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Meaningful Use Reporting Period Changed to 90 Days and Other Proposed Changes

Posted on April 10, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In case you missed the news, CMS posted the proposed rule that modifies meaningful use in 2015-2017 (Here’s the rule on the Federal Register). The 210 page document dropped late on Friday right before HIMSS. If you think we’ve seen CMS do this before, we’ve seen it happen a lot. They love to issue the rules on Friday and often right before HIMSS. At least that’s better than when they released the rule during HIMSS, but not much.

The summary of the changes is pretty straightforward:

  • Streamlining reporting by removing redundant, duplicative, and topped-out measures
  • Modifying patient action measures in Stage 2 objectives related to patient engagement
  • Aligning the EHR reporting period for eligible hospitals and CAHs with the full calendar year
  • Changing the EHR reporting period in 2015 to a 90-day period to accommodate modifications

The patient engagement was changed from 5% to a single download, view, and transmit as it’s been called. I think many will look on this as a very favorable change since you can’t force a patient to do something and so your incentive and penalties shouldn’t depend on their action.

It also makes sense that they change the hospital reporting period to the calendar year like it’s been for EPs. The change probably has some logistical questions for many hospitals, but it will make the process cleaner.

The big one of course is the 90 day attestation period. We knew it was coming and I think everyone’s glad that it’s here. Now it will be interesting to see how many wait until October to start their attestation period. That’s pretty risky if you ask me, but that didn’t stop organizations from waiting just the same.

I don’t think there will be many issues with what’s in this proposed rule. Although, we’ll see over the next week what other things people find as they dig into the rule. I know many were waiting for this to drop and are now breathing a sigh of relief over the 90 day reporting period.

Let us know in the comments if there are other details you find that we didn’t talk about or nuances we might have missed. Enjoy the light reading on the flight to HIMSS.

Working to Understand FHIR

Posted on April 9, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Ever since I’d heard so many good things about FHIR, I’ve been slowly trying to learn more about it, how it will be implemented, what challenges it faces, and what’s the pathway for FHIR to have widespread adoption.

So, it was no surprise that the Corepoint Health sessions on FHIR caught my eye and will be part of my HIMSS 2015. As part of that education they sent me their FHIR whitepaper which they’ll be handing out at their booth along with their sessions on FHIR. As with most things, the more I learn about FHIR, the more I realize I need to learn.

One example of this comes from the FHIR whitepaper linked above. It talks about defining resources for FHIR:

Resources are small, logically discrete units of exchange. Resources define behavior and meaning, have a known identity and location, are the smallest possible unit of transaction, and provide meaningful data that is of interest to healthcare. The plan is to limit resources to 100 to 150 in total. They are sometimes compared to an HL7 V2 segment.

The resources can be extended and adapted to provide a more manageable solution to the healthcare demand for optionality and customization.
Source: Corepoint Health

This section reminded me of a comment Greg Meyer tweeted during an #HITsm chat about FHIR’s biggest challenge being to define profiles. When he said, that I made a note to myself to learn more about what made up profiles. What Greg called profiles, it seems Corepoint Health is calling resources. They seem to be the same thing. This chart from the whitepaper does a great job summarizing why creating these resources (or profiles if you prefer) is so challenging:

FHIR Resource Examples
Source: Corepoint Health

I still have a lot more to learn about FHIR, but it seems like it does have really good founding principles. We’ll see if the powers that be can keep it pure or try and corrupt and modify its core principles. Not to mention take it and make it so complex that it’s not usable. I’ll be learning more about FHIR at HIMSS and I’ll be sure to report back. Until then, this FHIR whitepaper provides a pretty good historical overview of FHIR versus the other healthcare IT standards.

No Cloud Based Hospital EHR of Note…Yet?

Posted on April 8, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Scott Mace offered this interesting intro to his article “Cloud Adoption Gains Traction” in Health Leaders Magazine:

While no cloud-based electronic health record software of note for hospitals has yet to emerge on the scene, cloud-based ambulatory EHRs continue to gain traction, storage remains a strong cloud option, and intriguing new analytics options are tapping the versatility of cloud technology.

A look at hospital EHR market share and the main EHR companies (Epic, Cerner, MEDITECH, etc) are not cloud based EHR systems. Sure, some of them might have their client server installs hosted in the cloud, but that’s not a true single database EHR cloud.

What’s fascinating to me is why cloud EHR hasn’t taken off in hospitals like it’s taken off in the rest of the world (even ambulatory EHR as the article notes). It’s worth noting that athenahealth is working on a cloud based hospital EHR. However, there still at least a couple years out from even being in the conversation when a hospital considers selecting an EHR. The small SaaS Hospital EHR vendors don’t even make a dent in the market share.

Here’s why I think cloud EHR hasn’t taken off in hospitals:

Early Adopters – Many hospitals adopted some form of EHR really early on. They made the investment before cloud was really a decent option to consider (ie. before high speed internet was ubiquitous). Now they’re stuck with a legacy investment and they’re still paying off that investment

Switching Costs are High – Switching EHR in the ambulatory world is hard. Doing so in a hospital is infinitely more difficult. If I’m a CIO at a hospital, do I want to put my organization through that process? It takes a really visionary CIO and a supportive CEO to make the change.

No Great SaaS Hospital Alternatives – Once hospitals decided they needed one all in one system, that narrowed the number of EHR options to very few. We still have yet to see a SaaS software expand their offerings to cover the full gamut of software that’s required by a hospital. For example, even Epic which has been around forever (and is not a cloud EHR for the record), still gets complaints from hospitals about their lab software. Now apply that to 100 departments in a hospital and SaaS software just hasn’t been able to provide the full suite of software a hospital requires.

Fear – I think most hospitals are still afraid of the cloud. There are plenty of reasons why they should be less afraid of cloud than their current set up, but there’s still very much fear surrounding cloud. Somehow having the servers in my data center, on site where I can touch them and feel them makes me feel more safe. Reality or not, this fear has prevented most hospitals from even considering a cloud based EHR. I think they’re starting to get past it since every hospital now has something in the cloud, but that wasn’t true even 5 years ago in many organizations.

I’m sure there are other reasons you can offer in the comments. Of course, Scott Mace’s article linked above goes into a number of the benefits of a cloud EHR. However, that’s not yet a realistic option for hospitals. I’m sure one day it will be.

1/5th of Hospital EHRs are Poor Fits

Posted on April 6, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.


This is a really fascinating stat from Black Book. I’d like to dig into their methodology for this question. Defining what’s a “poor” fit is really hard when you realize that a poor fit is defined by hundreds and possibly thousands of EHR users in a hospital.

What I’ve found is that it’s really hard to make broad statements about EHR satisfaction at a hospital. The doctors may hate it, but the executives love it. The front desk may be annoyed by it, but the pharmacy is really happy. The nurses may love it…ok…I don’t think I know of any EHR that’s loved by nurses, but that’s a discussion for another blog post. Nurses often get left out in the EHR design and we’ll leave it at that for now.

With that disclaimer, let’s think about what it means that 20% of hospital EHRs are a poor fit. Does that mean that we’re going to see a wave of EHR switching in the hospital EHR world? I don’t think so.

The reason I don’t think so is that the hospital EHR is too expensive. Plus, changing EHR is so disruptive that you have to be really down on your EHR to actually switch. Sure, some of them are that down on their EHR that they’ll switch EHR. However, most of them don’t like it, but they aren’t ready to go through heart replacement surgery and take out their current EHR and replace it with a new one.

Some other factors at play is that they may not like their current EHR, but it’s the devil they know. That’s a powerful reason not to switch. Also, is there really a better alternative? Many who aren’t satisfied with their EHR aren’t convinced that switching to another EHR will be much better. Plus, many of these organizations are in the middle of meaningful use. If you switch EHR vendors in the middle of meaningful use, you might as well announce that you’ll be taking a year off from meaningful use (and all that entails…ask Intermountain).

While I don’t think we’ll see a wave of immediate EHR switching, once the renewal licenses come up, we’ll see more switching of EHR. Plus, if someone can come out with a high quality cloud based EHR for hospitals, then that could help with switching costs as well. However, until then, hospitals have mostly chosen their horse and now they have to ride it out. Of course, this assumes they don’t get acquired by a larger hospital system and are forced to switch EHR. That’s happening in a big way and is likely to continue.

Bringing Meaning to Disparate Clinical Data

Posted on April 3, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

For a while, I’ve been extremely intrigued by vendor neutral archives. While they’re usually applied to the PACS and imaging world, I’ve always thought that the concept will eventually spread across all healthcare data. With that in mind, I found this whitepaper, Bringing Meaning to Disparate Clinical Data, provided an interesting view into the world of vendor neutral archives (VNA) and it was very clear to me that the problems we’re working to solve in the medical imaging world are very much applicable to the problems we need to solve with other healthcare data (ie. EHR data).

Here’s how the whitepaper suggests you evaluate VNA solutions:

  • Interoperability
  • Image accessibility
  • Disaster recovery
  • Upgradability
  • Data security
  • Ease of use

It’s quite easy to see how this same list could just as easily apply to any healthcare IT system that a hospital adopts. The image accessibility may not apply, but accessibility of data (which is what the image represents) is extremely important. I think that many organizations would be much happier with their EHR today if they’d used the above list in their EHR selection process.

The whitepaper also lists events that affect the timing and direction around enterprise image management planning:

  • Replacing a PACS
  • Joining an integrated care community
  • Accommodating new sources of images
  • Impending mergers, acquisitions, and associations
  • Storage convergence
  • Centralized management

Looking through the list, it’s very clear to me that many of the above items are going to be drivers of EHR switching as well. In fact, it’s going to make up the majority of future EHR purchases. Plus, we’re seeing a lot of changes when it comes to joining care communities and mergers, acquisitions, etc.

At the conclusion of the whitepaper, it suggests that the single most important key to choosing an enterprise solution for image management is flexibility:

  • Flexibility of connecting all kinds of devices and systems.
  • Flexibility of accessing information anywhere, anytime
  • Flexibility to scale effectively with facilities’ growing needs
  • Flexibility to meet departmental needs

We didn’t use this framework for selecting EHR vendors, but will we use it the next time around. Has our current EHR experience helped us to realize the value of flexibility with our healthcare IT software vendors? I think these will become part of the future EHR purchase process.

I don’t think the markets are that much different. The future of EHR in healthcare organizations will likely follow the path that imaging vendors have already trod. It’s just too bad we couldn’t learn from imaging’s experiences and apply them to EHR already. Since we haven’t, I think learning about the history of image management systems in healthcare will help us better understand where EHR is headed.

Why Can’t Release of Records Be Automated Through A Patient Portal?

Posted on March 31, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I was in a recent discussion with one of the leading providers of release of information services, HealthPort about EHR’s impact on the release of health records. In our discussion, I asked why the release of health records can’t be completely automated through a patient portal. In my mind, meaningful use is requiring that healthcare organizations put a patient’s record up on a patient portal, so shouldn’t that mean that the release and disclosure of patient records would become obsolete?

Of course, I was applying a limited view to what’s required when a disclosure happens and who is making the records request. In most cases, it’s not the patient requesting the record and these third parties don’t have access to the patient’s portal. Plus, the release and disclosure of patient records often requires accessing multiple systems along with assessing which information is appropriately included in the disclosure. The former is a challenge that can be solved, but the later is a complex beast that’s full of nuance.

In order to clarify some of these challenges and explain why a patient portal won’t replace all records requests, here’s a short interview with Jan McDavid, Esq., General Counsel at HealthPort.

Q: What are HIPAA requirements around “charging” for copies of records, and what are considered “reasonable” costs?

A: HIPAA is very clear that its pricing applies only to copies provided to “individuals,, which HIPAA defines as the person who receives treatment—the patient. HIPAA guidance pertains only to patient requests for medical records, approximately seven percent of all requests received by healthcare providers.

The majority of records are requested by physicians for continuing care, governments for entitlement benefits, insurers, and inquiries from attorneys, according to internal data from HealthPort’s 2014 record release activity nationwide.

Within the realm of patient requests, providers can charge patients no more than their labor costs to produce the record, plus supplies and shipping. No upfront fee to search or retrieve records may be charged to patients.

Q: Why shouldn’t records just be free now that they are electronic?

While many believe the cost to produce records should be negated once information is digital, there are misperceptions and logistics that must be understood. The process of disclosure management (release of information) involves many steps that still require human intelligence and intervention—especially on the front end of the process (receiving, validating and approving the request). Here are three examples:

  • The authorization must be adhered to strictly, which often requires contacting the requester and explaining that some of the records they requested may not be available, or may require very specific patient authorization.
  • Information is commonly pulled together from multiple sources and systems (paper and electronic) to fulfill a request. While providers are working toward completely electronic environments, almost all still have a combination of paper and electronic. Depending on who makes the request, every single page of a record may require review.
  • Staff releasing records must be trained on HIPAA, HITECH, the Omnibus Rule, state and federal subpoena requirements, and specific state and federal laws for drug, alcohol, HIV/AIDS, mental health, cancer, genetics, minors, pregnancy, etc.

Q: If the EHR is in the portal, what other records aren’t in the EHR that HIM staff has been aggregating in a records request?

A: Not all patient information is automatically included within the patient portal view, nor should it be. Each provider organization determines what EHR information is posted to the portal and what patients can do within the portal (e.g. requesting refills, scheduling appointments, viewing lab results, etc.). HIM experts are key in these decisions.

The Overdose – When EHRs Go Wrong

Posted on March 30, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

We’re getting more and more stories coming out about the impact for bad that an EHR can have in medicine. Most of them have been anecdotal stories like The Old Man and the Doctor Fable and Please Choose One. However, today I came across one that talked about an overdose due to an error in the use of EHR. Here’s a summary of the discovery:

Levitt’s supervising nurse was stumped, too, so they summoned the chief resident in pediatrics, who was on call that night. When the physician arrived in the room, he spoke to and examined the patient, who was anxious, mildly confused, and still complaining of being “numb all over.”

At first, he was perplexed. But then he noticed something that stopped him cold. Six hours earlier, Levitt had given the patient not one Septra pill—a tried-and-true antibiotic used principally for urinary and skin infections — but 38½ of them.

Levitt recalls that moment as the worst of her life. “Wait, look at this Septra dose,” the resident said to her. “This is a huge dose. Oh my God, did you give this dose?”

“Oh my God,” she said. “I did.”

If you read the whole article linked above, you’ll discover that the issue happened when entering the dosage for a drug into the Epic EHR system at UCSF. I’m not here to point fingers since every case is unique and you could argue forever about whether it’s the software’s responsibility to do something or whether the person using the software is responsible for understanding how the software works. I think that’s a discussion that goes nowhere since the right answer is that both can do better.

These types of stories are heartbreaking. They even cause some to question whether we should be going electronic at all. I’m reminded of a time I was considering working at a company that did expert witness testimony for cars. One of their hypothesis was that the computers that are now found in cars will usually save people’s lives. However, in a few cases they’re going to do something wrong and someone is going to lose their life. I think that’s where we’re at with EHR software. It’s not perfect and maybe never will be, but does it save more lives than it kills?

That’s a tough question that some people don’t want to face, but we’re going to face it whether we acknowledge the question or not. Personally, I think the answer to that question is that we do save more lives with an EHR than we damage. In the case above, there were still a lot of humans involved that could have verified and corrected the mistake with the EHR. They didn’t, but they could have done so and likely do with hundreds of other mistakes that occur every day. This human touch is a great counterbalance to the world of technology.

If we expanded the discussion beyond lost lives, it would be a much more challenging and complex discussion to know if EHR makes an organization more or less productive. I believe in the short term, that discussion is up for debate. However, in the long term I’m long on the benefits of EHR when it comes to productivity.

None of this should excuse us from the opportunity to learn important lessons from the story above. We need to be careful about over reliance on data in the EHR (similar to over reliance on a paper chart). We need to make our EHR smarter so that they can warn us of potential problems like the ones above. We need EHR vendors to not let known EHR problems remain unfixed. We need a solid testing plan to avoid as many of these situations as possible from ever happening in the first place.

There’s a lot of work to do still to improve EHR. This story is a tragic one which should remind us all of the important work we’re doing and why we need to work really hard to improve it now.

Meaningful Use Stage 3 Apathy

Posted on March 27, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ll admit that I was out of town when the meaningful use stage 3 rule was released. (Side Note: Why do they always release the rule on a Friday right before the weekend?) So, unlike many people I wasn’t deep in the regulatory details of meaningful use stage 3.

Since I missed the initial release of MU stage 3, I like to read the commentary coming from other people to sort of triangulate some of the most common issues and challenges people have with the new rule. However, what’s been fascinating for me in almost all of these writeups is that people are tired of meaningful use.

Over and over I’ve read of people who haven’t read the rules, people who are putting off reading the rules, and people who’ve shunned meaningful use all together. In fact, I’ve been shocked by the number of people who are just “over” meaningful use. They’re ready to move on from it and move on to something new.

Many people might misinterpret this apathy with meaningful use as a dislike for technology in general. In most of the cases I’ve mentioned that couldn’t be further from the truth. Most of the people who are tired with meaningful use are all about implementing technology in healthcare. They’re just tired of the government regulating that they do it.

What’s not clear to me is whether this apathy is deep enough that hospitals will not actually go after the meaningful use dollars or not. The EHR incentive money is very real for many hospitals and the penalties are a big deal as well. A decision to not do meaningful use is a really big one and the financial incentives and penalties might still win out. However, you can be sure that whoever’s working on the MU stage 3 project won’t do it with as much gusto as they did MU stage 1.

By Tradition, or By Design?

Posted on March 11, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

A few of my healthcare social media family are my friends on Facebook and so a get a smattering of work on my Facebook account. Today when I was browsing through my Facebook feed (likely avoiding some other work) I found this great question from Dirk Stanley, MD, MPH (@dirkstanley), and CMIO at Cooley Dickinson Hospital:

By Tradition, or By Design?

4 words that caused me to stop my day and think. Hopefully it does the same for you.

Dirk is a great guy if you don’t know him. I love running into him at HIMSS since he always seems to be hanging around a bunch of other CMIOs who are overwhelmed by the craziness of HIMSS. It then leads to great conversations since he’ll pose questions like the one above.

There are so many ways we could talk about the question of tradition and design in healthcare. I think we could all come up with examples where tradition was an amazing thing for healthcare and where tradition has been detrimental. The same could be said for design. Like in most things in life, it depends.

With that as framework, I’m more interested in talking about how often we’re stuck designing around traditions. When the tradition is a good thing, that can lead to excellent results. When the tradition is a bad thing, it can lead to awful results. Once our traditions are incorporated into design, it’s REALLY hard to change those traditions.

Our billing system is a great example of this challenge. EHR systems were built around the traditions we’ve created in our billing system. For doctors wanting to be reimbursed for their work, it’s been a good thing. They need to get paid and early iterations of EHR were often able to get doctors paid at a higher level just based on their ability to create more complete documentation. The tradition of creating fluffy documentation that would get paid at a higher level has now been designed into most EHR systems. Every doctors knows the impact of this and it’s not a very pretty result. Plus, now it’s EXTREMELY hard to change.

The good news is that the only way to solve this problem is to design new traditions that avoid these challenges. That’s what they’re trying to achieve with ACOs. Although, the above example should be a warning to those designing these new reimbursement models. If you design them well so they become a tradition that’s integrated into our systems, all will be well. However, the opposite is also true.

By Tradition, or By Design? I’d love to hear your thoughts.

Health System Investment in Single EHR Platform

Posted on March 6, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I heard about this investment at an ACO conferences in Las Vegas. It had been a while since I’d written about the hospital subsidizing the cost of an EHR for their affiliate providers. We all know they’ve been implementing an EHR with their owned practices. However, in a lot of areas the hospital is also spending a bunch of money subsidizing the cost of EHR for their affiliated providers as well.

The above comment is even more interesting in the context of an ACO. Basically, this health system’s progress towards an ACO gave them a really great reason why they should spend money on an EHR for even their affiliate providers. They obviously saw a lot of value in having all the providers and hospitals on a single EHR. Otherwise they wouldn’t have made an investment like this.

This also seems to highlight their bleak outlook on healthcare interoperability. If interoperability was a reality, would they really care that much about having everyone on a single EHR platform?

What is absolutely clear to me is that an ACO needs technology to connect all of the entities in the organization. The single EHR approach is one way. However, there’s a really strong argument to be made that most ACOs are going to be a heterogeneous environment. Where does that leave the ACO?