Switching EHRs Mid-Stream – Meaningful Use Monday

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

With all the attention that meaningful use Stage 2 has received in the last 2 weeks, it’s easy to forget that most providers are just ramping up for meaningful use stage 1 and are still trying to understand the requirements they must satisfy for the next 2 years. So I’m going to let the dust settle a bit on the Stage 2 proposal and go back to addressing lingering questions about Stage 1.

Last week’s post talked about the increased frequency with which providers are switching EHRs. Some are replacing legacy EHRs that are not ONC-certified in order to qualify for meaningful use incentives, while others are switching from one certified EHR to another to better meet their practice needs. An EMR and HIPAA reader who is changing EHRs in mid (meaningful use) stream submitted the following question:

Q:  “If we attest for 2011, then 3-4 months into 2012 we change to another software vendor, is there a way to attest using both software vendors since we have to combine or run reports to attest for the whole year of 2012?”

A: Yes, you can attest using both EHRs—in fact, you must report from both EHRs. First, enter both certified complete EHRs into the Certified Health IT Product List (CHPL) website to generate a new EHR Certification ID number to use for 2012 attestation. You will need to combine the results, measure by measure including clinical quality measures, from the two sets of reports that you run. For measures that require a count of actions, this is fairly easy—you simply add the numerators and denominators. Where this becomes somewhat challenging is in reporting measures where the denominator is “unique patients.” According to a CMS FAQ regarding a similar situation, (i.e., providers who see patients in multiple locations with different certified EHRs), “…it is the responsibility of the EP….to reconcile information from multiple certified EHR systems in order to ensure that each unique patient is counted only once for each objective.”  No further guidance is provided on how to accomplish that.

About the author

Lynn Scheps

Lynn Scheps

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

7 Comments

  • I have an unrelated question. Ive spend three days trying to find the answer to this question, with no luck.
    I had a child last year in Jan by March I was back to work. In April I ended up in the ER with what was explained to me as a “kidney bleed out.” That I was simply over doing it and had not let my body heal from having the baby. The doctor handed me a no work slip for 4 days.
    When I called my boss and explained to him what happend. I used those words to describe what the doctor said. He in turn was upset that he had to work more hours and wrote the words “kidney bleed out” under my name hugely. He left it up and posted for all my co-workers to see. I was so embarrassed.
    Im not looking to cause problems about it but now theres a younger girl thats having complations with her pregancy and hes doing the same thing. Isnt it wrong ? is there a law that protects us?

  • Jill,
    That’s a really unfortunate incident. I’m not a lawyer, so I can’t give you legal advice on the subject. However, I don’t think this would be covered under any HIPAA violation since I can’t imagine your employer is what’s called a covered entity. However, it’s very possible that it is a violation of some other HR law when it comes to this.

    Sorry we’re not much help here. You should consult a lawyer to know if it’s a violation or not.

  • Jerome Carter,
    Great find. I’m going to have to dig into it and write a future post about it. In fact, that whole section is quite interesting.

    My gut reaction is that the government won’t do anything about it. If I’m most EHR vendors I want to kick against a standard of portability so someone can leave their EHR. Although, it could be a great competitive advantage to the first couple that adopt it. In fact, I’ve kicked around an idea related to that for a while now.

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