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Hospitals Allowed to Pay for EMR Interfaces and Not Violate Stark
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As noted in HIS-Talk and HANYS News, CMS released an advisory opinion that allows for hospitals to pay the cost of EMR interfaces without violating the Stark Law. Hospitals are restricted under the US law regarding compensation arrangements between physicians and hospitals. HANYS News wrote:
Specifically, a hospital system can pay for the creation of an electronic interface between unique electronic health record (EHR) systems of individual physician practices and the hospital network’s EHR system. The interface would allow physicians, from their practices, to order and communicate the results of tests and procedures performed.
The CMS news was delivered in “Advisory Opinion No. CMS-AO-2008-01″. There are many words used in the advisory; here is a quote that is the meat of the opinion:
The Requestor … owns and operates … hospitals … [and] contracted with a third-party … Vendor … to install a proprietary health care software information …System …, customized to the Requestor’s specific requirements, including a software interface engine that facilitates access by the custom Physician Practice Interface(s).
Pursuant to the contract between the Requestor and the Vendor, the Vendor provided software licenses to the Requestor that permit the Requestor and its controlled affiliates to use the System.
Currently, the medical staffs of Requestor’s … hospitals have the option to view laboratory reports for the Requestor’s patients over a protected internet connection to the System. The Proposed Arrangement would permit also the ordering or communicating of laboratory tests or procedures performed by the Requestor using the Physician Practice Interface(s).
Numerous physicians on the Requestor’s medical staffs have begun to purchase and use electronic health records (“EHR”) systems for their private practices. Requestor would like to integrate its System with individual information systems maintained by the Affiliated Physician Practices to promote the secure transfer of patient data between the parties. Integrating the System with each Affiliated Physician Practice requires the custom development of an interface that can extract data from the System and transfer it to the Affiliated Physician Practices’ EHR systems. The Requestor may need to develop several versions of the Physician Practice Interface to accommodate the various EHR systems. The Requestor would limit the functionality of the Physician Practice Interface to the ordering or communicating the results of laboratory tests or procedures furnished by the Requestor.
Under the Proposed Arrangement, the Vendor would develop, and the Requestor would pay the development cost of, a Physician Practice Interface customized to the Affiliated Physician Practice’s existing EHR software. … Physician Practice Interface would be used only to order or communicate the results of tests and procedures furnished by the Requestor and could not be used for any purpose other than the ordering or communicating of the results of tests or procedures furnished by the Requestor.
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Therefore, we have determined that the Proposed Arrangement does not meet the definition of “compensation arrangement” for purposes of the statute’s prohibition on physician self-referral
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Healthcare IT Definitions Released
For more information visit NeoTool.com
The National Alliance for Health Information Technology (NAHIT) recently released new definitions of certain healthcare IT terms. This project was completed for the Office of the National Coordinator of Health Information Technology; this office was created by the President on April 27, 2004 to promote the adoption of electronic health records by most Americans by 2014.
Outlined below are the definitions published by NAHIT. These healthcare IT definitions were published in the report entitled Defining Key Health Information Technology Terms (PDF).
- Electronic Medical Record: An electronic record of health-related information on an individual that can be created, gathered, managed, and consulted by authorized clinicians and staff within one healthcare organization.
- Electronic Health Record: An electronic record of health-related information on an individual that conforms to nationally recognized interoperability standards and that can be created, managed, and consulted by authorized clinicians and staff across more than one healthcare organization.
- Personal Health Record: An electronic record of health-related information on an individual that conforms to nationally recognized interoperability standards and that can be drawn from multiple sources while being managed, shared, and controlled by the individual.
- Health Information Exchange: The electronic movement of health-related information among organizations according to nationally recognized standards.
- Health Information Organization: An organization that oversees and governs the exchange of health-related information among organizations according to nationally recognized standards.
- Regional Health Information Organization: A health information organization that brings together health care stakeholders within a defined geographic area and governs health information exchange among them for the purpose of improving health and care in that community.
The greatest understatement in the report is: “Interoperability is the common thread running through health IT terms. Interoperability is the essential factor in building the infrastructure to create, transmit, store and manage health-related information.”
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Radiology CIOs Play a Strategic Role
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A recent Radinformatics article entitled CIO at the Table highlights the fact that most radiology practices have not welcomed their CIOs to sit at the executive committee table. Nevertheless, research indicates that having the CIO at the management table will facilitate the practice’s growth more effectively.
Creating a competitive advantage for your radiology practice is critical in today’s market. Healthcare IT is a critical strategic element that can automate, streamline, enable, etc. radiology workflow. Having the CIO present at the business level can only help your radiology practice meet the growth and operational goals.
Many of the radiology practices we work with have a CIO who has a strong involvement in the operational discussions, and they have produced impressive results. The results can include improved turn around times (TAT), improved billing cycle times, or other elements of the radiology workflow.
The Radinformatics article highlights some important insights about radiology CIOs, including the valuable role they can play and the skills they can bring to the management table.
