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CMS Issues Final Rule on EHR Certification Flexibility, MU Stage 2 Extension, and MU Stage 3 Timeline

I can’t figure out what government process leads to final rules being regularly published at the end of the day on Friday. I know that Neil Versel from Meaningful Health IT News has hypothesized that they release it late on Friday when they want to bury the news. Maybe that’s the case, but the EHR certification flexibility doesn’t seem like something they’d want to bury. Regardless of the odd timing, CMS has just published the final rule that provides flexibility around EHR certification in the meaningful use program.

In their announcement, I’m not noticing any changes from what was in the proposed rule, but with some time we’ll know for sure if there’s any gotchas hidden in the final rule. No doubt many a meaningful use expert have just had their Labor Day weekend ruined by the announcement of this final rule.

Unfortunately, after the proposed rule was published most people loved the flexibility, but decided that it was too late for them to really benefit from the changes. I’ll be interested to see how many organizations will really benefit from these changes.

More importantly, the rule still includes the nebulous asterisk, “Only providers that could not fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability.” For EHR vendors that are already 2014 certified, this little asterisk feels like ONC is letting all the EHR vendors who didn’t perform well off the hook. It’s basically rewarding EHR vendors who can’t or have chosen not to keep up. Maybe that’s why the rule was published late on a Friday.

One could make the case that ONC was more worried about the doctors/hospitals whose EHR vendors failed to become 2014 certified, than the EHR vendors themselves. However, that part of the story is not likely to be told. Plus, it doesn’t take into account how a doctor/hospital whose EHR vendor is 2014 Certified will feel having to do the substantially harder MU stage 2 while their colleagues only have to do MU stage 1. (UPDATE: This EHR Certification Tool that CMS created seems to say that even if you’re on a 2014 Certified EHR and scheduled to do MU stage 2, that you can do Stage 1 or stage 2 objectives with 2014 CQMs. The chart linked at the bottom of this post says it as well. Seems like they’re being pretty open in their interpretation of “due to delays in 2014 Edition CEHRT availability”. Clear as mud?)

I’ve captured a chart showing the EHR Certification flexibility that this final rule provides:
EHR Certification Flexibility - 2014 Certified EHR

Plus, here’s the latest chart showing the meaningful use timelines:
Updated Meaningful Use Stage 3 Timeline

Other Resources and Responses:
CMS Official Press Release
CHIME’s Response
CMS’ EHR Certification Rule Tool
CMS HITECH 2014 CEHRT Flexibility Chart

We’ll keep adding other responses and commentary on the final rule as we find them.

August 29, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

The Path to Interoperability

The following is a guest blog post by Dave Boerner, Solutions Consultant at Orion Health.

Since the inception of electronic medical records (EMR), interoperability has been a recurrent topic of discussion in our industry, as it is critical to the needs of quality care delivery. With all of the disparate technology systems that healthcare organizations use, it can be hard to assemble all of the information needed to understand a patient’s health profile and coordinate their care. It’s clear that we’re all working hard at achieving this goal, but with new systems, business models and technology developments, the perennial problem of interoperability is significantly heightened.  With the industry transition from fee-for-service to a value-oriented model, the lack of interoperability is a stumbling block for such initiatives as Patient Center Medical Home (PCMH) and Accountable Care Organization (ACO), which rely heavily on accurate, comprehensive data being readily accessible to disparate parties and systems.

In a PCMH, the team of providers that are collaborating need to share timely and accurate information in order to achieve the best care possible for their patient. Enhanced interoperability allows them access to real-time data that is consistently reliable, helping them make more informed clinical decisions. In the same vein, in an ACO, a patient’s different levels of care – from their primary care physician, to surgeon to pharmacist, all need to be bundled together to understand the cost of a treatment. A reliable method is needed to connect these networks and provide a comprehensive view of a patient’s interaction with the system. It’s clear that interoperability is essential in making value-based care a reality.

Of course, interoperability can take many forms and there are many possible paths to the desired outcome of distributed access to comprehensive and accurate patient information.  Standards efforts over the years have taken on the challenge of improving interoperability, and while achievements such as HL7, HIPAA and C-CDA have been fundamental to recent progress, standards alone fall far short of the goal.  After all, even with good intentions all around, standard-making is a fraught process, especially for vendors coming to the table with such a diversity of development cycles, foundational technologies and development priorities.  Not to mention the perverse incentives to limit interoperability and portability to retain market share.  So, despite the historic progress we have made and current initiatives such as the Office of the National Coordinator’s JASON task force, standards initiatives are likely to provide useful foundational support for interoperability, but individual organizations and larger systems will at least for the time being continue to require significant additional technology and effort dedicated to interoperability to meet their needs.

So what is a responsible health system to do? To achieve robust, real-time data exchange amongst its critical systems, organizations need something stronger than just standards. More and more healthcare executives are realizing that direct integration is the more successful approach to taking on their need for interoperability amongst systems. For simpler IT infrastructures, one to one integration of systems can work well. However, given the complexity of larger health systems and networks, the challenge of developing and managing an escalating number interfaces is untenable. This applies not only to instances of connecting systems within an organization, but also connecting systems and organizations throughout a state and region. For these more complex scenarios, utilizing an integration engine is the best practice. Rather than multiple point-to-point connections, which requires costly development, management and maintenance, the integration engine acts as a central hub, allowing all of the healthcare organization’s systems from clinical to claims to radiology to speak to each other in one universal language, no matter the vendor or the version of the technology.  Integration engines provide comprehensive support for an extensive range of communication protocols and message formats, and help interface analysts and hospital IT administrators reduce their workload while meeting complex technical challenges. Organizations can track and document patient interactions in real-time, and can proactively identify at-risk patients and deliver comprehensive intervention and ongoing care. This is the next level of care that organizations are working to achieve.

Interoperability allows for enhanced care coordination, which ultimately helps improve care quality and patient outcomes. At Orion Health, we understand that an open integration engine platform with an all access API is critical for success. Vendors, public health agencies and other health IT stakeholders are all out there fighting the good fight – working together to make complete interoperability among systems a reality. That said, past experience proves that it’s the users that will truly drive this change. Hospital and health system CIOs need to demand solutions that help enhance interoperability, and it will happen. Only with this sustained effort will complete coordination and collaboration across the continuum of care will become a reality.

About David Boerner
David Boerner works as a Solutions Consultant (pre-sales) for Orion Health where he provides technical consultation and specializes in the design and integration of EHR/HIE solutions involving Rhapsody Integration Engine.

August 28, 2014 I Written By

Monday Health IT Potpurri


This is a little bit self serving since Dan’s tweet includes a link to my article on EMR and EHR called, “If You Were an EHR, Which Would You Be?” Although, that post was 19 days ago, so it’s fantastic that Dan loved it enough to tweet it again. Plus, I’m sure that hospital readers will love that article. Side Note: Be sure to subscribe to all the other Healthcare Scene blogs here.


This shouldn’t be surprising. ACOs only require basics. Once they start requiring advanced capabilities, then they’ll built them.


Good advice from Cassie on LinkedIn. Good advice for anyone looking for a healthcare IT job is to get brushed up on LinkedIn. Not to mention uploading your health IT resume to Healthcare IT Central.

August 25, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

Other Forms of Overcharging in Hospitals

In response to my previous post talking about hospital overcharging being overstated, I got an interesting reply from someone about other ways that “overcharging” is happening in hospitals.

Some are overcharging according EMR upgrade coding errors. How about $720 for ONE nitro tablet. Insurance company did not catch it either. About 9 months after an EPIC implementation so how many people/Insurance were overcharged and never knew?

In the meantime a gastric band operation in the UK is $7500 average. In the US it is between $15k and $30k depending on State. Is that not overcharging?

The first one is really interesting. You can see how after implementation of an EHR in a hospital it would be easy to charge extra for something (even accidentally). There are so many details to look at during an EHR implementation that it’s easy to see how something could be overcharged. Plus, it’s probably not a surprise to many that the insurance company doesn’t catch many overcharges.

The second point they made isn’t an over charge as we were describing it. Although, the price disparity question is a really important one and could be considered over charging in healthcare. Just a different form.

I’ve long said that I think the biggest key to fixing the healthcare pricing problem is to infuse more transparency into the system. Once transparency gets applied to pricing, it usually gets resolved pretty quickly. The second piece to transparency is shifting the cost responsibility to patients. In the past, patients didn’t care since they just paid their co-pay. However, this is quickly changing with more high deductible plans. This shift will require price transparency and then healthcare will be held accountable for what they’re charging for their services.

August 21, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

The Place of EHR in the Hospital IT Ecosystem

I’ve been thinking a lot about EHR software and the part it plays in the hospital IT ecosystem. The $36 billion of EHR stimulus money has shined a big light on EHR software. No doubt the EHR incentive money has increased EHR adoption, but at what cost. I wonder if the EHR incentive money has caused many hospital IT teams to place undue emphasis on the EHR software.

The reality of a hospital IT ecosystem is that they usually have hundreds of healthcare IT systems in their organization. The EHR is just one of those systems. In fact, it might not even be the largest system. Their ERP system (usually Peoplesoft or SAP in large hospitals) could be larger. However, try being system #90 at a hospital. Do you think the IT people at a large hospital system are paying much attention to what’s happening to that system? Not only are they distracted chasing the EHR incentive money, but even without that incentive there are 89 other systems in front of it.

I’m reminded of this Healthcare CIO Mindmap that I posted previously. It’s a great image of the amazing complexity that a healthcare CIO is facing. Each of the branches on that mindmap represent one or more IT systems that have to be managed by an organization. That’s a complex and challenging task.

I guess my message here is that while the EHR is extremely important to an organization, don’t lose track of all the other healthcare IT systems you support. They won’t likely be noticed in the short term, but transgressing these smaller health IT systems will create organizational debt that will be hard to overcome in the future.

August 20, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

Has Epic Fostered Any Real Healthcare Innovation?

I saw the following tweet and was really struck by the question.

I think we could broaden the question even more and ask if any EHR vendor has really fostered healthcare innovation. I’m sorry to say that I can’t think of any real major innovation from any of the top hospital EHR companies. They all seem very incremental in their process and focused on replicating previous processes in the digital world.

Considering the balance sheets of these companies, that seems to have been a really smart business decision. However, I think it’s missing out on the real opportunity of what technology can do to help healthcare.

I’ve said before that I think that the current EHR crop was possibly the baseline that would be needed to really innovate healthcare. I hope that’s right. Although, I’m scared that these closed EHR systems are going to try and lock in the status quo as opposed to enabling the future healthcare innovation.

Of course, I’ll also round out this conversation with a mention of meaningful use. The past 3-5 years meaningful use has defined the development roadmap for EHR companies. Show me the last press release from an EHR company about some innovation they achieved. Unfortunately, I haven’t found any and that’s because all of the press releases have been about EHR certification and meaningful use. Meaningful use has sucked the innovation opportunity out of EHR software. We’ll see if that changes in a post-meaningful use era.

August 13, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

Pay at Epic – Did You Know There’s an Epic Reddit?

HIStalk recently pointed to a reddit post about the Salary, Raise and bonus structure at Epic. It’s a fascinating look at what you get paid to work at Epic. I’ll be covering that topic in detail on our Healthcare IT Today career blog. However, did you know that there’s a subreddit on Epic?

In some ways, I think this says a lot about how far reddit has come, but it also says something about the size of Epic and the type of employee they attract. The younger reddit generation is their hiring strategy.

The subreddit is quite interesting. They talk about things like lunch at Epic (cheap and good), what it’s like to be a mom at Epic, and even topics like whether you can have a tattoo at Epic. Although, this one talking about the creepy customer announcements made me laugh:

The customer announcements over the loud speaker are so bizarre. It makes me feel like I’m in a1984-esque reality with an unsilenceable propaganda machine.
I doubt they intend it to be this way, but it is all I ever feel when it occurs.
Does anyone not find them creepy?

Looks like they even preach the Epic culture over the loud speaker. I do like that their celebrating each customer win since an Epic customer win is a really big deal. Although, the description makes me wish I could hear one of these announcements.

The Epic subreditt isn’t super active, but I’ll have to keep an eye on it to see any other interesting topics that are started. Maybe start a few of my own.

August 11, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

Cerner’s Siemens Acquisition and the Impact on the DoD Bid

One topic I didn’t address in my post covering the $1.3 billion Siemen’s acquisition by Cerner is how this will impact the $11+ billion DoD bid. There’s a lot of discussion about what this acquisition will do. Let me pull out my crystal ball and give you my thoughts.

I personally think that this acquisition will have very little impact on which cluster of companies will win the DoD EHR contract. Some might say that Cerner gains some advantage by having some of the Siemens capabilities on board. Others could argue that Cerner will be distracted with the Siemens acquisition and so they wouldn’t be able to focus on such a large EHR contract. While both of things have some truth, I really don’t think they’ll factor into the DoD decision making.

It seems the consensus out there is people expect Epic to win the DoD contract. If that happens, the Siemens acquisition could become even more interesting for Cerner. It’s a very likely reality that whoever gets the DoD contract will lose some potential clients due to concerns about capacity. If Epic or Cerner get the DoD contract, then it’s possible that these capacity concerns will move them down a notch in people’s EHR selection process. This is a situation where Cerner will benefit from having connections to all of these Soarian customers. As I posted previously, it might be best for Epic not to win the DoD contract.

Are there other ways that Cerner’s acquisition of Siemens impacts the DoD EHR bid?

August 7, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

EHR Consolidation Continues as Cerner Acquires Siemens Soarian

The big news that had been rumored for a while was that Cerner was going to acquire the Siemens Health Services product line including Soarian. The rumor became reality as the acquisition was announced today. You can see the investor slide deck they published here. Most notably, Cerner has committed to supporting the Siemens Soarian product line for a decade:

Following the acquisition, support for Siemens Health Services core platforms will remain in place. Current implementations will continue, and Cerner plans to support and advance the Soarian platform for at least the next decade.

Of course, it’s one thing to suggest this in a press release. It’s another thing to actually do it in practice. However, it was smart of them to announce this approach to allay the fears of Soarian customers. If enough Soarian customers move over to Cerner, then you can be sure the announcement to sunset Soarian will happen. That’s a feature of EHR acquisition and consolidation. It’s just too expensive, especially in this regulatory environment, to maintain two code bases which perform the same functions.

These stats about the combined organizations are quite interesting:

  • 20,000 associates in more than 30 countries
  • 18,000 client facilities, including some of the largest health care organizations in their respective countries
  • $4.5 billion of annual revenue
  • $650 million of annual R&D investment

The last one is interesting given yesterday’s post on R&D companies. However, I think one of the key numbers there is the associates in 30 countries. Siemens Health Services has approximately 5,000 client facilities in over 40 countries including a strong presence in Germany, Sweden, Austria, Spain, Norway, and the Netherlands. You can be sure that a large part of this acquisition by Cerner is being able to go after the global market. There’s a huge opportunity in many countries that haven’t had billions of dollars falsely stimulating the market.

What I found particularly interesting on the investor call about the deal was Siemens efforts to take care of their existing customers. I’d describe it as finding a soft landing for their customers. You can understand why this is important. Many of those Soarian customers are still Siemens customers in other parts of the business like radiology. Siemens no doubt didn’t want to kill their other business by selling Siemens Health Services.

We’ll see what comes of the Siemens and Cerner $100 million innovation budget. If you look at the wording it says stuff like up to $100 million budget. Plus, these two companies are going to have to work together on some projects regardless. Cerner needs the data Siemens has and Siemens will need to get the data into Cerner. Will anything beyond that really occur, I’m not as optimistic.

I did find Neil Patterson’s comments on the post-Meaningful Use era interesting. I’d love to explore more of what he sees in that future. One person described it as a move from documenting the care given to a patient to technology that drives the care given a patient.

I’m not sure hospital execs should be that excited about this acquisition. It takes out another competitor from keeping EHR vendors honest. This really is getting down to a two horse race between Cerner and Epic and I think this acquisition will put Cerner just ahead of Epic in market share.

I liked this tweet from Hospital CIO Will Weider about the acquisition:

August 5, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.

R&D Budget or Your Company Is R&D

Today I realized a good way to describe the difference between a large company and a startup company. I was reading an interview with a very large healthcare IT company and whenever he was asked about the innovations they’re working on in healthcare IT he referred to their R&D budget or their R&D efforts. As more of a startup person myself, I found the mentality interesting to compare against a startup company. At a startup company, your entire company is focused on innovating.

I find the approach so uniquely different and explains why many hospital organizations don’t want to work with startup companies. These hospital organizations are afraid that the startup company won’t deliver the results they expect. I get it. It’s much easier to “choose IBM” versus go with a newer startup company when working on a project. I think we regularly underestimate the value of a great brand.

I’ve seen the same. While my blog network has deep reach into the healthcare IT community, I’ve seen companies fawn all over Forbes bloggers (not to be confused with Forbes journalists) mostly because they saw the Forbes brand. The power of a great brand is tremendous. In fact, the power of a known brand (even if it’s not a great brand) is extremely powerful.

What I find most ironic though is that most hospitals love being part of the “innovation” programs these large companies put together. You’ve all seen the press releases that are put out between large company A and hospital B. Why are hospitals so interested in being part of large health IT companies R&D efforts and yet they’re scared of health IT startups?

I’m sure some would make the case that the large health IT companies will be around for a while and the health IT startup companies might not be. This is true, but what’s to keep a large health IT company from cutting their R&D budget and killing your innovation program? Nothing. Isn’t that the same thing as a health IT startup company closing up shop? In fact, I’d argue that the later might be better for you. If the health IT startup company was on to something and just ran out of funding, you could buy the whole startup company and continue your efforts. Try doing that with a shutdown innovation program at a large company.

I think healthcare would really benefit from being more open to startup innovations. I realize that the politics of a hospital system make it tough. However, with some smart planning and thought, we could find ways to make working with health IT startups easier. Our hospitals and healthcare in general would really benefit from doing so.

August 4, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.