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

Posted on 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 13 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.

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.

The Path to Interoperability

Posted on August 28, 2014 I Written By

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.

The Forgotten Pieces of Healthcare IT

Posted on August 27, 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 13 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.

I’ve obviously been thinking a lot lately about the rest of the healthcare IT world beyond EHR software. We’ve had such a focus on EHR software, that we’ve forgotten a lot of other IT projects that need attention. I saw a quote recently that a CIO is no longer just managing the IT infrastructure. I believe that’s spot on.

A hospital CIO needs to be an integral part of the business decisions of their organization. You can’t buy a few hundred million (or a few billion) dollar EHR and not think that it won’t have a major economic impact on your organization. However, while a hospital CIO needs to do more than just IT infratructure, they still have to do the IT work as well.

I was thinking about all of the various IT projects that a hospital CIO could still be managing:

  • Internal Network
  • External Internet Connection
  • Firewalls
  • Data Center (this could be a few hundred things in itself)
  • Servers/Virtualization
  • Desktops (virtual or otherwise)
  • Mobile Devices (cell, tablets, etc.)
  • Telephony
  • Identity Management
  • Email
  • Shared Drives
  • Printers
  • Scanners
  • Biometrics

I’m sure I’m leaving some obvious ones off. Please add to the list in the comments. However, even just looking at this is pretty overwhelming. Luckily, most hospital CIOs have a lot of people helping them support all of these efforts. However, each one needs to be considered and managed.

Take a simple example like email. You’d think we’d have it down to a science and we kind of do. However, if you host it in house, you have to constantly stay on top of it, update the software, manage mailbox sizes, spam filters, etc. Whether you outsource your email or keep it in house you also have to manage all the account creation and deletion. You have to provide ongoing help desk support and training.

The point I’m trying to make is that each one of these technologies has its little nuances. It takes time and effort to do them well. Unfortunately, many of them have been transgressed as the all hands on deck EHR efforts have occurred. Now we’re heading back to clean up these messes. Looking at the list above, there are a lot of possible messes waiting for a hospital CIO.

Monday Health IT Potpurri

Posted on 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 13 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.


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.

What Should You Do About HIPAA Today?

Posted on August 22, 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 13 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.

Mac McMillan, CEO of Cynergistek, offers some great insight into why organizations should make sure they’re on top of HIPAA today and where they can start.

The above video is just a portion of the full HIPAA Privacy and Security interview I did with Mac. He has a lot of great insight into what’s happening with HIPAA and HIPAA audits.

I also love his comment to encrypt your devices. How is it possible that hospital organizations haven’t heard this and dealt with it already? The other no brainer is to do a proper HIPAA risk assessment. Meaningful Use has pushed this forward in many organizations. Although, I think it’s fair to say that many haven’t done a “proper” risk assessment.

Other Forms of Overcharging in Hospitals

Posted on 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 13 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.

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.

The Place of EHR in the Hospital IT Ecosystem

Posted on 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 13 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.

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.

Patients Are Only People in Healthcare System Not Paid to Be There

Posted on August 19, 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 13 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.

I was absolutely intrigued by this tweet that was shared at last week’s #HITsm chat.

I’m still chewing on this idea and not sure if this matters and how it matters. I look forward to hearing your thoughts too. Here are a couple things I’m thinking about related to this.

First, the consumerization of healthcare. There really has been a weird dynamic in healthcare where consumers of healthcare (patients) really weren’t the people who were paying for the healthcare. Their employers generally were footing the bill and so patients were mostly interested in their co-payment and not much else since insurance was covering the rest. This has led to some really messed up dynamics when it comes to the cost of healthcare.

One of the trends happening in the industry is the shifting costs from employers to patients. This is largely happening on the backs of high deductible plans. We’re just starting to see the shock that these high deductible plans are having on patients. Once the shock’s been absorbed I think we’ll start seeing a much more proactive patient when it comes to how they choose a doctor and the price they’re willing to pay for medical care.

The second thing that the above tweet brings to mind is the idea of patients not wanting to be in the healthcare system. I’ve written regularly about the need for healthcare to start “Treating Healthy Patients.” That’s a huge shift in mentality from where we are today. Although, I’m hopeful that as ACO’s and value based reimbursement goes into effect, we’ll see a wave of health care that’s focused on outreach to patients who by all accounts are “healthy” or at least feel that way.

What do you think about these two topics? Are there other things we can learn from the perspective provided in the tweet above?

Negative Maintenance Leadership

Posted on August 18, 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 13 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.

It seems like I have a little trend of leadership posts going on. This one goes along the lines of my previous post where I talked about Surpassing Expectations. The next leadership concept that I want to talk about comes from Brad Feld and he calls it Negative Maintenance.

Here’s how Brad describes it from his perspective:

There are days that I’m high maintenance. Everyone is. But if you subscribe to my “give before you get”, or #givefirst, philosophy, you are constantly contributing more than you are consuming. I’ve talked about this often in the context of Startup Communities, but I haven’t really had the right words for this in the context of leadership, management, and employees in a fast growing company.

I think that this description applies just as well to healthcare organizations. We all know the Hospital CIO who takes more than he gives. The hospital CIO that makes a project 10 times harder than it needs to be with the exact same (or sometimes worse) results. Hopefully you’ve also known leadership that makes your life easier. They remove roadblocks. They clearly articulate the path forward. They make the work easier as opposed to harder.

The same applies to anyone on a project team. There are those people on a team that are high maintenance, no maintenance, and negative maintenance. The highest performing teams are those that have a team full of negative maintenance people.

What kind of team member are you?

650 Posts, 500,000 Pageviews and Interesting Search Terms

Posted on August 15, 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 13 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.

It’s an exciting time for Hospital EMR and EHR. We just passed 650 blog posts since we started this hospital IT focused blog back on May 19, 2011. Hard to believe that this blog is already 3 years old. 215 posts a year is a pretty amazing body of work. Plus, we’re approaching nearly half a million pageviews in that time and have 1,198 email subscribers for just this blog (not including the general Healthcare Scene email subscribers). A big thank you to everyone who reads us regularly.

I thought it would also be fun to take a look at the funny, interesting and insightful things that people are searching on Google (and other search engines) that lead them to the site:

epic certification – With 1,625 searches (and thousands of more searches for variations of this term), there is a lot of interesting in becoming Epic certified. Unfortunately, I think that means there are a lot of really unsatisfied people when they find out that there’s no easy way to get Epic certified. I hope this changes.

epic emr – Obviously we’ve written a lot of content about Epic. Although, overall interest in Epic is always high. So, it’s not surprising that many of our readers are interested in reading about Epic.

soarian & soarian emr – At least for this site, Soarian takes the second spot on searches. I think that’s attributed to some great articles that we’ve written on Soarian over the years.

meditech emr – I’m a little surprised that we still don’t have Cener on the list, but Epic, Soarian, and MEDITECH are attracting more searches to this site than Cerner. I guess that means we need to write more content about Cerner.

meditech vs epic – Looks like many people have been searching to see if they should move from MEDITECH to Epic. At least I assume this is the direction they’re considering. Has anyone heard of someone going from Epic to MEDITECH?

epic certification salary – You can understand the interest in these numbers. Although, I’m surprised that Google didn’t send them to this post on Healthcare IT Today about Epic Salaries and Bonuses. Although, that’s for people working at Epic. Maybe I should do a post on Epic certified consultants salaries.

hospital ehr vendors – This search is not surprising since our Hospital EHR vendor page is one of our most popular pages.

ipad security issues – A great topic of discussion that every hospital is dealing with. Apple has come a long way on this issue, but they could still do better. Although, I’m not convinced they’ll ever fully embrace enterprise IT.

closed loop medication administration – We haven’t dug into this topic as much, but we should. I’ll add it to my list of future topics.

An interesting look at what people are searching on Google (albeit biased by the content of this site). Thanks everyone for reading. I look forward to our next 650 blog posts.