CPMC EHR Donation Program
Eligibility and Selection
Frequently Asked Questions
What made CPMC decide to do this now?
In October 2006, CMS created an exception to Federal Kickback/Stark regulations, which allowed hospitals to donate an EHR, information technology or training services to referring physicians under certain defined criteria. This was followed in May 2007 by IRS guidance allowing non-profit entities to protect their tax-exempt status in these situations. These two key legal developments created the opportunity to develop the Donation Program. CPMC recognized the need to assist independent physicians in obtaining electronic health records.
How does this relate to CPMC’s timing for bringing on Epic? Since this Donation Program is using Allscripts, what happens when Sutter Health brings Epic to CPMC?
Epic is currently being implemented in the CPMC Foundation outpatient clinics, and is scheduled for inpatient implementation in 2015. Eventually, all SPMF physicians will be on Epic. Future plans include the development of robust interfaces to allow bidirectional data exchange between Allscripts and Epic.
Some CPMC physicians are part of Sutter Pacific Medical Foundation, which is rolling out Epic. How will this work? Compatibility?
As indicated above, there are definitive plans to develop communications interfaces between Allscripts and Epic so that key clinical information can be shared electronically between Foundation and non-Foundation providers.
Why only three years? What is the rationale?
The CMS exceptions described above are scheduled to sunset on December 31, 2013, so after that time CPMC cannot legally continue the program.
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Tell me about Meaningful Use and Financial Incentives? What is this about – how does the EHR program fit in, how do I reap these benefits, etc?
The federal government, through Medicare, will pay physicians up to $44,000 over four years for “meaningful use” of a certified EHR, beginning 2011. It is intended that physician practices in the Donation Program should be eligible to qualify for these incentive payments. Allscripts has recently been announced as one of the first certified EHRs, and we are confident that all implemented physician practices will meet meaningful use criteria and thus quality for incentive payments. See Benefits at a Glance for more details.
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Eligibility and Selection
What are the selection criteria?
All independent physician practices (non-Foundation) are eligible as long as all physicians in the practice are members of the CPMC or St. Luke’s medical staffs and meet legal requirements. Practice Selection Criteria pertain to the order in which practices can be scheduled for implementation order.
Who is making the decision on implementation order?
The EHR Donation Physician Advisory Committee will make recommendations to CPMC Executive Management, which will make the final decision.
If a group of physicians meet the criteria, is it first come, first serve within that group? Can I put my name in now?
Applications will be pooled on a regular basis, and practices will be scored based on the criteria recommended by the Advisory Committee and established by CPMC. Scoring will determine implementation order within a specific pool of applicants.
A practice may submit its application at any time.
If the criteria are just guidelines for the Committee, how exactly are you going to make decisions on who is selected and when they will be on boarded?
Provided all physicians in the practice are on the CPMC or St Luke’s medical staff, all practices meeting the minimum technical requirements and meeting legal requirements will be eligible to participate in the program. CPMC will, do the best of its ability, apply objective criteria to score each practice in order to create an implementation “queue.”
I use an EHR now, but would like to switch to Allscripts? Can I do this?
Stark Law guidelines indicate that physicians who currently have full EHR capabilities are not eligible for the CPMC EHR Donation Program. Of course, you may chose to switch to Allscripts at your discretion, but it is unlikely that you would be eligible for the Donation Program. However, we are willing to explore whether or not you might qualify, based in part on the depth and breadth of your current EHR capability.
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What exactly will be provided to me as a physician? What will CPMC provide, what will BTPSO provide?
BTPSO will provide physicians with the integrated application, which includes a full electronic health record (Allscripts Touchworks) as well as a robust practice management module (GE Centricity). Seamlessly incorporated into the EHR are multiple data feeds from interfaces to many large healthcare organizations and vendors around San Francisco. Physicians will also have as an option a website with patient portal features, and standard financial and clinical reporting.
BTPSO will provide physician training and ongoing customer services. CPMC will be paying for 82% of the costs per physician per month.
What do I have to provide? What if I don’t have all the requirements in place?
Physician practices must provide and support all computer hardware (desktops, laptops, etc), as well as all networking (including wireless) in order to be eligible for the program. An initial technical assessment will be performed to assure all hardware meets acceptable standards for system performance. All hardware upgrades required will be the responsibility of the practice.
Once I am selected, what are the steps/schedule leading up to implementation?
The implementation process takes about 16 weeks from initial contact to Go-Live, and includes the following elements:
- Practice meetings and demos
- Workflow assessment and recommendations
- Chart scanning/abstraction planning
- Note template creation
- Hardware testing
What is the timeframe from application to on boarding??
Once an application has been received, the practice will be confirmed within 2-6 weeks. It takes approximately 4 months in total from confirmation to actual “go live.”
How can CPMC legally give computers to private physicians –isn’t that a potential violation?
Compliance with the Stark exceptions as described above has been carefully reviewed by attorneys and is in compliance with regulations; the physician payment portion was developed – and calculated – to ensure compliance.
Given the short program duration, what are the pros and cons of me choosing this program vs. going out on my own with another vendor? What special benefits does this program bring to me? What is the value added?
We encourage you to look at the Benefits at a Glance fact sheet
Why was BTPSO selected as the vendor?
Brown and Toland Physician Services Organization (BTPSO) has highly experienced implementation teams. It has over 6 years in training and implementing Allscripts and the GE Centricity physician project management software.
What is the training plan?
There is a comprehensive training program for both physicians and non-physicians. This involves at least two 3 hour sessions in the computer lab. Plus, there is extensive training in the provider’s office. After go live there will be ongoing training and input from both the PPS team.
BTPSO will provide training for physicians and physician users that may include
- a customized implementation training program and schedule for EHR Items and Services,
- ongoing training courses for various Items and Services scheduled on a monthly basis and based on class availability - we have use a groups setup for physicians, GE users and we are also looking at a touch works used to group for non physicians
- the option to customize and schedule additional training courses scheduled at mutually convenient times at the currently hourly rates.
What kind of customer service support can I expect? How can we ensure high quality customer service?
CPMC’s agreement with BTPSO outlines very specific performance metrics around customer service. Metrics include ticket turnaround times as well as criteria for what is considered critical, high and medium priority issues. Performance metrics [PDF] will be posted to the BTPSO physician website on a monthly basis. (Download a free copy of Adobe Acrobat Reader)
Will my staff get access?
Yes. All staff have a unique username and password. Roles and rights will differ if you are a non-physician (eg: MAs can’t prescribe medications).
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What levels/types of security will be in place?
CPMC’s contract with BTPSO stipulates that BTPSO will maintain reasonable safeguards against destruction, loss or alteration of physicians’ patient PHI and will maintain virus protection software as well as disaster recovery and a business continuity plan.
There are comprehensive policies and procedures in place to maintain system security and to monitor access to confidential patient information. There is an electronic chart audit process that checks for inappropriate chart access and generates reports for each medical practice. Incorporated within the EMR system is the ability to “lock down” sensitive or personal information viewable by a single provider entry. BTPSO maintains a Physician Advisory Committee oversees and regularly reviews all the aforementioned policies and procedures as they relate to data security and chart access.
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Why do physicians have to pay?
This ensures that CPMC is in compliance with Stark regulations
On what basis was the physician portion determined?
CPMC is donating the maximum amount possible under Stark exceptions (82%). The physician portion represents the remaining 18% as applied to the fair market value of the EHR.
Is there a different rate for physicians in group practice? i.e. a practice rate?
No. All physician users will pay the same monthly rate.
Are there any additional/hidden costs, e.g. dictation?
Those practices wishing to utilize dictation within the EHR will be responsible for the cost of the voice recognition software (Dragon), or any outside transcription service. Other additional costs may include any network or hardware upgrades necessary to meet the minimum technical requirements as defined by BTPSO.
What happens after December 31, 2013 –do I have to pay the $1611 a month/will this amount be fixed?
Physicians will be responsible for paying the market rate for the EHR - currently $1611/month.
What if I am on boarded late in the process – do I still have to pay for the full three years?
Contracts are executed with the entire practice; the contract term is three years, regardless of when initial implementation occurs. New physicians joining a practice already in the program will be added to the practice contract, so will pay for less than three full years at the Donation Program price.
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When/how are you going to announce the criteria/selection process?
Through a variety of vehicles - memo, email and the internet.
Who is the contact within the Physicians Advisory Committee?
Arieh Rosenbaum, MD is the Chair of the PAC
Who do I contact if I have questions about the application process?
Arieh Rosenbaum, MD (RosenbA@sutterhealth.org)
Who do I contact for customer service help once I am online?
As part of the on boarding process, you will be given customer service contact information.
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