Electronic Medical Records

One of my roles with Ortmann Healthcare Consultants is to help the ASCs we develop decide on information technology needs. I find most of our physicians want electronic medical records and do not want to build out the space in which to store patient records in their new ASCs. That is, until they discover what all goes into putting together a truly “electronic” record. (Unfortunately, discovering what goes into being paperless isn’t truly realized until the decision has been made to cut the medical records room in the ASC design.)

What I’ve found since I started working in this industry over the past five years is that it’s really easy to say “electronic record,” but more difficult to make it happen. I could probably write several times on this subject, but for today my focus will not be on any particular information technology system, but rather on the true difficulties of “paperless,” especially with new changes to CMS’s requirements for ASCs.

Other than putting together the actual software system, one of the most difficult things about going paperless is the amount of paperwork that a patient must sign (informed consent, HIPAA notification, financial disclosures, discharge instructions, to name a few) along with paperwork that may come from a referring physician. We get around this problem by scanning these items into the electronic medical record software that is used, so we can in the end become “paperless,” but printing out all of this paper sort of defeats the purpose of trying to be “paperless.”

It’s amazing how many pieces of paper must be generated for the typical electronic medical record. Part of the savings associated with these systems is not having to buy the folder for the chart contents, not having to buy paper to print out patient forms, and not having to spend as much time assembling the paper chart and paying the salaries of those who do the assembling. Now, please don’t get me wrong. We are saving money, even though we still need to do these things. We don’t need to print out as many pieces of paper, we don’t need to pay for dictation, we don’t need to spend as much time assembling the chart, but if we could be more paperless, we would save even more.

So as part of my job is to deal with the best way for our centers to handle all of this, you may imagine how pleased I was to find that Provation Medical, a company that I particularly like to use in the centers I work with, had released Provation EHR. One part of this software system is the ability for patients to sign paperwork electronically, much as you electronically sign for credit card purchases. Wow, I thought, this will eliminate so much paper! The patient will be able to read the document and sign—no paper and no scanning (saving even more time and salaries for that time). This could save 10 or more sheets of paper per patient.

Unfortunately, part of my “Wow,” though, was dashed all too soon. By whom? CMS, in its final rule for ASCs 2009. Typically most paperwork is signed in the ASC (and in hospital outpatient departments, too) on the day of the procedure. So, with this electronic signature available, patients could sign all of the required paperwork the day they arrive for their procedures, electronically, saving paper, time and a few trees. But CMS is changing all of this on May 18, 2009, with the implementation of new Conditions of Coverage. You can find more information about all of the changes on the ASC Association webpage.

Now several items have to be provided in advance of the date of the procedure: forms on patient rights, disclosure of physician financial interests in the ASC, information on the ASCs policies on advanced directives. And to prove that these items have been provided, the patient needs to sign each in advance of the date of the procedure (at least that’s my current understanding). So, unless the patient comes into the ASC before the date of the procedure to sign these items electronically, these items will have to be scanned into the chart.

So, this great new feature, will have limited usage in the ASC, unless CMS changes its mind next year about this new condition for ASCs.

This is another example of the ASC being held to a different standard than hospital outpatient departments. A hospital outpatient department does not have these “advance of the date” requirements. If a patient is seen by a physician one morning and there is an opening in the ASC or hospital for a procedure to be completed that afternoon, currently there’s no problem. But, on May 18, 2009, this will be a problem for an ASC as explained above. Not for a patient who has a procedure done in a hospital outpatient department, though. That patient can still be treated in the HOPD the same day. (Are HOPD patients more capable of digesting important paperwork while ASC patients must be given 24 hours or more to understand the same information?)

Obama has made it clear that he wants American’s healthcare system to move into using electronic medical records. I hope he can convince CMS to structure current policies so that ASCs can follow his lead.

Submitted by Chris McMenemy, VP Administration