembering that Medicare doesn’t pay for consults any more.
  • Sample medications that providers want to give patients are in the sample closet.
  • Records that providers want to reference are in the chart and are highlighted.
  • No one calls urgently for old medical records that are in the storage unit across town.
  • There are no duplicate medical records.
  • Patients checking out never say “But he was only in the room for 5 minutes!”
  • The patient restrooms don’t run out of toilet paper.
  • No bankruptcy notices come in the mail.
  • All phlebotomists get blood on the first stick.
  • No kids cry.
  • The HVAC system works beautifully, keeping it cool where it needs to be cool, and warm where it needs to be warm.
  • Congress announces that the SGR formula has been revoked and a new reasonable model for paying physicians has been discovered.
  • Everyone goes home at 5:00 p.m., glad to have a job, glad to be of service, and happy with their paychecks.

I was fortunate enough to be listening by phone to the historic (yes, historic) announcement of the final meaningful use rules by Kathleen Sebelius, Secretary HHS; Don Berwick, MD, new CMS Administrator; David Blumenthal, MD, national coordinator for health information technology at HHS; Regina Benjamin, MD, Surgeon General and a surprise speaker, Regina Holliday, artist and activist for patient rights.

Kathleen Sebelius
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The memorable quotes I wrote down were:

Kathleen Sebelius: “When electronic health records are well-designed and implemented correctly, they can be a powerful force for reducing errors, lowering costs, raising quality of care, and increasing doctor and patient satisfaction.” That is the best one-sentence description of “Why EHR?” I’ve ever heard.

Don Berwick: “If it’s (EHR) so good, why doesn’t everyone use it? Because it’s HARD.” There is a little slice of honesty that you won’t get from most EHR vendors.

David Blumenthal: “We are only as good in treating patients as the information we have.” Wow, an admission that could rock the medical world if we stopped and thought about it.

Regina Holliday: “I will not stop until we all have the right see our own information.” Regina’s Medical Advocacy Blog is here. Her lauded mural “73 Cents” refers to how much per page she was told by the hospital medical records department she would have to pay to get a copy of her husband’s records while he was still in that hospital.

The Meat: Specifics of Stage 1 Meaningful Use (2011 and 2012)

Meaningful use includes both a core set and a menu set of objectives that are specific for eligible professionals and hospitals.

For Eligible Professionals (definition here), there are a total of 25 available meaningful use objectives. 20 of the objectives must be completed to qualify for an incentive payment. 15 are core objectives that are required, and the remaining 5 objectives may be chosen from the list of 10 menu set objectives.

For Hospitals, there are a total of 24 available meaningful use objectives. 14 are core objectives that are required, and the remaining 5 objectives may be chosen from the list of 10 menu set objectives.

Stage 1 (2011 – 2012) sets the baseline for electronic data capture and information sharing.

Stage 2 (est. 2013) and Stage 3 (est. 2015) will continue to expand on this baseline and be developed through future rule making.

Summary Overview Of Meaningful Use Objectives

(full article from New England Journal of Medicine here)

blumenthal_t1

As I am sure you expect, there will be much more information to come.

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Medicare Definition of Eligible Provider (EP)

For Medicare, physicians and some hospitals are eligible providers. “Physicians” includes doctors of medicine (MD) or osteopathy (DO), dentists or dental surgeons (DDS or DMD), podiatric medicine (DPM), and optometry (OD) and chiropractors (DC).

For providers, their annual payment will be equal to 75 percent of Medicare allowable charges for covered services in a year, not to exceed the incentives in the table below.  Payments will be made as additions to claims payments.

Hospitals include quick-care hospitals (subsection-d) and critical access hospitals  and only includes hospitals in the 50 States or the District of Columbia.

Medicaid Definition of Eligible Provider (EP)

Medicaid takes the Medicare definition of eligible providers (physicians) and adds nurse practitioners, certified nurse midwives and physician assistants, however, physician assistants are only eligible when they are employed at a federally qualified health center (FQHC) or rural health clinic (RHC) that is led by a Physician Assistant.  Eligible hospitals include quick care hospitals and children’s hospitals.

At minimum, 30 percent of an EP’s patient encounters must be attributable to Medicaid over any continuous 90-day period within the most recent calendar year. For pediatricians, however, this threshold is lowered to 20 percent.

The first year of payment the Medicaid provider must demonstrate that he is engaged in efforts to adopt, implement, or upgrade certified EHR technology.  For years of payment after year 1, the Medicaid provider must demonstrate meaningful use of certified EHR technology.

Change 1:

The  definition of “hospital-based physician” was recently clarified to include physicians working in hospital outpatient clinics (employed physicians) as opposed to the inpatient units, surgery suites or emergency departments.  This still excludes pathologists, anesthesiologists, ER physicians, hospitalists and others who see most of their patients in the ER as outpatients or as hospital inpatients.

Possible Change 2:

The Health Information Technology Extension for Behavioral Health Services Act of 2010 (HR 5040)  is a bill in the US Congress originating in the House of Representatives that would amend the Public Health Service Act and the Social Security Act to extend health information technology assistance eligibility to behavioral health, mental health, and substance abuse professionals and facilities, and for other purposes.  You can track the bill here.

For more information on stimulus money for meaningful use of an EMR, read my post here.


When a payer or health plan calls your practice and requests records or requests an on-site visit to review charts, follow this guideline:

  1. Be professional at all times.  Audits can be nerve-wracking and can be a drain on internal resources, but there is always something to be learned from the process.
  2. Ask for the request in writing, to include the names of the patients whose charts will be accessed, the dates of service covered under the audit, the name of the auditor, the specific reason for the audit, what the result from the audit will entail (warnings, sanctions, grading, etc.) and if the result will be published in any form anywhere.  Request that the specific information culled from the audit be shared with your practice in an usable form.
  3. Review your contract with the payer for any language related to the payer’s rights to access information, the description of the information, and any payment due to the practice for the labor and resources used in producing the records.  Check with your state insurance laws for any information regarding such requests.  Note that Medicare Advantage plans do not have contracts with practices, so you do have the right to charge for the labor and resources necessary to produce records.
  4. When the information arrives from the payer, confirm that the patients named in the audit have records in your practice.
  5. If the explanation for the audit is unclear, request more in-depth information in writing.
  6. Review records or charts requested by the payer and be sure to remove any documentation that does not specifically refer to the dates being included in the audit.  Do not give the entire chart to the auditor.
  7. For practices with EMRs, print the appropriate documentation for the auditor if they request an on-site visit.  Do not give the entire chart to the auditor.
  8. If you are satisfied that all requirements are being met by the payer, schedule the audit, or arrange for records to be sent.  If coming on-site, arrange for a quiet place for the auditor to review records, preferably close to you so you can observe, answer questions and ask questions.
  9. Analyze the feedback received to improve any areas needed and document your effort as a part of your compliance plan.  Have all practice employees sign off on any compliance plan updates.
Posted on Wednesday, March 31st, 2010
  1. Everyone is waiting for the other shoe to drop on Medicare payments.
  2. Private practices may not have the in-house expertise to implement an EMR and may not be able to afford a consultant (although some states are receiving grants to help practices – check your state’s grant here.)
  3. There is a lot of confusion on the parts of Meaningful Use that have been clarified and of course, on those that haven’t.
  4. Administrators are distracted by RAC, PECOS, HIPAA , PQRI, eRx and RCM.
  5. Some practices have spent years avoiding Medicare and Medicaid patients and now don’t have the patient numbers to participate.
  6. Everyone and their uncle is selling an EMR – who can tell the long-timers who are about to be bought from the short-timers who might last forever?
  7. Physicians are worried about the drop in production that (some say) happens when a practice launches an EMR.
  8. There seems to be as many horror stories as there are success stories with EMRs.
  9. Practices that are affiliated with a hospital are nervous about tying themselves to the hospital in such a serious way as hopping on their EMR package.
  10. Because two practices can have absolutely opposite experiences with the same EMR, no one can find consistent recommendations for any single product. (It’s not the product, it’s the implementation!)
  11. Bonus Reason: lots of people are confused about how to qualify for the ARRA money (read my post about this here.)

Where Did the Idea of Meaningful Use of Electronic Medical Records Come From?

The American Recovery and Reinvestment Act of 2009 was signed by President Obama on February 17, 2009.  The Law includes the Health Information Technology for Economic and Clinical Health Act or the HITECH Act.  The HITECH Act establishes programs under Medicare and Medicaid to provide incentive payments for the Meaningful Use of Certified Electronic Health Records technology.

The goal of the HITECH legislation is to improve healthcare outcomes, to facilitate access to care and to simplify care.  It is believed that the installation of electronic health records in medical practices is only the beginning.  The goals of HITECH will be met when the EHR is used in a meaningful way.

What is Meaningful Use (MU)?

There are three  identified components of Stage I Meaningful Use.  They are:

  1. Use of a certified EHR in a meaningful manner such as e-prescribing.
  2. Use of Certified EHR Technology for the exchange of health information (exchange data with other providers of care or business partners such labs or pharmacies)
  3. Use of Certified EHR Technology to submit clinical quality and other measures.

The first stage of Meaningful Use is capturing and sharing the data.  Meaningful Use Stage II is advanced clinical processes and Stage III is starting to look Meaningful Use of an EHR in the context of improved healthcare outcomes.

There are 25 specific criteria for MU Stage I listed in this article in Healthcare IT News:

[1] Objective: Use CPOE (Computerized Physician Order Entry)
Measure: CPOE is used for at least 80 percent of all orders

[2] Objective: Implement drug-drug, drug-allergy, drug- formulary checks
Measure: The EP (Eligible Provider) has enabled this functionality

[3] Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data.

[4] Objective: Generate and transmit permissible prescriptions electronically (eRx).
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

[5] Objective: Maintain active medication list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data.

[6] Objective: Maintain active medication allergy list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient has no medication allergies) recorded as structured data.

[7] Objective: Record demographics.
Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data

[8] Objective: Record and chart changes in vital signs.
Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20.

[9] Objective: Record smoking status for patients 13 years old or older
Measure: At least 80 percent of all unique patients 13 years old or older seen by the EP “smoking status” recorded

[10] Objective: Incorporate clinical lab-test results into EHR as structured data.
Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data.

[11] Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach.
Measure: Generate at least one report listing patients of the EP with a specific condition.

[12] Objective: Report ambulatory quality measures to CMS or the States.
Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures are discussed in section II.A.3. of this proposed rule.

[13] Objective: Send reminders to patients per patient preference for preventive/ follow-up care
Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over

[14] Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules
Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3.

[15] Objective: Check insurance eligibility electronically from public and private payers
Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP

[16] Objective: Submit claims electronically to public and private payers.
Measure: At least 80 percent of all claims filed electronically by the EP.

[17] Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request
Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours.

[18] Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies)
Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information

[19] Objective: Provide clinical summaries to patients for each office visit.
Measure: Clinical summaries provided to patients for at least 80 percent of all office visits.

[20]  Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
Measure: Performed at least one test of certified EHR technology’s capacity to electronically exchange key clinical information.

[21] Objective: Perform medication reconciliation at relevant encounters and each transition of care.
Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care.

[22] Objective: Provide summary care record for each transition of care and referral.
Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals.

[23] Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted.
Measure: Performed at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries.

[24] Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
Measure: Performed at least one test of certified EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically).

[25] Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities.
Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1) and implement security updates as necessary.

Have the Details of MU been finalized?

The comment period for the NPRM (Notice of Proposed Rule Making) for Meaningful Use is currently open but will close on March 15, 2010. You can read the NPRM here.  Many individuals and organizations have expressed concern that the timeline for implementing EHR and meeting MU criteria is too short for the majority of providers. The American Academy of Family Physicians (AAFP) recently sent a 7-page letter to acting CMS Administrator Charlene Frizzera (see story here) that included the following concerns:

  1. The administrative burden of reporting computerized physician order entry measures “is excessive to the point of being unachievable for most eligible providers.”
  2. The rule could require manually entering results from laboratories that don’t have an interoperable interface with the physician’s electronic health record.
  3. The term “health information” is used throughout the proposed rule, but is never defined.
  4. A requirement that a patient’s health information be shared with that patient within 48 hours doesn’t take in account that physicians or their staff may not be able to process the information if that 48-hour period includes weekend days.
  5. There is no incentive for physicians who meet less than 100% of the proposed requirements, so it is an all-or-nothing approach.

The Medical Group Management Association recently surveyed (see Modern Healthcare story here) 445 physician practice administrators in February 2010 with the following feedback:

  1. Nearly all are aware of the upcoming incentive programs for meaningful use of electronic health records, but fear the programs will reduce physician productivity.
  2. 68% of respondents expect physician productivity will decrease if all 25 proposed meaningful use criteria are implemented.
  3. Nearly one-third believe the decrease in productivity will be greater than 10 percent.
  4. Almost 25% of practices without an EHR doubt some of their providers will ever attempt to qualify for incentives.
  5. Among practices with an EHR, nearly 84 percent believe some of their physicians will attempt to qualify for Medicare or Medicaid incentives by the end of 2011.

How Do I Comment on the MU Standard?

You can submit your comments on the NPRM on MU here.

You can read comments already submitted here.

How Do I Know if My EHR is Certified?

No EHRs have been certified for the CMS Incentive Program and the certifying bodies have not yet been announced.  It seems reasonable that CCHIT will be one certifying body, but there are expected to be others.  If your vendor tells you that his EHR is certified before the rule has been finalized and the certifying bodies have been announced, ask him “For what?”

What Does it Mean to Be Eligible? (description courtesy of Everything HITECH)

This term encompasses three general types of payers to establish eligibility: 1) Medicare Fee For Services (FFS), 2) Medicare Advantage (MA) and 3) Medicaid.

For hospitals to be eligible, they can be acute care (excluding long term care facilities), critical access hospitals, children’s hospitals.

For providers, these include non-hospital-based physicians who receive reimbursement through Medicare FFS program or a contractual relationship with a qualifying MA organization. The Act defines the term “hospital based” eligible professional to mean an EP such as a pathologist, anesthesiologist,or emergency physician, who furnishes substantially all of his or her Medicare covered professional services during the relevant EHR reporting period in a hospital setting (whether inpatient or outpatient) through the use of the facilities and equipment of the hospital, including the hospital’s qualified EHR’s (Fed Reg p. 1905). The determining factor is the site of service as to whether the service is hospital based or not. If the EP provides at least 90 % of their services in a hospital inpatient, hospital outpatient or hospital emergency room setting (Point of Service codes 21, 22, 23), then they are considered a hospital based EP and not eligible for EHR incentive payments (i.e. providing substantially all of his or her Medicare covered professional services).

There is a difference between Medicare and Medicaid when it comes to defining an eligible professional for EHR incentive payment purposes. Medicare defines an eligible professional as (Fed Reg p. 1996):

  1. doctor of medicine or doctor of osteopathy
  2. doctor of dental surgery or dental medicine
  3. doctor of podiatric medicine
  4. doctor of optometry
  5. chiropractor

Medicaid, on on the other hand, defines an eligible professional as (Fed Reg p. 2001):

  1. physician
  2. dentist
  3. certified nurse-midwife
  4. nurse practitioner
  5. physician assistant practicing in a Federally Qualified Health Center (FQHC) or a Rural Health Clinic, led  by a physician assistant.

What are the Guidelines for Providing Patients With Their Medical Records Electronically?

Under HIPAA, patients currently have the ability to access their medical records.  Meaningful Use does not change HIPAA in that regard.  You may charge patients for the expense related to providing paper or electronic medical records.  Each state has its own schedule for charging for medical records (state-by-state schedule here.)

Do Eligible Providers Have to be Participating With Medicare to Receive the Incentive Money?

No, the eligibility requirements only relate to the benchmarks for the percentage of Medicaid patients you have, or amount of allowed Medicare charges you have.

Can Eligible Providers Work at Locations Other Than Hospitals and Private Practices and Receive the Incentive Money?

The location where the provider works is not the issue.  The issue is whether or not the provider meets the requirements, either for Medicare or Medicaid, to be considered eligible for the program.

It doesn’t matter where the provider accesses the certified EHR.  If they meet the eligibility criteria, and they are using a certified EHR, they can collect on the stimulus money.

What Are Health Provider Shortage Areas?

Physicians practicing in determined “health provider shortage” (detailed info here) areas will be eligible for a 10% bonus payment.

How Does This Incentive Relate to ePrescribing or PQRI?

If the PQRI Program is extended in its current form, practices can participate in both PQRI and an EHR Incentive Plan.

If the EP chooses to participate in the Medicare EHR Incentive Program, they cannot participate in the Medicare eRx Incentive Program simultaneously.  If the EP chooses to participate in the Medicaid EHR Incentive Program, they can participate in the Medicare eRx Incentive Program simultaneously.

Also, e-prescribing penalties sunset after 2014, so that no physician will be subject to penalties for failing to both e-prescribe and use an EHR!

How Do EPs Get Paid For Meaningful Use of a Certified EHR?

For the first payment year only, all an EP or hospital has to do is to be a “meaningful user” for a continuous 90-day period during the payment year. Hospitals’ payment year is October 1 to September 30 and EPs’ payment year is the calendar year.  You must start and complete the 90-day period within the payment year with no overlapping.

Also, if  you can qualify as a Medicaid Eligible Provider (or Hospital), are in the process of adopting, implementing or upgrading your EHR  and your Medicaid patient volume is at least 30% (Pediatricians only need 20% minimum and Hospitals need 10% minimum), you can collect your incentive money without meeting Meaningful Use criteria.

Attestation forms and forms of other types are most likely the way that EPs will provide information to apply for the incentive funds, although the details have not yet been released.

What Does it Mean to Transition From One Program (Medicaid or Medicare) to Another?

EPs who meet the eligibility requirements for both the Medicare and Medicaid incentive programs will be able to participate in only one program, and will have to designate which one they would like to participate in.  After their initial designation, EPs are allowed to change their program selection only once during payment years 2012 through 2014.


To Recap:

How Do I Get My EHR Stimulus Money?

  1. Decide whether you are an eligible provider for any of the programs.
  2. If you are, buy a certified EMR (once certification has been defined.)
  3. Use your EMR in a way that demonstrates your meaningful use of the product.
  4. Pass “GO” and collect your money.

ARRA (Stimulus Bill) Acronyms

• A/I/U –Adopt, implement or upgrade
• CAH –Critical Access Hospital
• CCN –CMS Certification Number
• CDS –Clinical Decision Support
• CMS –Centers for Medicare & Medicaid Services
• CY –Calendar Year
• EHR –Electronic Health Record
• EP –Eligible Professional
• eRx –E-Prescribing
• FFS –Fee-for-service
• FY –Federal Fiscal Year
• HHS –U.S. Department of Health and Human Services
• HIT –Health Information Technology
• HITECH Act –Health Information Technology for Electronic and Clinical Health Act
• HITPC –Health Information Technology Policy Committee
• HIPAA –Health Insurance Portability and Accountability Act of 1996
• HPSA –Health Professional Shortage Area
• IFR –Interim Final Rule
• MA –Medicare Advantage
• MCMP –Medicare Care Management Performance Demonstration
• MITA-Medicaid Information Technology Architecture
• MU –Meaningful Use
• NPI –National Provider Identifier
• NPRM –Notice of Proposed Rulemaking
• OMB –Office of Management and Budget
• ONC –Office of the National Coordinator of Health Information Technology
• PQRI –Medicare Physician Quality Reporting Initiative
• Recovery Act –American Reinvestment & Recovery Act of 2009
• TIN –Taxpayer Identification Number

To see the full transcript of the CMS Audio Conference Call from February 23, 2010 which this article drew heavily upon, view the handout, or listen to the audio of the call click here.

For more information who is eligible and for how much, read my post ARRA Eligible Providers: Who Is Eligible to Receive Stimulus Money and How Much is Available Per Provider?”


If you don’t have the following ten items on a manual checklist or in your EMR, you might want to add them.  Any time I hear someone list things that improve quality of life and downstream health, I think to myself “This is future reimbursement criteria.”  Actually, several of these are already included as measures in the 2010 PQRI (Physician Quality Reporting Initiative) list.

I came across this list on the physician blog “The Examining Room by Dr. Charles”.  Dr. Charles writes:

“These items were chosen by the National Commission on Prevention Priorities, and highlight those preventive services including immunizations, screenings, preventive medications, and counseling that give “the most bang for the buck.”

  1. Discuss Daily Aspirin Use
  2. Childhood Immunization
  3. Smoking Cessation Advice and Help to Quit
  4. Screening for Alcohol Misuse and Brief Counseling
  5. Colorectal Cancer Screening
  6. Hypertension Screening
  7. Influenza Immunization
  8. Vision Screening
  9. Cervical Cancer Screening
  10. Cholesterol Screening

Get ahead of the curve, and discuss with your providers how you can give your patients more bang for their preventive care buck by making these ten items standard questions in your practice.

Read more on Dr. Charles blog here.


Okay, okay, so I shamelessly lured you into reading this post by telling you Rosemarie Nelson would reveal the “best” EMR product on the market, and she really does, only not in the way you wish she would.  Read on to the end of this post for her EMR advice.

It was my pleasure to talk with Rosemarie Nelson after she had given her third presentation (!) at the North Carolina MGM Fall Meeting at Pinehurst this past October.  As we visited, I realized I’ve been listening to Rosemarie talk about electronic medical records for at least 10 years.  If you don’t know Rosemarie, she’s a running fanatic, an EMR guru, Principal Consultant with Medical Group Management Association (MGMA) and she has 15 years of consulting in operations and technology under her belt.

When I asked her why it’s so hard to implement electronic medical records in a physician’s office she said: “Medical practices are a home-grown industry, really a cottage industry, so every single one is different.  There are specialty differences and workflow differences and many EMR vendors don’t know how to address this.”

Rosemarie particularly enjoys helping groups to fix poorly implemented systems and often finds that vendors have not carefully looked at the way the client physicians work before selling them a system.  She has experienced the many unique ways that practices operate, and why they operate that way, and has been able to bring EMR success to over 300 practices during her tenure.

Rosemarie recommends that practices take electronic records a bite at a time.  She suggests that groups start with one component, maybe ePrescribing, or messaging or electronic test results, and get it working really well. Although vendors might prefer that a group follow its timeline, there is no reason that a practice cannot set its own timeline.  Finding out if a vendor will be flexible to a group’s unique needs and timeline is a must-have question when developing a RFP (Request for Proposal.)

The dichotomy of the physician (“make it so”) and the administrator (“take it slow”) is another challenge medical practices face.  Many physicians want EMR to happen quickly and painlessly with no interruption of workflow. Rosemarie suggests to these physicians that they should “refer their business to a specialist (her), just as they would refer their patient to a specialist.” Working through the process takes time.

Here are some other observations from Rosemarie:

  • “Apply the EMR as a tool to the operations, it is not an end to itself.”
  • “Accept the incremental benefits” of the electronic medical record.  “All or nothing is a losing propostition.”
  • On the Stimulus Money for implementing EMR: “Do it because of the benefits and if you qualify for the stimulus, all the better.”
  • On preparing an RFP (Request for Proposal): “Define the deliverables, the timeline and the money and focus on your practice’s absolute needs.”
  • On scanning old paper records into the EMR, she says “Only 25% of documents stored are ever used again.”
  • On savings using ePrescribing (besides the Medicare bump): “ePrescribing can save each FTE provider $15,000 per year on average.”
  • On using electronics to make the medical practice more efficient, “A typical primary care practice might get 85-100 patient calls per day.  Try to offload 30% of those calls per day to electronics – ePrescribing, patient secure messasging, electronic lab results, appointment requests, etc.”
  • On her favorite client story: “A cardiologist who did not want to do ANYTHING differently, saw me two years later and told me that EMR was the best thing that had ever happened in his practice!”
  • Her favorite tip: “Add your website address to your appointment reminder calls!”
  • And…her most asked question ever – Tell Me Which EMR to Buy, to which she replies, “There really is more than one good product out there.  Buy the one that matches your needs and your workflow the best, and it will be the right one for you!”

You can reach Rosemarie Nelson here: RosemarieNelson@alum.syracuse.edu