Google Health could drive EHRs

Posted on August 19, 2009 by Anthony

With two large players, Microsoft and Google, entering the health IT marketplace, it would make sense that the two would drive standards for information exchange between applications and their PHR systems.

Microsoft and Google are notorious for innovation and driving development towards their own ends yet neither seems too vocal on electronic health records and the inevitable leap in innovation the industry will experience over the next five years.

Both Microsoft and Google have electronic health portals for use by patients to create and store a patient health record (PHR) yet neither has been very vocal to drive interoperability and consistent formatting. For an industry we literally entrust our lives to, patient records have the least governance for standardization.

It makes sense that the national health exchange would dictate standards for formatting to both share doctor driven EHRs and patient driven PHRs, but with the states gaining control of the backbone of data exchange, it seems unlikely that all 50 states will agree upon a standard format. Where does the industry turn? HITSP? HHS? Industry leaders?

In the past, the health care industry seems happy to invent their own cryptic standards such as HL7, but with the aggressive time table for implementation it seems fruitless to spend time reinventing the wheel. There are many options available, but why not use XML? With XML accelerators available on the market to process large quantities of data, a structure easy to customize and modify as requirements change, and the perfect way for disparate software platforms to communicate to each other. It seems XML would be a perfect solution for vendors to use to export data from practice to national health data exchange and then again to PHR systems for the patient to view their data. XML data exporters can be effectively optimized for speed, security and integrity.

Close to any modifications and upgrades to the health IT infrastructure in use within the United States must always be the security of the patient’s health information. HIPAA security requirements are weak at the best of times, but generally are open for any knowledgeable hacker to obtain from the average health care provider. It is imperative to treat the security of patient health information with the care we treat our financial information.

How to calculate your stimulus incentive

Posted on August 6, 2009 by Anthony

There are a lot of questions and confusion around how to calculate the stimulus incentive payments that I hope to clear up in this post. My calculator on this site uses the most common method for calculating the Medicare payments but I will also explain the calculation for Medicaid.

Medicare
The first thing to do is figure out an estimate of your Medicare submitted allowable charges per patient. The Act does state that Medicare submitted allowable charges will be multiplied by 75% to figure out your annual incentive payments but there is some debate that this number may end up being the Medicare actual submitted charges multiplied by 75% which would be a lower number. A physician wanting to receive the full first year payment of $18,000 would need to submit allowable charges to Medicare of at least $24,000 to receive the full amount for first year’s payment. If you submit $18,000 for allowable charges then your payment would be $13,500. Each year the cap reduces so you can figure out your total incentive per physician by adding up the max expected stimulus for each of the years.

Year they first file	2011	2012	2013	2014	2015	2016	TOTAL
2011	$18,000	$12,000	$8,000	$4,000	$2,000	$0	$44,000
2012	$0	$18,000	$12,000	$8,000	$4,000	$2,000	$44,000
2013	$10	$10	$15,000	$12,000	$8,000	$4,000	$39,000
2014	$0	$0	$0	$15,000	$12,000	$8,000	$35,000
2015 or later	$0	$0	$0	$0	$0	$0	$0

Items to note
Physicians operating in a “provider shortage area” will be able to increase their cap of 10%. Additionally, physicians operating entirely in a hospital environment are not eligible for these stimulus funds as the hospitals have a different calculation for the stimulus funds they are eligible to receive.

Calculating total Medicare
To calculate your total incentive payment per physician for each year, simply use the following equation:
x= Average number of patients per MD per day
y= % of patients who are Medicare
z= Average submitted allowable per Medicare patient
a= Working days per year for the physician

(.75(a(z(y*x))))= Eligible Medicare submitted allowable charges

If this number is larger than the cap for each year (above table) then take the max allowable for each year and add it up for the total incentive per physician. If it is less, than use the number calculated above.

Medicaid
Calculating Medicaid payments is much more simple and provides a greater payment up front than the Medicare incentive package. Reasoning behind this is to encourage more physicians to accept Medicaid patients, but the requirements may seem to stiff for most physicians.

Medicaid stimulus calculations require physicians to see more than 30% of patients paying with Medicaid with the exception of pediatricians only required to see 20%. If your billing meets these requirements then your incentive payments are simple. $35,000 for the first year and $10,000 for subsequent years over the five year period with a total incentive payment of $64,000.

Practice totals
It is important to note that stimulus payments are calculated per physician. If a practice has multiple physicians, then this must be done for each physician and then totaled to figured out the maximum payment for an entire practice. If a practice is able to receive the maximum Medicare amount for 5 physicians, then the total payment would be $220,000 for the entire practice.

How payments are made
Although the basic formulas are available to estimate payments, there has been no official word yet on exactly when and how the payments are going to be made. It is expected that the official process for application, certification of meaningful use for the year and disbursement of payments will be out by the end of September 2009.

Shift in responsibility

Posted on August 3, 2009 by Anthony

A shift is occurring in the enforcement of HIPAA…. Again! Less confusion on enforcement and dispersion of penalties for violation of HIPAA requirements as a result. No longer will there be split departmental enforcement for HIPAA violations at the federal level.

http://tinyurl.com/kloqb7

Meaningful Use 2.0

Posted on August 3, 2009 by Anthony

Summary
If you ask a doctor what is most important to them concerning the ARRA stimulus money, most of them will tell you “meaningful use.” Multiple iterations of what this means have been issued, reviewed and regurgitated, but what does this mean to the recipient of the ARRA funds? This IT guy does not believe the doctor or health care provider should worry too much unless you already have an EHR implemented.

Transfer of Responsibility
More than likely, if a health care provider is using a CCHIT certified EHR system, they will be in compliance with meaningful use. Most of the requirements that have come out of the definition will be part of the development and implementation of the EHR. Simply implementing and using the appropriate EHR will qualify a provider for stimulus funds.

ONC Definition

Most recently, the ONC recommended a definition of meaningful use that includes seven different electronic exchanges to be required. It is important to note that this is only for the 2011 requirements. Going forward, there will be additional capabilities and exchanges required.

ePrescribing
Lab Results
Clinical Data Summaries from provider to provider
Bio-surveillance
Immunization Registries
Public Health
Quality Measurement

What does it all mean?
If you are health care provider waiting for ARRA stimulus funds, it means wait to buy your EHR. Most large companies will be updating their software to fit government requirements, but there is no guarantee the upgrade process will be any less painful than the initial implementation. Start looking at an EHR now and find out which one fits your needs best, but since funding will not be available until 2011, there is still some time.

EHR: Saving Health Care Industry $$

Posted on July 30, 2009 by Anthony

One of the main purposes for many of the new regulations in the HITECH Act and the push to increase technology utilization within the health care industry is to save money. If implementation of an EHR increases the amount of time to see a patient, is it saving money? What is the real ROI for the average provider post implementation?

My argument is by no means to stop the push for EHR and other technology improvements to the health care industry. My argument is the current players simply do not have the right EHR system to do the job. The majority of systems do not improve workflow or increase efficiency within an office. These systems definitely improve quality of care and decrease the possibility for human error, but do they actually save time and increase the doctor’s ability to perform timely and cost effective health care.

Technology generally improves a person’s quality of life. User interface design is big business. Other software developers focus on ease of use, number of clicks, user intuitive screen design. Business intelligence, finance, security and other very high tech industries have very efficient and easy to use systems. Health care does not. Health care is 10 years behind the curve.

Where is the EHR system that will anticipate the user’s actions based on previous click and role? Where is the EHR system that reduces the number of clicks compared to a comparable system by half? Where is the EHR that allows a physician to double the number of patients they see?

HITECH Act pushes high-tech development?

Posted on July 16, 2009 by Anthony

Why has the health industry historically been so quick to resist movements to jump into the electronic age? Cost barriers? Implementation headaches? Lack of usable solutions? Perhaps all of these items have contributed to the slow adoption of technology within the smaller practices but the software industry has not been helpful in reducing the barriers to entry and educating the end user.

A few weeks ago I was sitting in a seminar hosted by a major health care software development company and listened to a client testimony tell the full room to simply accept that the process of implementing an EHR should be painful and slow for six to eight months. Appalled would be an understatement for my reaction to this testimony but unfortunately it seems to be a consensus for most health care professionals when you start talking about EHR and practice management solutions. This is the fault of the software industry. It is completely unacceptable for a end user to believe that implementation of technology will impede not improve their operations.

My background in software development is not rooted in health care technology but most of my clients would have called security and had me escorted out of the building if I told them my software package was going to be painful to install and not improve business processes post implementation. It is time for the reformation of the health care software industry and impose the standards and requirements the rest of the software development world has apparently been using for years.

More importantly than simply catching up to status quo, I believe that the HITECH stimulus funding will push health care software development to push features and functions beyond the expectations of the end user. Why should the application simply store data? The application should be intuitive and interactive. If ever the software industry had a market for bleeding edge features and functionality, the health care industry is it.

Speech recognition is still very costly for rich functionality. Many EHR systems that offer speech recognition charge $100,000 or more to integrate the module and training the system for each user is yet still another costly burden. Health care IT has an opportunity to push speech recognition to the edge and reduce implementation costs while increasing effectiveness.

Moreover, IT should improve practice management operations and profit margins. Patient evaluations should move more quickly allowing doctors to see more patients without sacrificing care. Systems should automatically notify practice managers when patients are due for checkups or tests based on treatment, diagnosis and lifestyle. Prescription management should have guesswork removed. Systems should auto-interface with other provider records and pharmacy records to aggregate all prescribed medications for a patient so health care providers are better informed.

Providers should remember that anything is possible with software. Be vocal with your requests and ideas and drive development. Write letters to your congressman and women and to HHS. http://www.hhs.gov/feedback.html

Medicare Stimulus Calculator

Posted on July 16, 2009 by Anthony

2009 HIPAA; what has changed?

Posted on July 14, 2009 by Anthony

Abstract
The 2009 HITECH Act expands HIPAA coverage and definition to include covered entity business associates, definition of security breach and disclosure requirements, new restrictions on use and disclosure of protected health information, new patient rights, mandatory compliance audits and heightened HIPAA enforcement.

2009 HIPAA; what has changed?
Many changes have been made to HIPAA as part of the 2009 HITECH Act. Many expansions to existing rules were qualified and additional penalties and actions required for violation. Proactive response to new requirements should be best practice for all health care providers with careful attention paid to the additional expansion on requirements and enforcement over the next 18 months.

Expanded definition of security breach
One of the most significant changes is the burden placed on a health care provider or covered entity who suffers a breach of unprotected health information. This breach does not apply just to electronic data, but any breach of data stored by the provider. HITECH establishes a rule that all individuals affected by the breach must be notified within 60 days of the security violation. Additionally, if more than 500 records were compromised then “prominent media outlets” must be notified as well. A breach is defined as an acquisition of an individual’s unsecured identifiable health information by any person without the their authorization. Additionally, the notification of the breach will be posted on the HHS website when more than 500 records are breached.

New restrictions on use and disclosure
Additional restrictions on use and disclosure of protected health information are also in the expansion of HIPAA privacy. A covered entity is prohibited from receiving remuneration in excess of the cost of preparing and transmitting the data and only with authorization of the individual and for research purposes. Marketing to individuals based upon protected health information becomes more restrictive as well and often prohibits any direct marketing if money is exchanged by any parties involved in marketing to the individual without the individual’s consent.

New guidelines will be set forth on definition of minimum information necessary for treatment. This is used to determine what information can be transmitted between parties except for treatment of the patient. These are due within 18 months and will be defined by HHS.

New patient rights
Patients will be happy to hear that several new rights have been granted to the patient regarding use and disclosure of their health information. Patients have the right to request providers not share their health information with a health insurer if the patient is paying full cost of the services provided. Additionally, providers are required to provide a patient with a copy of their health record once a year. Additionally, covered entities maintaining electronic health records must provide audit accounting of all disclosures for treatment, payment and health care operations for a three-year period. Many of these features will be included in a patient health record portal that good EHR systems should include. Last of all is the right to opt out of fundraising communications and opportunities. Opt-out rights have been present in the past, but fundraising communications must communicate the patient’s right to opt out in future fundraising solicitations.

HIPAA coverage for business associates
Additional restrictions on how data is shared with covered entity business associates have been defined as well. All business associates of a covered entity must comply with HIPAA security requirements and data sharing policies. This legislation now brings technology vendors, practice management companies, transcription services, billing services, attorneys, accountants and many other types of business associates under direct regulation of HIPAA.

Heightened HIPAA enforcement
New more severe penalties are effective immediately for HIPAA violations.
Increased Monetary Penalties

Unknowing Violations	$100/violation up to $25,000 annually
Reasonable Cause Violations	$1,000/violation up to $100,000 annually
Willful Neglect Violations	$500,000/violation up to $1.5 Million annually with civil penalties starting in 2011

Additionally, the State Attorney General’s office are now granted authority to bring civil action against HIPAA violations. The HITECH Act also clearly defines that criminal penalties may be imposed under HIPAA for individuals or entities that wrongfully obtain protected health information.

Mandatory Compliance Audits
HHS will be required to conduct periodic audits of covered entities and business associates to evaluate HIPAA compliance.

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What do you want in your EHR (Survey)

Posted on July 13, 2009 by Anthony

[SURVEYS 1]

What does Meaningful Use mean?

Posted on July 11, 2009 by Anthony

One of the more confusing requirements for stimulus funding under the HITECH Act is the definition of “meaningful use.” The goal of this requirement is to encourage not inly implementation of an EHR, but utilization as well. Understanding how meaningful use is defined is important when determining your stimulus incentives for implementation of an EHR system. This is the first in a series of many documents to begin helping the physician understand “meaningful use” requirements and insuring stimulus funds will not be denied.

As of today, meaningful use is still very broadly defined and has a ways to go before a clear understanding emerges. The initial broad scope requirements outlined in the HITECH Act have undergone a 1st iteration by the Health IT Policy Committee and this iteration is simply a recommendation of the definition for meaningful use. On July 16, 2009, a second iteration will be released before CMS begins work on the final requirements for compliance with meaningful use.

It is important to not disregard initial iterations of the meaningful use definition. The 2011 deadline to have an EHR system in place and demonstrating meaningful use is just around the corner. Implementation and training will likely need to occur before the start of 2011 to qualify for the first incentive payments available to health care providers. Most likely a certain % of patients will be

Look for a breakdown of the 2nd iteration of the meaningful use definition on this site after the July 16th release date and expect a final publication by CMS before the end of September 2009.