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Million dollar price tag to certify - the end of days

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CEOMike Posted: Tue, Aug 17 2010 2:59 PM

 Using the CMS's own data and report a CCHIT EMR will spend between $125,000 to $350,000 in programming costs to be certified (add at least $20,000 for actual certification) An existing EMR not CCHIT certified they predict will spend $175,000 to $700,000 to meet the standards (plus the $20,000.)

Certification has to be done for each year, for three, so a 2011 certification does not guarantee MU certification for 2012.

Self certifying for Open Source are not exempt from requirements so it stands to reason they will have the same expense.

What does this mean:

1. Forget collecting MU with Open Source software.

2. If you are using no CCHIT software it is unlikely the software will be qualified by the vendor.

3. Even fewer EMR vendors will certify than those that did so for CCHIT.

4. Innovation is dead if MU certification becomes generally why an EMR is purchased as this will also set the preception of useability. Vendor design resourcess will go to MU not useability.

5. If MU EMRs fail to get widespread purchase, those EMRs who certify are dead (including some current larger market share ones, as they will undoubtably spend a ton on marketing to maintain their share.) The MU EMRs will also then presummably be left behind by the innovators for useability.  

6. Certifying bodies, especially CCHIT may be in trouble because there will be fewer takers, or they will charge a lot more pushing EMR prices up.

7. Regardless everyone is going to pay a lot more for an EMR making the MU payment mote.

Medscribbler could be certified, we are still evaluating this, because there are a lot of CCHIT EMRs now dead in the water - certification is no guarantee of success - we believe useability is - and how do we balance useablity which will guarantee success with certification which may or may not? 

 

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CEOMike replied on Tue, Aug 17 2010 4:56 PM

I should add an addendum here. The critism when this law was being debated for passage was that it would be unattainable for a large number of innovative and new EMRs. The law provided relief for those small businesses which has been rejected by CMS ONC in the application of the law. The rationale is small vendors can certify as modules, ie document management? The problem here is no one using these "modules" will collect because they will not meet the reporting for collection standard. CCHIT itself reports 75% of EMR vendors are this small business status which will not be able to qualify. Ergo they are accepting 75% of all EMR vendors are "out of the loop" and probably dead as viable vendors, if MU is actually viable in the marketplace.

From Medscribbler's point of view, it means that we are likely the last great innovation. Even the other few EMRs now appearing  with the same kind of innovation we have and  are just beginning to enter the marketplace may be killed by MU. While we can certify and actually anticipated some of the requirements in our design, making certification not as costly to us, the question still comes "Is MU going to be as failed as CCHIT was or worse because it is a full government initiative."

Should we tie our future to a government program and its success or remain independent and keep innovating?

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elidan replied on Tue, Aug 17 2010 10:30 PM

Get certified, Mike.

The new MU certification is very lightweight and in no way interferes with innovation. Actually, it is so lightweight that it doesn't completely guarantee that MU can be achieved.

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Help me understand where the real cost come from in meeting meaningful use for a preexisting well designed EMR.  Most of what I see as requirements from "meaningful use" look like modest improvements to a well designed EMR/EHR - the exception being external interfaces that may be by attestation for some time to come.  I notice NIST publishing test procedures on their web site - looks like a lot of labor saving there. Not being a software person I may be making some faulty assumptions but it does seem that most of what meaningful use calls for is effectively "specialized reporting" that only goes modestly beyond what a well designed EMR/EHR would already provide.  In all fairness government cost estimates often miss the mark so I wouldn't put much confidence in their low or high estimates.  Ok, take two or three representative requirements and explain why they would be more expensive than routine upgrades to field.

Huntsviile Doc Huntsville, AL 35802

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CEOMike replied on Wed, Aug 18 2010 7:53 AM

My concern here is not on whether an EMR can meet the meaningful use requirements, as Medscribbler can and probably will, but on the doctor use. We believe that only an EMR that meets and enhances physician workflows is the only acceptable EMR. If new workflows have to be taught to a doctor we are sceptical of both widespread adoption and whether the EMR is actually an effeciency boost. Medscribbler actually requires little clinical training, few clinical workflow changes, and clerical changes that really only relate to paper to computer changes.

A recent research whitepaper published by CSC Healthcare Group examines the data collection needed to collect MU funds. It assumes a certified EMR is used. What it points out is the MU reporting standards are designed in such a way that the exclusion documentation is about three times greater than the inclusion (my analysis.) What this means is an extention of the documentation by exception that is done now for billing (the normals and "shows no signs" and recording of obvious information every time) is being extended from a single patient care to the care and mangement of the whole roster of patients that a physician has.

The study also points out that third party payers are not going to be long in figuring out the control this will give them.

So the question is if doctors buy a certified EMR, because of the obvious massive change required for the way they practice, will they go "negative"

The recording requirements to collect MU funds will make the changes required in an office to use EMRs look like small potatoes - from a vendor perspective this is good - we will become the relief not the problem. 

The report

 

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CEOMike replied on Wed, Aug 18 2010 8:08 AM

HuntsvilleDoc:
Help me understand where the real cost come from in meeting meaningful use for a preexisting well designed EMR.

It is the documentation required, not the EMR capabilities. For example, the BMI and BP must be calculated and recorded for 80% of all patient encounters for an EP. (and funny the CMS takes a lot of effort to explain they do not care if the EMR calculates BMI correctly !!! )

For a doc, sounds good, the EMR calculates and records. But it is the doctor who must take the the BP, weight and height everytime. You see a 30 year new diabetic once a month, trying to get their DM under control but EVERY time you see them you must record their height, Now an EMR can cheat for you do this automatically (but this extra programming is increasing prices) but this is just "paperwork" for the government. It becomes even more ludicrious when you think that Psyc's are now included for MU but there are no special rules for them. They will have to record BMI and BP everytime they see a patient to collect. 

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elidan replied on Wed, Aug 18 2010 11:23 AM

Mike, docs don't take vitals usually. It's the nurse that does that, and while measuring height for an adult is not always necessary, weight must be measured. BMI is calculated on the fly. You don't need to store it.

As to changes and workflows, I don't see much that needs to change. They don't address the visit note at all in the criteria.

For "a day in the life..." and how meaningful use can fit in seamlessly from a doctor perspective, see my latest writeup here:

http://www.thehealthcareblog.com/the_health_care_blog/2010/08/one-day-in-the-life-of-a-meaningful-user.html

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CEOMike replied on Wed, Aug 18 2010 12:36 PM

Margarlit,

I tried to make it simple with the vitals illustration.

Read the CSC study - it pertains to hospitals but can be extrapolated to solo docs as well.

On reading the final rule on certification you will read that theCMS estimate is it will cost a CCHIT 2008 certified EMR a minimum of half a million dollars and up to $1.5 million by certifying. Those without a program structure equal to CCHIT they estimate at $1.5 on the low end and upto $3.6 mil

On your article, I am a realist - the article is a work of fiction with a "feel good" plot. Yes I immediately went home and hugged my kids and kissed the wife. The reality is who do you think is going to input all this wonderful data that is required for absolute full and wonderful care? Who is going to manage the computers and networks? Who is going to have to figure out all the screen interfaces to have this data.

This is possible but as designed it is for following a government guideline, to produce government data, to get a government payment which by nature is not enough in payment for the report preparation work required.

All this is, MU is the superbill that is applied to a single patient and taken to encompass the whole practice. I have my doubts that EMRs that "document by exception" on the individual patient basis will be any better when they take this documentation by exception design to a practice reporting level.

Marg, you need to read the MU and MU cert law fully and imagine the application of the law in a doctors office.

Also, many other countries and places have tried this with failure as a result. Will the US be better, maybe, but right now I am betting not enough.

Whatever happened to "build a better mousetrap and the world will beat a path to your door" which Emmerson is attributed to have said in support of American ingenuity and innovation. Americans, I'll include myself in this, are known as  the best innovators and  buiders of quality goods in the world. When did we give this responsibilty over to the government to tell us what we needed to do? In my opinion this MU is simply an interference in the market that has stifled innovation and getting a real solution of useability.  

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It's been a very long time since I have made a post here but I was just curious about something.  Forgive me if I have posed this question before but why doesn't the government just give all of the doctors and hospitals EMR's?  Seriously!  How many billions of our tax payer dollars could have been saved if the government just hired a group of talented programmers and doctors to design a system?  I'm guessing an awesome program could have been created for about 2 million.  It just doesn't make sense. 

I too fear the loss of innovative entrepreneurs who will come out with new products.  I developed a small, affordable application called FasterCharts and FasterChartsPhD as a charting tool for health care providers.  There is no way I could ever afford to get any certification.  I am just too small.  There are plenty of people out there that are still buying niche applications like mine but for how long? 

I hope that I can still provide a fast, easy to use software application for health care providers to chart with for years to come.  I suggest translating our software applications to Spanish and start peddling our wares to our neighbors to the south! 

Eric Robinson, DO

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CEOMike replied on Thu, Aug 19 2010 1:38 PM

FasterCharts:
why doesn't the government just give all of the doctors and hospitals EMR's

That is what they are doing but like all good government plans they do not want to take responsibility and want to be able to blame someone other than themselves if (for this one I will say when) it doesn't work out.

"The doctors will be too backward," "the EMRs will be too poorly designed," "the economy hurt the program," etc. etc. But I fully expect one or two hospitals may make it work and then the government will crow, see it works, but "all of the usual suspects" are to blame for poor adoption not us!

Medscribbler's only concern is if the government induced marketing is going to drive sales enough to make the certification aggrevation and cost worth it. Are we going to get 100 to 200 extra sales per year for the next three years over what we do now? Problem is CCHIT promised this and it didn't happen, but simply bankrupted many. Meeting HIPAA promised this and it didn't happen. The E-prescribing incentives promised this and were a total bust - we went to several large CMEs to market this and out of 200 or so doctors spoken to 0 had interest in even the concept of getting a government incentive. There are many more failed programs like this one as examples, both here and abroad.

The bottom line is doctors are not the imbeciles it is the government iniatives that are imbecilic;  often lead by those with good intentions but surrounded by butt coverers, sycophants and the untalented. Again the question is if the boat load of cash enough to overcome the incompetence to actually drive sales?

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gchiu replied on Thu, Aug 19 2010 6:10 PM

Margalit

Your day in the life of is not a fantasy .. my users can do all of that now.

Of course, I'd like to warn them that giving celecoxib to this elderly, overweight,  hypertensive, hyperlipidemic patient may not be a good idea in that all nsaids have a cardiovascular signal ... but maybe in a future version :)

 

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elidan replied on Thu, Aug 19 2010 10:17 PM

gchiu:

Of course, I'd like to warn them that giving celecoxib to this elderly, overweight,  hypertensive, hyperlipidemic patient may not be a good idea in that all nsaids have a cardiovascular signal ... but maybe in a future version :)

"They" were looking for your opinion before "they" decided to prescribe, but you were not online... :-) I hope she survives for the sequel: Meaningful Use - Stage 2

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gchiu replied on Fri, Aug 20 2010 12:43 AM

The "I'd" I was referring to is my Synapse EHR persona !  Cool

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alborg replied on Sat, Aug 21 2010 5:58 PM

>>> For "a day in the life..." and how meaningful use can fit in seamlessly from a doctor perspective, see my latest writeup

Oh, that was really good Margalite! Excellent, and entertaining, but I think that the physician in your article was probably taking Prozac or some other mind altering drug!  Wink Doctors generally hate the concept of MU (my perception on visiting the www.sermo.com site).

Anyhow, I've now written the same article, but seen through my vision of what the typical day in a MU user will be like... it'll be up on the MDNG site on Monday. Here is a tickler:

A Day in the Life of a Physician EHR Meaningful User

 

Ms. Margalit Gur-Arie wrote a recent article chronically a typical day of a MU physician as seen through her technology consultant eyes. (1) As a practicing physician, I'd like to write my own version of a typical day in the life of a future MU Physician:

 

Dr. Welby’s first day as a MU physician meant that things were going to be different. This was going to be his first day at not only using the new $30,000.00 EHR system that has taken 3 months to install and countless hours of training to learn how to use, but it was the day that he would begin using this EHR in a meaningful way, as called on by the recent HITECH Act mandate signed by President Obama last year. Dr. Welby sorely remembers the first attempt at this using an “enterprise” CCHIT certified EHR which took the same amount of time, effort and cost, but ended up in a disastrous deinstallation. These 2 EHR installations may mean that he will have to postpone his retirement farther than 10 years now that most of his savings have been spent on concept of the EHR, and how it is perceived by some to be overall beneficial to our healthcare system... (to be continued)

For the rest of the story... URL is to be posted on Monday once it gets uploaded to the MDNG website! Yes

Al

Al Borges, M.D.

  • Internist/Oncologist in a Small Group Practice in Virginia
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elidan replied on Sat, Aug 21 2010 6:29 PM

Thank you, Al. I am looking forward to reading your version. Reality is probably somewhere in the middle.

alborg:
Doctors generally hate the concept of MU (my perception on visiting the www.sermo.com site).

I think most doctors have no idea what MU really entails. For the right wing Sermo crowd MU equals Obamacare which equals big spending government which equals lefty wealth spreading liberals, and has little to do with medicine.

Frankly, I am a bit surprised that you hang out at Sermo which is nothing more than a zoo where pharmaceutical companies can observe doctors in their natural habitat, research them and experiment on altering their behavior.

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