Are You Ready for EHR? Is Your Vendor?

September 14, 2010
Randy Pinnow, CPA

A look at how EHR certification of vendors may impact physicians' medical practices as they prepare to select and implement an EHR.

Over the past year, so much media attention has been focused on the use of technology in the medical practice, more specifically, the new “meaningful use” rule for electronic health record (EHR) technology.

As the headlines have stated, the Health Information Technology for Economic and Clinical Health (HITECH) Act has created a business incentive in the form of bonus payments for Medicare- or Medicaid-eligible providers that are meaningful users of a certified EHR. So how will this impact your medical practice clients as they prepare to select and implement an EHR?

In January, the concept of meaningful use was born through a proposed rule from the Centers for Medicare and Medicaid Services. Stakeholders provided feedback during the time of public comment, and the final rules were published on

July 13, 2010.

In order to qualify for a bonus, meaningful use must be achieved using a certified EHR. But how will this be achieved when the federal regulators have yet to certify any EHR applications?

In late June, a temporary certification program was announced by the Office of the National Coordinator. This program defines a process for private entities to become Authorized Temporary Certification Bodies. To date, the Certification Commission for Health Information Technology (CCHIT) and Drummond Group Inc. of Austin, Texas, have been accepted as authorizing bodies.

CCHIT will first host a “Town Call” webcast to launch the certification process for EHR vendors on Sept. 20, 2010. Immediately thereafter, applications will be accepted from the vendors to begin the certification process.

Although CCHIT and the Drummond Group will have their own unique application process, we can expect to see software that meets criteria to receive either a “Complete EHR” or “EHR Module” status.

As the name suggests, the Complete EHR certification will identify solutions that provide all necessary functionality to meet meaningful use. The EHR Module certification will be awarded to solutions that intend to meet only key components of meaningful use. As an example, this may include an e-prescribing application.

Beyond EHR selection, meaningful use will also impact the implementation strategy. Moving from paper to electronic recording will bring profound change to the clinical and operational workflow of the practice. Many of the necessary changes to incorporate the EHR and achieve the quality-of-care goals envisioned before government incentives will also lead to meaningful use. The scope will need to change to ensure all 15 of the “core” objectives, along with five of the 10 “menu” objectives are contained in the implementation project plan.

Along with scope, implementation timing will need consideration. To obtain the maximum bonus under Medicare, the meaningful use period must begin in 2011 or 2012, for a minimum of 90 consecutive days of meaningful use during the initial year. What impact will this have on the vendor community? Will the vendors that are first to achieve certification have the resources necessary to manage the implementation process for all interested parties?

As mentioned earlier, do not underestimate the impact of the EHR on the practice. Physicians should not expect that on Oct. 1, 2011 EHR will go-live to achieve meaningful use for 90 days. It will take time to implement the workflow changes necessary to support the components of meaningful use. Vendors will likely recommend a phased approach to the implementation. If the practice-management system is included in the scope, this may go live in Phase 1, and individual aspects of the EHR will be phased in over time.

Meaningful use has changed the game significantly. Prior thinking around selection and implementation needs to change as well. (As if the process wasn’t complicated enough prior to HITECH!) Keep an eye on the certification processes as the full impact of meaningful use continues to emerge. Soon certified EHR’s will be available and many medical practices will begin the profound journey.

Randy Pinnow, CPA, is manager and health care consultant at Kolb+Co. SC, has been in practice since 1989. Randy has more than 12 years of experience in the healthcare industry and specializes in assisting practices streamline workflow and improve processes; internal audits and revenue cycle projects; and strategic planning to help practices reach their goals. For more information, please call (800) 461-8843 or visit www.KolbCo.com.

Mr. Pinnow is a proud member of the National CPA Health Care Advisors Association. The HCAA is a nationwide network of CPA firms devoted to serving the healthcare industry. Members provide proactive solutions to the accounting needs of physicians and physician groups. For more information contact us at info@hcaa.com.