Practice Wise 6/15/11

What if …?

I don’t like the term disaster recovery. When I try to discuss this with customers or in presentations to practice management groups, nobody likes to think of a disaster striking where they live and work. So they don’t do the work they need to do to prepare a Disaster Recovery plan as part of a Business Continuity Plan.

In light of the past months of natural disasters both near and far, this topic is at the top of mind for many.

A disaster recovery plan is an instrument that documents the actions to be taken before, during, and after a disaster. A disaster is any event that interrupts your routine business operations. The primary objective of disaster recovery planning is to protect the organization in the event that all or parts of its operations and/or computer services are rendered unusable. Good planning should minimize the disruption of operations and ensure some level of organizational stability and an orderly recovery after a disaster.

A well-executed Disaster Recovery Plan should:

• Provide a sense of security
• Minimize risk of delays
• Guarantee the reliability of standby systems
• Provide a standard for testing the plan
• Minimize decision-making during a disaster

Last month I was struck by an image on the news. A few medical practice staff (identified by their cheery scrubs) sifting through the wreckage of their clinic in Joplin, MO, pulling out paper charts and handing them off in an assembly line. I know of another clinic in Joplin who is on EHR that is hosted by an ASP. The doctors were able to fire up their laptops from home and contact all their patients letting them know that the clinic was out of commission and give them instructions for their immediate needs.

This is the most extreme form of disaster, and even the best disaster recovery plans can be thwarted in the face of an act of God. If you have one, it is a step towards restoring normalcy. I was struck that the medical staff were wearing their scrubs, their need to retain a sense of normalcy.

There are daily smaller events that interrupt business continuity. When these smaller events disrupt production, they frustrate staff and patients alike. I prefer to help practices write their “What if ___?” plans. It’s easier to imagine the small business disruptions and build on those for a more comprehensive disaster recovery plan as part of your business continuity plan.

For instance, a practice I was at this week had printer issues on a global level, as if the printer gods were conspiring against them. Nobody could print to any of the four printers in this one doc office, for all different reasons. They didn’t have a “what if” the printers don’t work plan.

Everyone was in a panic. Front desk couldn’t print patient forms that required signatures. Back office couldn’t print prescriptions, chart notes, or lab requisitions. They were taking their angst out on each other. Nobody could see through the “disaster” and find a working solution.

How do we help practices write these plans? It can seem a daunting task when you think about the global issues all at once. I recommend taking a less global, high tech approach and take it back to basics:

1. Create a What If _______, how will I_____? document and distribute it to each person in the practice
2. Have them fill in the blanks for each task that they do for a period of a few days or a week so that all their tasks are adequately captured. It’s important to capture as many tasks as possible, no matter how small, because when the process is broken, the smallest task can become a big issue.
3. Have your internal and/or external IT support people do the same.
4. Have your software vendors do the same.
5. Have your other outside vendors and partners do the same (e.g., your bank — if you scan checks to deposit and the deposit scanner or Web site is down, will they send a courier to pick up your deposit?)
6. The compliance officer (sure we know, all small practices have someone with this title!) or the person who is responsible (practice administrator/manager) for daily operations should compile these documents into a comprehensive business continuity plan. For some, this might be, filing them in a binder and calling it a plan. For others, it will be much more comprehensive. There are many excellent websites that offer free disaster recovery and business continuity plan models.
7. DISTRIBUTE the plan! Make sure everyone in the practice has a copy and an electronic copy is stored somewhere off site that you can access if your practice is down. There’s no point in creating the plan if everyone in the practice does not have immediate access to it.
8. TEST the plan. There’s no point in going to all this effort if you don’t know if the plan will work in the face of a disaster. There’s a reason we had all those fire drills when we were in school!

My husband was on the aircraft carrier Nimitz somewhere out in the vast ocean when there was a deck fire. Now when you are out in the ocean, too far away for anyone to come to your aid, and the planes on deck are on fire and blowing up, you have a life and death disaster at hand. He was asleep when the alarms sounded and said he was dressed and up on deck manning his station before he even knew he was awake.

They had prepared for this type of event over and over again, and groaned and grumbled all the time about the hassle of the training drills. But as they were pushing jets off the deck and fighting fires, he realized that all that their continuous training made their reactions in this crisis automatic, and saved the ship and the many lives aboard.

Hopefully none of us will ever face this type of life and death disaster. The point here is to not make this so daunting a task that you avoid it at all costs. Disruptions small and large are just that – disruptions. They can be not just events that cause anxiety, but also a liability for the practice. We can use all kinds of fancy buzzwords and language around the development of a comprehensive plan, but why not keep is stupid simple (KISS) and get the job done?

Don’t wait for a natural disaster or a Zombie apocalypse to think about disaster recovery and business continuity planning. Every day presents us with what if scenarios that we can easily plan for in advance. Start your What if ___? plan now!

Julie McGovern is CEO of Practice Wise, LLC.

News 6/14/11

The ONC names the American National Standards Institute (ANSI) the sole authorized accreditor for EHRs under the permanent certification program.  The temporary program will be sunset at the end of 2011.

The American College of Clinical Information Managers launches itself as a non-profit accreditation organization for medical scribes. The certification process includes testing, proof of employment as a scribe, and a $250 fee, which will be waived through the end of this year. I am not sure if certification will make much difference for scribes working in physician offices, but at least the fee seems reasonable.

The 20-physician River Falls Medical Clinic (WI) attests for Medicare incentive funds for its meaningful use of Cerner’s EHR. The clinic’s medical director says that 70% of the physicians in his area are also on EHRs.

Vermont IT Leaders, the REC for Vermont, announces that 750 primary care providers have signed up to receive EMR adoption assistance. That’s about 75% of all of Vermont’s primary care providers.

The Louisiana HIT Resource Center names SuccessEHS a supported vendor for its REC.

Less than one-third of physicians are expected to remain independent by 2013 as they continue to sell their private practices to healthcare systems. The attraction of larger health systems include greater access to leading edge HIT, facilities, and equipment; a more manageable work schedule; and increased financial stability.

Steven T. Plochocki, CEO of NextGen’s parent company Quality Systems, is named Outstanding Technology CEO in TechAmerica’s 18th Annual High-Tech Innovation Awards.

MedeAnalytics releases a report that summarizes the public comments on the ACO proposed rule. The bottom line from seven national healthcare constituencies, including the AMA, AMGA, and MGMA:

• The ACO program, as proposed, needs revision, not repeal.
• The 65 quality measures in the proposed rule need to be reduced, perhaps to 32, and should include a phase-in period.
• Financial terms need to be more attractive with a standard, minimum savings rate and the elimination of the withhold.
• CMS needs to create a separate model without downside risk.

E-mail Inga.

DOCtalk by Dr. Gregg 6/10/11

HIGH Tech Support

Ohio Medicaid went live last week with their HITECH EHR incentive program, MPIP. Signup availability was announced on the morning of June 1 and I happened to be sitting there when the e-mail came through. So, as I had already done the preliminary stuff at the federal level (which was itself a pretty easy process, I should add), I went straight away to the MPIP link to get on board.

The site was laid out pretty well overall. The process of signing up seemed easy enough. I already had the basic info: identifiers for me, my EHR, and my aforementioned recently-created CMS account. I needed to generate some figures for total number of patients seen during my chosen three-month reporting period, plus determine the number of those patients who were Medicaid insured. Not too hard to gather.

Once I had those numbers generated (and after I had a good, long cry about the fact that my percentage of Medicaid during that chosen period as a walloping 48% !!!) I finished out the process following all the “fill in here” slots and “you are required to do this” red asterisks. When completed, I submitted it … and it went through!!!

Oh,no … wait. Though I did have all four progress areas turn green with a “Completed” check mark, the end summary said I was still “In Progress.” Does that mean it’s “in progress” on their end, or that I still have some unfinished piece of info yet to addend? It wasn’t clear.

I went to their Help section and FAQs, which were actually just links to PDFs. I tried, but my ADHD wouldn’t let me go too long within the many, many pages of their PDF “help” tool.

I could wait, but if it was something on my end, that’d mean unnecessarily delaying my Incentive check. With my 48% Medicaid, you can easily understand why I might need that check sooner rather than later.

I decided to call the support line listed on the MPIP web site. Not unsurprisingly, they were a little busy and weren’t able to take my call right then. I left a voice mail and figured it may take a day or three to hear back. Patients were beckoning, so I left it there.

Later in the day, it crossed my mind that as a member of the board of directors of OHIP (Ohio’s HIE/REC), maybe I should notify some of the important folks there who may want to let folks at MPIP know there might be some glitches worth addressing. I mean, if it wasn’t apparent to me, and I have a bit of an inside track on all this, then I bet others might also find the process a little unclear. So, I e-mailed and/or called a couple of the good folks at OHIP who seemed to appreciate the insights.

A little surprisingly, late in the afternoon I received a call back from MPIP support. A wonderful fellow, Aaron, said they had indeed been busy that day, but he nonetheless took time and listened to each of my concerns or problems. We walked through the process together, I showed him where it appeared confusing to me, and he made notes. I told him I couldn’t tell if I was complete on my end and he assured me I couldn’t be, as they did not yet have anyone in the pipeline for payment.

I told him about the one non-asterisked item I had not submitted since it didn’t appear required. He said, “Let’s try it,” and … VOILA! My submission then popped up on their end as “ready for payment”! WOO HOO!

I hadn’t mentioned to Aaron that I was on the OHIP board until well into our conversation and he had not received any word from any of the OHIP folks I had contacted. Thus, his kind and helpful demeanor was unpretentious and un-persuaded. Ya’ gotta love that in IT support.

Then, within two days of the MPIP help desk call, I had the fun of spending hours and hours with the support folks at two large vendors of wireless routers and the support folks at my ISP vendor, a giant in — or should I say AT? — the telecommunications world. From these three technology firms, I received only attitude, runaround, and resolutionless aggravation.

Tech support calls often a feel like connecting with soulless, uncaring seat-fillers who would rather be somewhere else doing something, anything, else, especially if you have no established relationship with them. But, not always. Not with Aaron at MPIP. He’s high end, HITECH support. I thought he deserved a mention.

Thanks, Aaron. Keep it up.

From the trenches…

“There are no traffic jams along the extra mile.” – Roger Staubach

Dr. Gregg Alexander, a grunt in the trenches pediatrician at Madison Pediatrics, is Chief Medical Officer for Health Nuts Media, directs the Pediatric Office of the Future exhibit for the American Academy of Pediatrics, and sits on the board of directors of the Ohio Health Information Partnership (OHIP).

News 6/9/11

The HIT Policy Committee advises ONC to push back the Stage 2 deadline for Meaningful Use to 2014 for providers who qualified for Stage 1 this year. The committee believes the original timeframe does not give providers or vendors adequate time to prepare for Stage 2, especially since the final Stage 2 rules will not be released until June 2, 2012. The proposed change would allow providers to collect Stage 1 and 2 incentive payments for two years without penalizing early Stage 1 adopters with a tight Stage 2 deadline.

Shareable Ink partners with Waiting Room Solutions to combine its digital pen technology with the EHR from Waiting Room Solutions.

Spring Hill Primary Care (WV) contracts with Sage Healthcare Division for the Intergy Meaningful Use Edition.

Initivia will extend special pricing for its InSync EMR/PM product to members of Premier Purchasing Partners, a group purchasing organization.

The Louisiana Care Quality Forum REC designates Greenway’s PrimeSUITE EHR as a supported EHR product.

CRISP, the REC for Maryland, meets its subscription goal with the enrollment of 1,000 primary care physicians.

CMS adds a few questions to its FAQ page on the EHR incentive program. Here are a couple of the better ones:

What information must an EP provide in order to meet the measure of the meaningful use objective for "provide patients with an electronic copy of their health information?”

The minimum required information includes a problem list, diagnostic test results, medication list, and medication allergy list. CMS also notes the four elements must be provided to patients within three business days  of their request.

For the Medicare and Medicaid EHR Incentive Programs, when a patient is only seen by a member of the EP’s clinical staff during the EHR reporting period and not by the EP themselves, do those patients count in the EP’s denominator?

The EP can include or not include those patients in their denominator at their discretion as long as the decision applies universally to all patients for the entire EHR reporting period and the EP is consistent across meaningful use measures. In cases where a member of the EP’s clinical staff is eligible for the Medicaid EHR incentive in their own right (NPs and certain PAs), patients seen by NPs or PAs under the EP’s supervision can be counted by both the NP or PA and the supervising EP as long as the policy is consistent for the entire EHR reporting period.

E-mail Inga.

News 6/7/11

Merge Healthcare acquires Ophthalmic Imaging Systems (OIS) for approximately $30.3 million in stock. OIS’s products include OIS EMR and PM, as well as EMR and PM products through its Abraxas Medical Solutions subsidiary.

EMR costs make adoption difficult for small practices, even with incentives. That was the general consensus of several speakers who testified last week for the House Small Business Committee’s healthcare and technology subcommittee. Sasha Kramer MD, a solo dermatologist from Washington state, summarized the situation nicely:

HIT holds promise as a tool to increase quality and efficiency in the health system. However, there are significant barriers to full-scale adoption and implementation of HIT – specifically, cost, regulatory barriers, financial penalties, an unpredictable marketplace and system integration. It is imperative that Congress ensure small physician practices are able to make the investment in technology that will enable the American healthcare delivery system to coordinate care and make a measurable impact on quality without imposing overly burdensome procedures or failed financial investments upon physician practices.

Meanwhile, AHRQ announces plans to conduct a two-year, $425,000 study of the barriers Medicaid providers encounter in trying to achieve Meaningful Use. Note to AHRQ: save some money and see above because I bet the issues are basically the same.

Boston Laser implements Sage Portal for online appointment scheduling, registration, and messaging.

RIS/PACS provider DR Systems announces plans to release a fully certified ambulatory EHR for imaging specialists later this year.

The AMA names James L. Madara, MD as EVP and CEO. He served as dean at the University of Chicago Pritzker School of Medicine and as CEO of the University of Chicago Medical Center.

Practice Fusion earns full ONC-ATCB certification.

Adena Health System (OH) picks eClinicalWorks EHR for its 150 employed physicians, as well as non-affiliated community practices.

Ingenix says its transition to its new name, OptumInsight, is complete.

Consulting and implementation services firm MD Solutions partners with dashboardMD to enhance its analytics reporting offerings.

Every so often I am reminded how expensive EMRs can be and that EMR can be big business. Case in point: the 15-provider Great Hudson Valley Family Health Center (NY) recently completed a $1 million implementation of GE Centricity. The practice claims that $500,000 was related to training costs. The FQHC includes 11 physicians and four NP/PAs, so the total cost was about $67K per (primary care) provider.

e-MDs says that 21 of its provider clients in Texas have already received Medicaid EHR incentive checks.

Danbury Orthopedic Associates (CT) selects SRS EHR for its 20 provider practice.

CMS issues a proposed rule allowing certain qualified organizations access to patient-protected Medicare data on providers and hospitals. The intent would be for the qualified entities to combine the Medicare data with information from private carriers to evaluate provider performance, and presumably help consumers and employers make better healthcare decisions.

CMS releases a list of providers who have received Medicare EHR Incentive payments. If I were a provider, I am not sure I’d love having this information available for the world to view, even if the money does come from taxpayers.

IPAs may make a resurgence as doctors look for ways to unite with larger systems for the purpose of forming ACOs. The IPA model lost favor about 10 years ago and in many cases became financially unviable. IPAs may be a better solution today, as providers consider options for sharing savings and risk and collecting quality metrics on specific populations. I’ve always known that healthcare and fashion had many similarities. In honor of the returning IPA, I think I will pull out my stone-washed jeans.

E-mail Inga.