Adapting to 45 CFR Part 170 Subpart C

Adapting to 45 CFR Part 170 Subpart C of the Final Rule for Health Information Technology.

The consensus is sooner or later healthcare agencies are going to be herded into adopting “certified” EMR/EHR systems.  The party line is “a certified EMR/EHR system is a good thing” and there is truth in this, but the question is “good for whom”?

Right now we the industry is at MU Stage I (don’t bother to read the 2000 pages in the final rule).  Basically, it says that for eligible professionals attending to Medicare patient populations, you can, over a period of five years, get a $44,000 incentive payment per eligible professional.

Nowhere do we see what the required outlay is relative to the $44,000 incentive.

Remember the old saying “if you torture statistics sufficiently, they will tell you want you want to hear”?

ROIs that exclude hard-to-identify costs look good but most agencies don’t prepare ROIs and an even smaller number have the ability to cost out the indirect costs, so is payback from the investment positive or negative?

The EU did a big study on ROI of EMRs/EHRs – the payback period was far longer than most agencies in North America have patience for, besides, things are different over here, so, again, who knows?

Chances are it does not matter if the prediction of mandated EMR/EHRs comes true so the key issue becomes can a chosen EMR/EHR increase staff efficiency, increase patient throughput, decrease admin/clinical errors, and improve compliance with internal and external rules and regulations?.

The question I put to my clients when they ask whether they are doing the right things is “Are your workflows working for you or are you working for someone else’s workflows?”

On the presumption that we will see mandated EMRs/EHRs, Civerex has put together a blueprint for 2012 and beyond that will see a consolidation of our two healthcare products (CIVER-PSYCH® and CiVER-MED) to a single product called CIVER EHR.

The rationale for this is quite simple – at present there are no BH MU criteria – right now, the only category open for outpatient  is the Ambulatory category.  It includes various criteria such as Vital Signs, Submissions to Immunization Registries, Public Health Surveillance reporting and Automatic Measure Calculations/Reporting.

It may turn out that BH agencies can exempt themselves  from some of these criteria but we don’t know.  A consolidated MU product does not have to deal with the uncertainty – we will certify with ONC as CIVER EHR and content will then set the focus on BH, Medical or both.


Management consultant and process control engineer (MSc EE) with a focus on bridging the gap between operations and strategy in the areas of critical infrastructure protection, connect-the-dots law enforcement investigations, healthcare services delivery, job shop manufacturing and b2b/b2c/b2d transactions. (C) 2010-2018 Karl Walter Keirstead, P. Eng. All rights reserved. The opinions expressed here are those of the author, and are not connected with Jay-Kell Technologies Inc, Civerex Systems Inc. (Canada), Civerex Systems Inc. (USA) or CvX Productions.
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