While at HIMSS I had a discussion with the consulting firm Stoltenberg Consulting . I was really intrigued by their approach to EHR consulting and will likely write more about it later. Plus, the started what in many ways became a theme of my HIMSS experience around rural healthcare EHR. You can be sure I’ll be writing about rural EHR here on this site and on Hospital EMR and EHR much more in the future. In our casual introductory conversation we had a good discussion about how many of the smaller hospitals look at meaningful use and the EHR incentive money. Needless to say, many of these smaller institutions are faced with a huge challenge when it comes to adopting an EHR and showing meaningful use. Many of these rural hospitals barely have an IT staff and the CFO usually takes care of the IT environment. I heard one story at HIMSS where the IT person at a rural hospital started out as the janitor and his home IT skill made him the most qualified person to help. Needless to say, rural and smaller hospitals have some real challenges facing them when it comes to EHR adoption and showing meaningful use of that EHR. Although, an even worse thought struck me in my discussions about these smaller hospitals. Imagine many of these smaller hospitals making a good faith effort to adopt EHR and show meaningful use. It’s not that hard to see many of these hospitals falling short of the meaningful use standard. What will this mean to that organization? They’ve spent millions on an EHR. They won’t get the EHR incentive money they likely used as a justification for the EHR spending. To add insult to injury, now they’re going to get penalized for not being meaningful users of an EHR. This scenario honestly makes me sick to even consider. Something similar could easily happen in small ambulatory practices as well. The scale of the damage will just be different. I expect in meaningful use stage 1 this won’t likely be a problem since it’s self attestation. However, this could become a much bigger issue in meaningful use stage 2. Although, consider an organization who fails a meaningful use stage 1 audit. In most cases you can’t go back and fix whatever you failed in the audit. You’d be in a very similar situation where you have to return the EHR incentive money and would be open to the meaningful use penalties. At least that’s my understanding of how the EHR penalties will be implemented. If you know otherwise, I’d love to hear it. While I think the above scenarios are brutal, hopefully this will also serve as a warning for those hospitals pursuing EHR and the EHR incentive money. Be sure you are able to show meaningful use or you’ll not only lose out on the incentive money, but you’ll also be open to the EHR penalties. Not to mention, are you ready for a meaningful use audit? Related posts: How to Avoid Meaningful Use Penalties – Meaningful Use Monday The Low-Down on Future Meaningful Use Penalties — Meaningful Use Monday Meaningful Use Mondays – ePrescribing Penalties and MIPPA

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EHR Penalties after Meaningful Use Failure