Clinical documentation, EMR and Medical billing

Complete and accurate clinical documentation can guarantee maximum reimbursements to healthcare service providers. Prior to electronic medical record (EMR) systems, clinical documentation was fallible due to many reasons, such as, incomplete information, wrong billing codes, unauthorized or wrong procedure quoted etc. However, the integration of clinical documentation and medical billing on EMR applications has streamlined it to a near perfection.

Completeness of data entered

Thanks to computerized physician order entry (CPOE) system that runs now as part of EMR applications. The system has significantly decreased the errors related to bad handwriting and it checks for incorrect and incomplete entries. EMR systems are capable of alerting the data entry operator if a field is left blank by mistake which is pertinent information. With that capability, errors and omissions are avoided at the very beginning. Clinical documentation on EMRs, comprehensively cover patient’s data, such as, personal information, reason for encounter, history of disease, etc., followed by diagnostic test results assessment and plan for care.

Accurate CPT/ICD coding

To claim a medical bill, physicians are required to encode in numbers the procedures followed for diagnosis and treatment of patients and ICD codes for the disease identification. Until now, it was difficult to transcribe accurate CPT/ICD codes and usually the task was outsourced to professional medical billing companies. The EMR systems have automated this coding process which not only contributes to cost savings, but also brings precision to clinical documentation. This consistency in data ultimately ensures settlements without objections by the payers.

Editable electronic copies of medical records

Clinical documents managed through an EMR system are easier to access and edit unlike health records on papers. Correcting a mistake on paper would involve many legal complicacies and adding new information or editing existing was impossible. EMR systems have provided flexibility to documentation handling; one can always edit or amend health records and can send it electronically in HL7 Clinical Document Architecture (CDA) standard format.

Accuracy in clinical documentation achieved through EMR systems has fine-tuned the medical coding and billing process. Alongside, it has alleviated standards of clinical care, bettered data flow across healthcare service providers and improved reimbursements.

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How patient portals are reducing health care spending

Curtailing the cost of health care services is regarded as one of the major stimuli behind the healthcare reform. However, the health reform bill established in 2009 gave a new direction to this transformation of healthcare system, changing it more than merely digitizing health records. The proposed reforms went on to connect all the isolated health record management systems together, exciting a bundle of innovations and startups and public programs.

Patient Portal is one such solution which is meant to weave together the network of health care service providers. The Meaningful Use program prioritized patient portals by making it a must have feature within EMR and EHR systems. The combination of a digital health record management system and a Patient Portal can set physicians and patients free from conventional modes of communication, shifting them to a whole new level of mutual interaction. Integrating patient portals into practices has been fruitful in reducing cost and improving efficiency and in some cases Patient Portals are outperforming Meaningful Use requirements. Below we’ll delve deeper into how this has been made possible.

  • Saving on telephone-based communication cost

    Physicians and patients used telephones to schedule appointments, for instant advice, disease follow-ups, and / or monitoring effects of treatment. As the volume and affiliated cost of telephone-based communication between a physician and patients increased, practices looked for newer and cost-effective communication technologies. An integrated Patient Portal and EMR system eventually substituted that particular pattern of communication. Physicians now can handle appointment requests through integrated Patient Portals and share comments and health records via this tool as well.

  • Consultation via Patient Portal reduces frequency of clinical visits

    Although, working parameters of virtual care and telemedicine are still in evolution, there are benefits coming into the lime light. Patient Portals have provided the tools to provide instant advice to patients without having to visit the doctor’s office. It is of significant importance especially in a scenario when patients require multiple visits for a treatment and follow-ups.

  • More productive clinical visits and workflow

    By logging in to personalized pages of a Patient Portal, patients share rudimentary information with the physician helping them to predetermine the purpose of the visit and a brief note on symptoms of their illness or disease. It saves a lot of time on clinical visits, positively effecting productivity, saving travel expense and improving turnover.

  • Care coordination saves spending on data entry

    Through an integrated Patient Portal, patients contribute their time and effort in managing their health records. They enter basic information by filling in online forms at their leisure, saving data entry cost for the physician and saving cost of extra resources required for the task.

  • Sharing of health information through a Patient Portal saves on printing and postal costs

    Health records, such as laboratory test reports and other documents required to be shared with the patient can be provided through an integrated EHR and Patient Portal, which saves on printing and courier costs.

  • Electronic payments are managed through Patient Portals

    Online portals are quite a convenience now to manage bills and payments. Healthcare service providers can process it online through integrated Patient Portals. Patients can pay their medical bills, either current or outstanding, which helps to bring down the cost of payment follow-ups.

Get a complete view of the benefits by visiting SequelMed Patient Portal page or read about it on the blog.

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Key variables in the EHR implementation process

Why is it called a process? The deployment of an electronic health record system is like building an edifice of bricks as the foundation has to be laid according to the users specifications. Good training and support provided by the EHR software vendor can speed up the adoption phase. It is of key importance to simplify the complex learning processes by helping users taking their first steps by answering their queries and removing barriers that may arise coming on the way.

EHR implementation is a two way street in that first the user makes changes to the system to accommodate their needs – then the system steadily changes the user’s daily processes. It can be hard to switch from a long-established practice of working on paper performing most of the clinical procedures manually and then adopting a fully computerized workflow. Broadly speaking, there are three forces at work – the integration of each force is necessary to make the EHR function smoothly. First among the forces is resource development where the staff is involved and roles models are set. The second aspect is dealing with technical issues such as the hardware, software, networking etc. Last, but not least are regulators of the system who ensure that standards and requirements are met, which is crucial for the successful adoption of an EHR system.

Prepare for the adoption, Gear up staff & Manage expectations

Having a good strategy to start the EHR implementation process should be first and foremost. Management should draw a plan of action to achieve a phased transition from a paper-based office to an EHR.

  •  Staff involvement: It is a must at every phase of the EHR implementation to ensure that the entire staff is involved. Even in the filtering of vendors, management should take everyone into consideration and provide a detailed explanation explicitly regarding the process and the need to shift to an EHR system. Providing the capabilities of the electronic system as well as the benefits attached will help ensure the staffs buy in.
  • Task allocations: Implementation of an electronic health record system requires overhauling at every level of a health care organization. The practice should define the roles and divide tasks at the very beginning which will set the direction and roadmap to a successful implementation.
  • Setting goals and timelines: A phased implementation process should begin with realistic goals and timelines. There should be periodic meetings to discuss issues and share progress in turn creating a team work environment.
  • Training and resource development: For account managers at SequelMed, training the users on EHR technology is of utmost importance. Trainers gather information about the practice such as management style and workflow at the facility. Then, best practices or methodologies are recommended and dashboards are customized according to the needs of the provider and individual users. Each training phase is divided into multiple sessions. Account managers monitor the progress of the staff in each session before moving on to next phase.
  • Managing and influencing expectations: When the team starts working in a specific direction, then everyone is expecting the proclaimed benefits of the new system. It is very important to manage the expectations of the staff, for instance, if someone puts in extra effort while working through the electronic system implementation, the account manager should make them realize that the efficacy in their work will come with the passage of time. Otherwise, the user will feel reluctant and psychological barriers will kick in during the learning phase. In most of the cases cognitive learning is effective when users learn from early adopters or role models.

Deal with the technical side of the implementation, Upgrade hardware to fulfill the requirements of the software & Manage prerequisites

  • Hardware and network needs: EHR systems are designed to work in a collaborative style. Data entry operators at the front desk register the patient by entering all the basic information into the system. This information helps track the patient across the facility and is used for diagnosis and medication. Ensuring that other parties within the practice can access a patient’s information which requires a network of computers and devices that are compatible with the software connected to each other.
  • Scanning of papers: One of the primary prerequisites of a freshly deployed EHR system is converting already archived data and health records on paper into a digital format. This might require extra hours at the office in the beginning. However, to speed up the process, there are smart scanners now available which can scan documents and index them with greater speed or third party solution providers can execute the task for you.
  • Servers and storage devices: It varies with each vendors and the EHR solution offered. If a practice chose to maintain its own server to host the data, it in turn requires advanced machines and skilled IT personnel to manage them. Similarly, digital archiving of the health records requires a range of storage devices.
  • Support and maintenance: For an EHR application to run smoothly, an updated system is required as well as skilled IT personnel to maintain it. For instance, if there are any changes in medical coding or an update in regulations which may require system upgrade, it should precede deadlines.

Evaluate readiness, Security checks, Go Live & Meaningful Use attestation

  • Security of digital records: Incidents of health data breaches are constantly knocking the adopter of EHR technology off the road. Before going live, management should ensure that all the security measures have been followed. Data should be encrypted before sharing and a proper firewall and antivirus should be installed to bar outside intrusions. For this purpose, The Health Insurance Portability and Accountability Act (HIPAA), is regularly formulating rules and regulations which includes their latest rule; a version updated of 4010 to 5010.
  • Meaningful Use criteria: Meeting measures and objectives established by CMS’ Meaningful Use program is a must to demonstrate meaningful use of certified EHR technology. The criteria ensure that the EHR system offers the technological capabilities and that all the necessary features have been incorporated. The successful demonstration of meaningful use of EHR technology makes healthcare providers eligible for monetary incentives offered by CMS.
  • Internal testing and going Live: It is not recommended in any scenario to use an EHR system without confirming its stability in test mode. Prior to going live, the EHR application should be tested internally and any issues and problems appearing at this phase should be handled in a way that it may not occur in future. Working in test mode helps the users to learn and understand the EHR system in lifelike situations and they feel confident when practicing it in actual.

     

Perusal of these key variables provides only some of the necessary tips for the EHR implementation process. For a detailed perspective and technical insight contact us with your queries.

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Top Reasons for Implementing EHR System

The EHR technology is grabbing the wild fascination of everyone in the healthcare industry. Although the early purpose of utilizing information technology in healthcare was to mend deficiencies in the paper-based system, improve quality and to make healthcare more affordable. However, the digital system is opening up new venues for innovation and creativity as well.

Healthcare providers are implementing EHR systems in growing numbers because of the increasing benefits attached with it. In addition to monetary incentives, providers are taking into consideration a few most acclaimed benefits of EHRs, such as, health records become universally accessible, connecting providers to pharmacies and labs which in turn lend to the flexibility of the practice. A study published by Medical Economics narrowed down the top two reasons for implementing an electronic health record (EHR) system which indicate other factors encouraging the EHR implementation.

Here are the top two reasons prompting EHR implementation:

“To achieve meaningful use”

  • 95% of the EHR Study’s participating physicians regarded the meaningful use program as their primary motivation.

“To improve patients’ quality of care”

  • 53% of the doctors polled adopted an EHR system to improve the quality of care of their patients.

Besides this poll, there are a few more reasons which I think should fall in the top five

Peer pressure: Health care providers cannot work in isolation. In a highly competitive industry they need their facility equipped with the latest technologies which their competitors already have. Therefore, healthcare service providers opt for an EHR system when everyone around them has implemented one.

To improve returns: EHR systems are designed to manage finances as well. The system automates medical billing procedures, offering greater control over financial management and payment tracking. These extended capabilities of EHR systems have attracted a large number of adopters of this technology.

Reduced errors and omissions: Computer assisted ICD and CPT coding achieved through EHR systems leaves little room for errors and omissions in medical billing. Similarly, the benefits of clinical decision support system (CDSS) embedded in EHRs keep a check on malpractice. The aforementioned are great tools that serve as attractive qualities for the adopters of EHR software.

Cost effective: Automation of clinical processes requires fewer resources to manage daily operations of a health care facility. EHR systems require fewer resources to manage patient proceedings from registration to medication which makes it cost effective.

Until now, government lead programs and incentives are serving as the stimulus to implement EHRs, but the value this technology brings, will soon influence health care providers to adopt it for more a myriad of valid reasons.

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Switching EMR and EHR – What are the reasons behind

An interesting fact that early adopters of EMR and EHR software are now switching vendors or service providers for another electronic medical system. Decision to switch from one platform of EMR and EHR to another service provider invokes almost double the pain gone through on shifting from paper-based medical system to electronic system. It is even more complicated when you have been using a XYZ electronic medical system for quite a reasonable time now and you decide to shift to another system on the pretext of wanting better capabilities. In the switching process, all your records and patients’ information is structured and indexed with the current system and if you are using a cloud based or web based EHR, you don’t know where on earth those electronic records exist, how to retrieve them and make useable with the new electronic medical system. Either you have to print them out all on papers and have to start over again or with the advice of the new service provider, all the records have to be transformed in convertible digital formats (XML, CCD etc.)

Regardless of difficulties involved, health care service providers are switching one EMR/EHR application for another system for a few valid reasons.

  • Not satisfied with the current EMR system. Obviously dissatisfaction with the current system may lead to discard a running system. The system may not be fulfilling requirements of the practice due to multiple reasons.
    • Poor customer service and technical support by the vendor in down times, support team cannot answer properly on calling and technical issues waste a lot of time and appear in greater frequency.
    • The EMR system is difficult to operate either because the interface is not user friendly or due to the absence of proper training.
    • The EMR system lacks specialty features and templates required because it was not customized for that specific medical specialty.
    • The design does not match the workflow of the practice and is not flexible either. It happens especially in a case when staff was not consulted in the selection process.
  • Meaningful Use program has been pronounced as one of the major reasons behind switching EMR/EHR systems. Meaningful Use is raising the bar day by day, demanding new requirements to be included as part of the electronic medical systems, meeting which is required by CMS to receive incentive payments. Meaningful Use criteria requires users of EHRs to demonstrate certain objectives and measures using certified technology, just as
    • Meet clinical quality measures
    • Electronic prescription capability
    • Patient interaction
    • Health information exchange meeting HIPAA requirements
    • Online access of the patients to their health information etc.

    Meaningful Use program has promulgated a lot of software features required to meet at different levels of attestation. Meeting these indispensible requirements need a continuous upgrade in the EHR systems which is very difficult to keep pace with and health IT companies remain consistently engaged and when they do not fulfill clients’ requirements they switch to better systems.

  • The vendor is charging extra ordinarily for every set of new features or up gradation. Unlike other vendors, SequelMed has been phenomenal in this regard, it charges no fee on system upgrade or does not charge later on the expenses which were kept hidden at the time of implementation.
  • There are conflicts in integration or synchronization of the EMR software with other applications.
  • Hardware changes at the facility also lead to conflicts and users make a switch to compatible EMR software. For instance, the EMR system previously installed was designed for desktop computers and hardware upgrade to tablets required touch screen interface, in such assumed situations, EMR users opt to switch.

Sometimes EMR and EHR vendors discontinue support either because they were acquired by another company or they simply went out of the business. It is also one of the many reasons that EMR users make a switch to another vendor.

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Taking Control of Finances through Electronic Medical Billing System

Harnessing the complexities of medical billing and management of revenues is what tends to trouble health care providers in many ways. Although medical billing companies have been providing solutions; sparing health care providers from this cumbersome task of managing bills and following up on payments. Profits have been marginalized due to deficiencies in the system, unpaid bills or delayed payments and sometimes nonpayment due to objections made by the payers.

In most cases, objections were made on an unauthorized services billed or incorrectly transcribed ICD/CPT codes. These objections and recurring follow-ups for payment used to consume a great amount of time of health care service providers and they tended to give up all hopes of getting paid. However, electronic medical record (EMR) and electronic health record (EHR) systems have solved this dilemma for physicians and health care service providers by automating billing processes, as well as, by eliminating deficiencies in the billing process.

Let’s take a look at some of the factors which contribute to the success of an electronic medical billing system.

  • HIPAA-endorsed electronic transaction standards:
    HIPAA has developed a set of guidelines and standards for electronic transactions to eliminate deficiencies in the system. As discussed in a previous post on the correlation of HIPAA standards and medical billing, the enforcements have been instrumental in bridging the gaps and unifying the system to universal standards. By complying with HIPAA standards, claim submission and processing for payment is quicker and easy to track. Chances of payment denial or claim rejection have been reduced through the precision in claim handling. Details about claim processing are more transparent and payment status is easier to track electronically.
  • Pre-authorization of service: Through the electronic billing system embedded in EMRs and EHRs, it is much easier to check eligibility of the patients and get preauthorization from the payer to perform a medical service. Distinguishing between primary or secondary insurance carriers is easier and leaves no possibility of sending the bills to the wrong payer.
  • Accuracy of diagnostic and procedural coding: Electronic billing systems have automated the coding process. Physicians just need to click in the pre-designed templates and the electronic medical record system automatically imprints the corresponding code for the service. The medical bills are then submitted electronically to the relevant payer. It is also now much easier to add fresh codes for new diseases or upgrading to a new set of codes.
  • Electronic tracking and updates of payments: Status of the payments gets updated instantaneously and providers can check it in real-time. Electronic payment system is more efficient and situations like co-pay are easier to manage. Integration of online payment solutions has made the billing process a lot better than before.

Electronic medical systems have given new dimension to medical billing. By streamlining the processes of medical billing, it has granted a more than 90% success ratio on returns which is much higher in comparison to conventional practices of sending bills on paper or outsourcing the task to third parties and the ratio of successful reimbursements used to loom around 30% to 40%. Health care providers are now in better control of their finances due to an efficient electronic billing system.

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Meaningful Use Webinar: Stage 1 Requirements, Registration and Attestation

SequelMed holds online webinars and training sessions on a regular basis in order to keep clients updated on achieving Meaningful Use. Recently, SequelMed held two webinars which which were intended to offer necessary education & training in addition to clearing any confusions regarding Meaningful Use. The first webinar, held on March 29th, focused on MU Stage 1 requirements, registration, attestation and how SequelMed can assist you during the process.

For that webinar, Chris Klemballa (Product Specialist) was joined by Regina Sixon and Amanda Scanlan (In-house Meaningful Use experts), to elaborate on the step by step process and what kind of help you can expect from SequelMed. The recorded webinar video is now available:

Highlights

Here are some of highlights of the webinar:

Differentiating the types of incentive programs

  • EHR Incentive Program (MU)
  • eRx Incentive Program
  • Physician Quality Reporting System (PQRS)

Difference between Medicare and Medicaid Incentive Program

If an Eligible Professionals (EPs) Medicaid patient volume is above 30%, the EP is eligible for the Medicaid incentive program. It should be noted that the reimbursement rate is greater for Medicaid.

If an Eligible Professional’s Medicaid patient volume is below 30%, and they also see Medicare patients, the EP would be eligible for the Medicare incentive program. There are no patient volume requirements for Medicare. However, the EP would be entitled to reimbursment @ 75% of their annual Part B Medicare charges.

Certified EHRs are capable of achieving all measures put forth by CMS to achieve Meaningful Use.

Experiencing Meaningful Use Outcomes

What can SequelMed provide to assist during the process?

For Medicare:

  • SequelMed meets all 15 core and 10 menu set measures. Which of the 10 menu set measures you are going to achieve depends on your practice, specialty and the type of patients you see.
  • SequelMed meets all 44 Clinical Quality Measures (CQM).
  • To check where you stand in terms of Meaningful Use compliance, SequelMed has embedded MU and PQRI reports right into the EHR software for you to be able to see where your practice stands. You can review reports and enter appropriate data on CMS’ website at time of attestation.
  • MU Training is embedded right into the EHR training structure.
  • SequelMed also provides Meaningful Use training manual, a step by step guide on what to do to achieve MU.
  • Support during MU registration and attestation process.

For Medicaid

  • Support in registration
  • Information on stake links for attestation

SequelMed provides assistance to clients to ensure that they are knowledgeable about utilizing their certified system in a meaningful way.

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6 Reasons to choose a customizable specialty EMR

Customization of an EMR system means designing a workflow loaded with features and templates that should fulfill all the needs and requirements of a specific specialty. EMR systems should be flexible enough to accommodate the existing and immediate needs of a medical specialty.

Most EMR systems are developed in ways that can handle workflow of a general practitioner rather than a specific specialty. Those systems lack the sophistication necessary to work intuitively in specialized medical fields. A comprehensive set of templates designed specifically for a specialty improves efficiency and ensures accuracy of clinical decisions. EMR software intelligently interacts with a huge library of health information, absence of which would increase workload when everything has to be documented from scratch. Below are reasons that pertain to the advantages, a customizable specialty EMR system have over a generic system.

Reason 1: A preloaded specialty EMR takes less time to implement and adopt. It is usually operational at the minimum required level from day one.

Reason 2:  A custom designed specialty EMR comes with the library of required forms and templates which helps the user to focus on quality of care rather than writing templates.

Reason 3: EMR vendors consult specialty physicians to create a library of templates with structured data providing proper quality assurance leaving no room for errors and omissions. When it comes to getting a generalized EMR system to work properly, it can take up to one month and the burden of creating templates lies on the shoulder of the user which can heighten the chances of errors, causing further frustration. This is one of the top reasons that link to the failure of EMR adoption.

Reason 4: A specialty EMR is designed according to the workflow of a particular practice.  Work panels are adjusted according to the priorities of that specific practice. For instance, a Cardiologist requires panels displaying ECG, Vitals, etc. on the main screen while a Chiropractor requires a high resolution display of X-Ray and MRI reports. Both specialties would need different panels on their screens, along with a different set of ICD/CPT codes and drug database.

Reason 5: A general EMR system comes loaded with all types of features and functionalities whether a user needs it or not. All those generic tools simply distract a user’s attention and hamper their efficient workflow practices. On the flip side, a specialty EMR is customized to show only the features and options which are required by the specialty.

Reason 6: An EMR system customized for a specialty helps to improve efficiency through the precision of medical decisions. It expedites the revenue cycle in turn providing a greater ratio of return on investment.

SequelMed’s EMR holds an extensive library of specialty-based templates, custom designed to fulfill the unique needs of the each specialty. A comprehensive library of templates have been designed and evolved over time through the direct advice of the medical consultants serving in each specialty. The result is a fully customizable EMR system that a medical specialist can efficiently operate from day-one at its full potential.

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5 Ways Meaningful Use is changing the health care scene

The Meaningful Use program is changing the health care scene by bringing in fantastic technologies, turning paper charts into useful digital archives of health information. This program is paving the path for the adoption of the most advanced health care system in the United States yet. Realizing its impact, CMS is using Meaningful Use program similar to that infamous magic wand in the movie, Cinderella. The implementation of CMS’ ‘magic wand’ will change everything as desired. I remember the part when with a flick of the fairy godmother’s magic wand; Cinderella transforms into a princess in the most beautiful dress, a nearby pumpkin morphs into a sparkling coach, mice shape-shift into six white horses and instantly Cinderella is ready for the ball.

Besides from this humorous reference, the Meaningful Use incentive program has been successful in attracting almost more than half of the health care providers since its inception, who are registering with CMS in growing numbers to demonstrate that they have met Meaningful Use criteria using certified EHR technology. The Meaningful Use incentive program is not just about complying with a set of standards to get incentive payments; it has been established to change the health care system from top to bottom through enforcing the adoption of innovative technology solutions and by closing loopholes in medical practice.

1. Adoption of Health Information Technologies has been spurred by the MU incentive program
Adoption of Health Information Technology (IT) has increased tremendously since the Meaningful Use program incentivized the implementation of electronic health record (EHR) systems. Incorporating EHRs in physician practice changes the workflow at every level. It has brought to work the better use of computerized physician order entry (CPOE) system, digitized patients’ health information and records, accelerated clinical processes and has improved physicians’ efficiency.

2. Improved care coordination through interoperability of health information
The Meaningful Use program’s objectives and measures encourage the exchange of health information to improve care coordination. Patients can access their health information electronically (including lab results, problem list, medication lists, and allergies) and take an active part in the decisions related to their health. It is now possible to consult multiple specialties by giving everyone the access to a shared health record directory. A physician can refer a patient to another physician and can treat patients during emergencies with updated ambulatory information and case history.

3. Different Health Care IT solutions linked together to make one whole solution
Innovative Health Care IT solutions have evolved over the years. For instance, CPOE, eRx,
patient portals, electronic tracking of health records, digital imaging of lab test reports and advanced practice management tools are combined together in a way that these solutions can interact with each other. Most of these featured technologies are now available in one integrated EHR system. Integration of these Health Care IT tools has opened up new possibilities, such as the required practice of drug-drug and drug-allergy interaction checks, updated record of demographics and vital signs, medication reconciliation and history trails needed for Meaningful Use.

4. Use of artificial intelligence in clinical settings
Clinical decision support system (CDSS) is something which shadows the person involved in the care process at every step of their EHR use. It ensures quality of care through alerting on a missed precautionary measure or a wrong step taken, and intuitively guides to a best suited decision in given settings. This is the reason CDSS has been placed among the core objectives of the Meaningful Use criteria.

5. Electronic transactions has reduced cost and increased returns
Errors in medical billing used to deprive health care providers from a major portion of their legitimate earnings. Electronic medical billing and coding has streamlined the process by eliminating coding errors and proactively submitting bills within the time specified. Electronic tracking of bills keeps health care service providers informed of the payment status. It has remarkably reduced the cost of payment management and reduced the possibilities of payment denial because electronic preauthorization of a service leaves no reason for objections. Similarly, the Meaningful Use program enforces use of EHR technology that should meet HL7 transaction standards which is ensuring safer care at lower costs.

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Implications of deciding payment year for EPs who switch incentive programs and skip years

Now, when a proposed delay in the implementation of Meaningful Use Stage 2 is waiting in the wings, it is quite hefty to square off payment year if eligible health care professionals switch between the Medicare or Medicaid EHR incentive program and skip years.

CMS has gained the reputation for changing or extending deadlines as we observed for Stage 1 of Meaningful Use, HIPAA 5010 implementation, ICD-10 and now a proposed delay in Stage 2.  It is mixing up all the neatly designed tables and timelines that everyone had planned to follow. Even if it is done in good faith by the officials at CMS (with an intention to encourage more participation) or due to financial restraints,  the jigsaw puzzle of understanding payment plan in different years, is practically baffling health care professionals.

In the given scenario, for Medicare, Stage 1 of Meaningful Use continues on from 2011 through 2013, while Stage 2 will begin in 2014.  Eligible Professionals (EPs) must be Meaningful Use compliant in the Medicare program for consecutive years. So what would be the payment year for EPs receiving payments earlier and then switching to Medicaid?

Let us take the guidance from official documents on the subject. Stage 2 proposed rule suggests that there should be no changes to the rules on EPs switching between programs mentioned in the final rule. Going back to final rule we find that if an EP qualifies for both (Medicaid and Medicare program) then the EP must notify CMS as to whether he or she chooses to participate in the Medicare or the Medicaid EHR incentive program. If the EP desires to switch between the two EHR incentive programs after receiving at least one EHR incentive payment, he or she can make the move only once before the 2015 payment year.

Then the question is, if an EP receives Stage 1 incentive payments from Medicaid EHR program in 2012 by meeting all of the applicable requirements and then switches to Medicare program in 2013, then would he or she be taking payments starting afresh in 2013 because the program has changed, as well as requirements have been met again? The answer is ‘No’. An EP that begins receiving incentive payments in 2012, and then switches to the other program in 2013 would count as their second year of payment.

It is equally important to know that switching to another incentive program in an alternate year; the EP must meet all of the applicable requirements, including applicable patient volume requirements, for the program in which he or she chooses to participate.

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