Electronic Health Records: Operational Issues

The handwritten, paper medical record is taking its place in the archives of American medical history. Most healthcare entities have taken advantage of federal incentives to adopt electronic health records (EHRs) (US HHS "New"). EHRs represent one form of health information technology (health IT) that, in the view of many healthcare policymakers, is a means for improving healthcare quality, safety, and efficiency (Jha et al.).

EHR use is aimed at offering secure and reliable management of a patient's historic and current medical information at the point of care. EHRs support other care-related activities directly or indirectly via electronic interfaces, such as evidence-based decision support, quality management, and outcomes reporting (HIMSS "HIMSS Davies"). "Meaningful use" of EHRs is defined as "using certified EHR technology to improve quality, safety, efficiency, and reduce health disparities; engage patients and families in their health care; improve care coordination; improve population and public health; all the while maintaining privacy and security." (CMS "Medicare and Medicaid")

In April 2018, the Centers for Medicare and Medicaid Services (CMS) proposed changing the title of the "Meaningful Use" program to the "Promoting Interoperability" (PI) program. Several other suggested changes were bundled into the proposed rule, including an overhaul of the Electronic Health Record Incentive Program, with aims to increase interoperability; an increase in pricing transparency; and reducing the administrative burden on hospitals by reducing the number of reportable measures across five quality and clue-based purchasing programs. (CMS "CMS Proposes") The program was renamed Promoting Interoperability in May 2018. (CMS "Promoting Interoperability")

The healthcare regulatory environment is ever changing. Risk managers should monitor CMS and other government agencies to identify proposed changes to rules affecting their organization's operations. For more information about the proposed rule, see Monitor EHR Promoting Interoperability Program. For information on interoperability standards, see Partnership for Health IT Patient Safety materials, linked under Resource List​. For information on starting to implement EHRs in a healthcare organization, see Getting Help with EHR Implementation.

To help providers transition to electronic health records (EHRs), the American Recovery and Reinvestment Act of 2009 (ARRA) established a nationwide network of Regional Extension Centers (RECs) offering a variety of services to help providers, critical access hospitals, and regional hospitals face "the significant challenges of implementing EHR and demonstrating meaningful use" of EHR. (ONC "REC") As the regulations and requirements have changed, so have these centers. Those still in existence have modified their services to providers and organizations to assist with regulatory compliance, such as state Medicaid meaningful use programs, the Merit-based Incentive Payment System (MIPS) program, or other state funded initiatives. ARRA also funded individual state health information exchange (HIE) organizations via the State HIE Cooperative Agreement Program. The HIE was formed to develop and advance health information sharing across states. Unfortunately, fewer HIE organizations were established than anticipated. (ONC "Get the Facts")

Sources: Office of the National Coordinator for Health Information Technology (ONC), U.S. Department of Health and Human Services. Get the facts about using electronic health records to improve health care in your practice and community. cited 2017 Dec 13; cited 2017 Dec 11, link no longer available.

Medicare-eligible hospital providers may participate in the EHR incentive program if they are paid via the inpatient prospective payment system, as can critical access hospitals and Medicare Advantage Organizations. Dually eligible hospitals are included in the program if they meet specific requirements. (CMS...