Wal-Mart and Mental Health EMR: Unlikely

For the past week the health IT news world (NYTimes; Chicago Sun Times; MSN; ) and blogosphere (FierceHealthIT; Healthcare Informatics) have been abuzz with Wal-Mart’s announcement that they will begin selling electronic health record (EHR) software to doctor’s offices starting this Spring. They will do so in partnership with eClinicalWorks and Dell through their Sam’s Club stores.  

Our initial reaction was panic. After all, if the world’s largest retailer decides to get into our market space, how can we possibly survive? And what does this mean for our customers?

Then we started reading the fine print. The cost for the first physician in the practice will be $25,000 plus $10,000 for each additional physician. The first year’s price includes hardware, installation, some training, technical support, and a variety of other odds and ends. And that is for software as a service. That means you do not own a license for the software; rather you connect into the company’s system and maintain your records there.  (This is the model that some people believe is the only viable one for a broad national system, but many dispute that.) After the first year, the cost per doctor is $500 per month.

John D. Halamka, M.D., CIO of the CareGroup Health System and Harvard Medical School among many other posts, is convinced that this pricing is fair and that Wal-Mart’s expertise in supply chain management and their own experience with IT systems inhouse will make their coordination of this project a success. In fact, he says that its a “good deal“. 

While this sort of price point might be cost effective and competitive for general and speciality medical physician practices, it is certainly not so for those in behavioral health practices. Most community based behavioral health organizations are also not likely to find this pricing structure something they can build into their budget.

If this is the Sam’s Club bargain software, where does that leave mental health providers? While there are currently a few companies with very reasonably priced electronic medical records (EMRs) aimed at the behavioral health community, time will tell whether meeting the requirements for CCHIT certification and paying to acquire that certification will allow the products of this small cadre of companies to remain affordable.

What’s your take on the Wal-Mart announcement? Where do you see this search for the EMR going for you? 

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ARRA’s New Privacy and Security Requirements

I was all set to write an article Monday morning on the expanded privacy and security requirements in the American Recovery & Reinvestment Act of 2009 (ARRA) when I remembered that I was registered for a webinar presented by FairWarning (a privacy surveillance company) Monday afternoon on just that subject. I am really glad I waited to write, because this webinar provided a wealth of information on the new requirements. [By the way, you will also see this section of ARRA (Title XIII) referred to as the Health Information Technology for Economic and Clinical Health (HITECH) Act. Subtitle D contains the Privacy provisions.]

Many people and organizations have opined that EHRs will not take hold in general medical settings or in behavioral healthcare until consumers and providers trust that the EHR products and the means of transferring data are truly secure and protect the privacy of the patient. Webinar presenter Deven McGraw, of the Center for Democracy & Technology, most articulately presented the aspects of ARRA that will increase the privacy and security requirements that healthcare providers must follow. She indicated changes in four broad areas including substantive modifications to HIPAA statutory requirements, increased enforcement of HIPAA, provisions to address health information held by entitites not covered by HIPAA, and a variety of administrative changes.

The new law incorporates and expands upon the HIPAA requirements.

  • There has been an attempt to more clearly define certain terms, like just what a “breach” of privacy is.
  • Previously, covered entities where the only ones required to report breaches of privacy; now the same requirement is placed upon Business Associates.
  • HITECH strengthens the individual’s right to restrict disclosures of health information to their insurance plan and even allows the individual to “opt out” of electronic recording and sharing of their information if they pay for their services privately and in advance. Mental health services are frequently cited as  sensitive content that an individual may want left out of their electronic record.
  • The HIPAA mandate requiring that a provider not release psychotherapy notes to the insurer has been included in this act, and the Secretary of Health and Human Services (HHS) has been ordered to study whether psychological test data should be included in this exception.
  • ARRA improves upon the HIPAA “minimum necessary” standard requiring that only the minimum amount of patient information should be disclosed depending upon the specific request for information.
  • The legislation places requirements upon companies that provide Personal Health Records (PHR) for the security of the data in those records, and prohibits the sale of protected health information.
  • Most importantly, the law provides an ongoing process for setting privacy and security standards and evaluating their effectiveness. 

brief summary of these changes written by the American Psychological Association was published by Behavioral Healthcare magazine in February.

Perhaps the most important thing behavioral health providers need to realize is that the move toward mental health EHRs is happening. How exactly those records will interface with the rest of the National Health Information Network and exactly what information will be shared with other healthcare providers remains to be seen, but this endeavor is irrevocably marching forward. Where will you be in this process?

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E-prescribing and a Behavioral Health EHR: Where to from here?

For the past several years Synergistic Office Solutions, Inc. has had the privilege and pleasure of participating as a member of the Software and Technology Vendor Association (SATVA), a group of vendors of software and other technology for the Behavioral Health and Social Services community. Last Thursday, I returned from our semi-annual member meeting…charged up with information about what is happening in the behavioral health world and full of questions about how all of the current events will impact SOS and our customers.

Standards for Electronic Health Records (EHR) for Behavioral Health were our primary discussion topic at this meeting. The community mental health world has long known that they will need to use EHRs to maximize the efficiency of their services and document the effectiveness of their treatments. State reporting requirements alone make use of an EHR a worthwhile way to simplify the lives of clinicians and administrators. Psychologists and psychiatrists in the private practice community have been slower to embrace the idea that electronic clinical records will improve care. The cost of the product and the time it takes to learn and use such software has been an obstacle for many organizations. While our mental health clinical record software has been around since 1992, we have many fewer users of that product than of our billing software.

Some states and payers are rapidly moving toward mandates for implementation of aspects of an EHR. FierceHealthIT, a newsletter for those working in information technology for health care, reported last week that MA BCBS will be requiring e-prescribing by January 1, 2011 for physicians who participate in their incentives program. The Centers for Medicare and Medicaid Services (CMS) has developed an electronic prescribing incentive that will increase physician reimbursement by 4.5% by 2014 for those who use qualified electronic prescribing products. The National Governor’s Association (NGA) has provided a forum and support for states to move forward on Health Information Exchange (HIE), electronic prescribing and computerized physician order entry (CPOE) . At the federal level, a public-private partnership has been formed in the AHIC Successor, Inc. to move forward the process of developing a National Health Information Network (NHIN); and the Certification Commission for Healthcare Information Technology (CCHIT) has formed the necessary work group to certify a Behavioral Health EHR.

While the names and acronyms of these bodies may be new to many of you, they are working hard to assure that interoperable EHRs are widely implemented by 2014. Many in the industry consider this an unrealistic goal date for such comprehensive change, but many entities are dedicated to seeing successful adoption of this technology in the not very distant future.

How will the requirement for health care providers to utilize EHRs affect psychologists, psychiatrists and social workers in private practice? Will the expectations be different for private care providers than for behavioral health providers in a community setting? How do you expect these changes to affect your organization? Are you already using an EHR? Let’s talk about where you see this going in your world.