Electronic Health Record

[Jorgebon]

I received some information today about the "American Recovery and Reinvestment Act" that has as one of its provisions something called the "Health Information Technology for Economic and Clinical Health act" (HITECH Act) that promotes the use of electronic medical and dental records. It says that the federal government wants to have health care providers adopt electronic health records (EHR) by 2015. They even have a provision for reimbursing healthcare providers that adopt the EHR, but you have to qualify by being a "meaningful user" (whatever that means), have a certain percentage of patients that are Medicaid or Medicare patients, and the software has to be certified by the "Certification Comission for Health Information Technology". Anyway, I think they are moving towards some kind of standard so that patients can take their records electronically from one place to another.
Jordan, do you have any information on this and will Open Dental be compliant with this new standard?

Jorge Bonilla, DMD

[jordansparks]

Everything I've seen so far has to do with medical rather than dental. But yes, we certainly will become compliant if a standard for dentistry is ever created. I have never seen anything for dentistry but rumors.

[atd]

A year or so ago we applied for a grant that required interoperable electronic records for exchanging health information. We wanted to exchange medical/dental records with the nursing homes that we serve - instead of having to receive paper health history from them and us giving them paper progress notes. At the time there were no standards for dental records or any "certified" dental software, just medical. According to this article there is some movement on this issue, but it sounds like just the beginning:
http://www.fiercehealthcare.com/press-r ... oint-healt

[caringdentists]

Here's an alarming post:

"..

..The problem is that if HHS decides to use CCHIT as the certification criteria for the EHR stimulus, then the HITECH act will basically be excluding open source EHR and EMR packages from being part of the “certified EHR.”

http://www.emrandhipaa.com/emr-and-hipa ... ect-cchit/

By the way, my office could qualify for the incentive program. But is Opendental certified?
Here's another alarming post:

Why doesn’t every vendor just get certified?
It’s not that easy. Many non-certified vendors object to the certification fees – $29,000 for the initial review and $6,000 in annual maintenance fees over the three-year certification.

Read more: http://www.softwareadvice.com/articles/ ... z1ANOU5t6x


All comments and link would be greatly appreciated.

[jordansparks]

That's all talking about medical, not dental. It simply doesn't apply. When they refer to open source medical, they are talking about the ones with no viable business model, the ones that are free and have no paid programmers.

We could simply raise our rates for customers that needed a certified product. Since everyone else would also be raising their rates, we would still be competitive.

[JrGong]

From what I understand, the HITECH act is basically an extension of HIPAA. All of the regulations are apllicable to and I quoute:

"Sec. 164.104 Applicability.

(a) Except as otherwise provided, the standards, requirements, and
implementation specifications adopted under this part apply to the
following entities:
(1) A health plan.
(2) A health care clearinghouse.
(3) A health care provider who transmits any health information in
electronic form in connection with a transaction covered by this
subchapter.
(b) When a health care clearinghouse creates or receives protected
health information as a business associate of another covered entity, or
other than as a business associate of a covered entity, the
clearinghouse must comply with Sec. 164.105 relating to organizational
requirements for covered entities, including the designation of health
care components of a covered entity."

http://edocket.access.gpo.gov/cfr_2003/ ... 64.104.htm

That is for the HIPAA privacy rule but it applies to the HITECH Act aswell. There is no distinction as to the healthcare provider, so it is as applicable to dentists as it is dermatologists or psych docs.

[jordansparks]

There simply is no such thing as certification for dental software. So the article is only talking about medical software. It can't possibly be talking about dental software if there is no way for us to get certified.

[JrGong]

I decided to do some research, I find the HITECH Act to be an interesting regulatory act. As for who is eligible for incentives for using EHR (Electronic HEALTH Records, not medical, not dental, health).

"On January 13, 2010 we published a
proposed rule (75 FR 1844), entitled
‘‘Medicare and Medicaid Programs;
Electronic Health Record Incentive
Program’’ to implement the provisions of
ARRA that provide incentive payments
to EPs, eligible hospitals, and CAHs
participating in Medicare and Medicaid
programs that adopt and successfully
demonstrate meaningful use of ‘‘certified
EHR technology,’’ and incentive
payments to certain Medicare
Advantage Organizations for their
affiliated EPs and eligible hospitals that
meaningfully use certified EHR technology."

http://edocket.access.gpo.gov/2010/pdf/2010-17207.pdf

Now, this incentive is only for medicaid/medicare providers at the moment. So, are dentist's EP's (eligible professionals)?

"b. Program Participation
As specified under section
1903(t)(2)(A) of the Act, Medicaid
participating providers who wish to
receive a Medicaid incentive payment
must meet the definition of a ‘‘Medicaid
EP.’’ This definition (1903(t)(3)(B) of the
Act) lists five types of Medicaid
professionals: Physicians, dentists,
certified nurse-midwives, nurse
practitioners, and physician assistants
practicing in an FQHC or RHC that is so
led by a physician assistant."

If you, as a dentist and an eligible professional show use of EHR certified technology you can get a kickback. On to the real question.....

Is OD EHR technology material?

"5. Definition of EHR Module
We have defined the term EHR Module to mean any service, component,
or combination thereof that can meet the requirements of at least one
certification criterion adopted by the Secretary. Examples of EHR
Modules include, but are not limited to, the following:
An interface or other software program that provides the
capability to exchange electronic health information;
An open source software program that enables individuals
online access to certain health information maintained by EHR
technology;
A clinical decision support rules engine;
A software program used to submit public health
information to public health authorities; and
A quality measure reporting service or software program."

http://edocket.access.gpo.gov/2010/E9-31216.htm

I am not a lawyer, but it sounds like it could to me. This isn't about medical vs dental software, it's about the generalized definition of EHR. Now should OD care about this? Probably not, but I wouldn't be oblivious to it. Here is my opinion, and take it with a grain of salt (and this is coming from someone working in the information security field so it's definitely biased).

In the UK healthcare is nationalized, most of it runs on informations systems and there are heavy regulations on how those systems are supposed to perform and how they are to be secured and audited. The US is slowly moving in this direction, at least with regulation. HIPAA has always lacked teeth, and concrete standards as to what appropriate security is. Now that everything is converging to the digital realm security and interoperability are coming to the forefront. Will this all happen overnight where all healthcare providers have to have their information systems audited for compliance? Definitely not, but the government plans on having the infrastructure to do this for their systems by 2015.

Now, the various acts do mention the term physician in a few places, yet they fail to actually define it. Do they mean physician as in a an MD, or in general 'Doctors'? Dentist are definently eligible for money for implementing EHR, so you would think the EHR and software they use could fall under this incentive. Can't really say for sure though, but my opinion is dentists and dental software would definitely fall under this stuff as it relates to healthcare as a whole. All this being said I am not responsible for any misinformation

As for the certification standards, they have started developing the standards and implementation specifications for EHR modules.

http://healthit.hhs.gov/portal/server.p ... ached=true

[atd]

In 2009 we received a notice from ADEA entitled "New Law Includes Medicaid EHR Incentives for Dentists and Dental Clinics". The letter stated that there was federal stimulus money that would reimburse eligible dentists 85% of their costs for implementing EHR technology that meets the standards established by the Dept of Health and Human Services. The legislation required that HHS issue interim final regulations by December 31st, 2009. I did some searching online and found they established permanent certification to replace the temporary certification. It looks like they've developed what the standards are, but I don't see that there's a list of any EHR that has been certified.
http://healthit.hhs.gov/portal/server.p ... ogram/2884

We sure would like to apply for this if we could (we do meet the eligibility criteria), but would it be up to us to determine/demonstrate Open Dental met the standards? Here's more info on the testing methods:
http://healthcare.nist.gov/use_testing/index.html
http://healthcare.nist.gov/use_testing/ ... ments.html

[JrGong]

Here is a list of certified EHR stuffs

http://onc-chpl.force.com/ehrcert

Also from what I understand it wouldn't be up to you to to determine/demonstrate compliance, it would go in front of a certification board who would actually audit it to see if it meets specification, which if I had to guess is very expensive.....

[atd]

CMS is conducting an EHR teleconference this Friday, Feb 18th at 1pm EST about the Medicaid EHR incentive program, which includes dentists. I plan to participate, hopefully someone from Open Dental can also. You have to register by Thursday Feb 17th. Here's the link to register: http://www.eventsvc.com/palmettogba/reg ... 6a11697b13

[Fortune Hack]

IS THERE A WAY TO ISOLATE JUST ONE PATIENT RECORD FROM OPEN DENTAL FOR A PATIENT AND THE PATIENT COULD ACCESS THEIR FILE THEMSELVES VIA A TRIAL VERSION OR THIS FILE OF ONE PATIENT CAN BE IMPORTED BY ANOTHER DENTIST- PROTABILITY OF ELECTRONIC RECORDS -INDIVIDUAL PATIENT BASED.
IF THIS IS NOT POSSIBLE CURRENTLY IS IT POSSIBLE TO DO SO, IF WORKED ON?
IF IT CAN BE WORKED ON THEN ABOUT HOW MANY HOURS OF WORK THIS IS- APPROXIMATE- ANY INFORMATION ON SAME WOULD BE HELPFUL OR OTHER SOURCES TO SEARCH?
IN THE SECURITY SET UP- CAN THERE BE AN ADDITION MADE TO JUST ACCESS ONE PATIENT BY ONE USER-AND THEN FURTHER SECURE CERTAIN MODULES IF NEED BE? CAN THERE BE A LIMIT TO THE NUMBER OF USERS OR PATIENTS?
IS IT POSSIBLE TO ADD MORE SUBDIVISIONS IN THE SECURITY-PERMISSION OPTIONS FOR CERTAIN MODULES, FOR EXAMPLE IN THE FAMILY MODULE (NOT TO DISPLAY SS# OR SOME FIELDS IF NECESSARY) OR IN THE IMAGES MODULE ALLOW FOR ACCESS OF CERTAIN FOLDERS &/OR ALLOW ACCESS TO COMMUNICATION LOGS -DATE RANGE OR TYPE BASED IN ACCOUNTS OR IN THE CHART MODULE ALLOW FOR ONLY A CERTAIN DATE RANGE? IF IT IS POSSIBLE HOW MANY HOURS OF WORK IS THIS APPROX?
ANY CHANCE OF ADDING THE ABILITY TO CREATE OR ADD HYPERLINKS IN OPEN DENTAL ITSELF- LINKS IN PATIENT CHARTS OR ACCOUNTS TO IMAGES IN THE IMAGE MODULE OR TO WEB SITES OF PATIENTS IN THE FAMILY MODULE ?
THANK YOU.

[jordansparks]

We are, of course, working on all of those issues. I can't really answer the questions about how long each item might take. I'm not trying to be evasive, but it's just too complicated. I can probably give rough development costs, though:
1. Patient version of OD: $8000
2. Portability (depends on how many tables we're talking about) $10,000-$50,000
3. Family module hide individual fields (again, that's very vague and variable): $1000-$15,000
4. Images module security on certain folders: $5000
5. Commlog access based on date range (I don't entirely understand the point): $2000
6. Hyperlinks (depends on where and how many): $3000-$6000

PS. Please don't use all caps. Very hard to read. Also, this is probably better in a new thread.