Private Practice Olio

[R. Matey]

I do not believe that is necessarily the case. Can you provide the specific part of the statute that mandates EHR use in such a circumstance?

I think the requirement is that healthcare providers have to provide unfettered electronic access to their records, which in essence mandates EHRs. I don't have time right now to check on specific.

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[AcronymAllergy]

I do not believe that is necessarily the case. Can you provide the specific part of the statute that mandates EHR use in such a circumstance?

I think the CURES act actually explicitly says somewhere that it doesn't apply to paper records, meaning that it wouldn't mandate EHR use. Unless I'm misremembering.

It basically says a patient has to have access to their electronic records. It doesn't say their records have to be electronic.

 

[WisNeuro]

I think the CURES act actually explicitly says somewhere that it doesn't apply to paper records, meaning that it wouldn't mandate EHR use. Unless I'm misremembering.

It basically says a patient has to have access to their electronic records. It doesn't say their records have to be electronic.

I believe you are correct. Our state explicitly states EHRs are not required in many circumstances, and legal guidance I have seen federally is similar to this notion. Also, my patients all have copies of their reports, and the referring provider is also sent a copy. Never been an issue for me.

 

[WisNeuro]

I think the CURES act actually explicitly says somewhere that it doesn't apply to paper records, meaning that it wouldn't mandate EHR use. Unless I'm misremembering.

It basically says a patient has to have access to their electronic records. It doesn't say their records have to be electronic.

In addition to my statee laws and guidance on their HHS site, I found these

"While federal law strongly encourages the use of EHR systems, it doesn't mandate it across all healthcare providers in the United States. The HITECH Act, ARRA, and 21st Century Cures Act have incentivized and supported EHR adoption, particularly among providers participating in Medicaid and Medicare. However, the decision to implement an EHR system ultimately rests with individual healthcare providers, based on their specific circumstances and needs."

and this from a HC law firm

"To be clear, the Cures Act does not require you to adopt an EMR or EHR system at your practice. Additionally, at this time, there is no federal ban prohibiting the use of paper records as part of your practice operations. The Cures Act requirements only apply to electronic patient health information. In other words, if you are using paper records, the Cures Act’s final rulemaking process does not apply to you."

 

[R. Matey]

In addition to my statee laws and guidance on their HHS site, I found these

"While federal law strongly encourages the use of EHR systems, it doesn't mandate it across all healthcare providers in the United States. The HITECH Act, ARRA, and 21st Century Cures Act have incentivized and supported EHR adoption, particularly among providers participating in Medicaid and Medicare. However, the decision to implement an EHR system ultimately rests with individual healthcare providers, based on their specific circumstances and needs."

and this from a HC law firm

"To be clear, the Cures Act does not require you to adopt an EMR or EHR system at your practice. Additionally, at this time, there is no federal ban prohibiting the use of paper records as part of your practice operations. The Cures Act requirements only apply to electronic patient health information. In other words, if you are using paper records, the Cures Act’s final rulemaking process does not apply to you."

I found similar ¯\_(ツ)_/¯

 

[WisNeuro]

I found similar ¯\_(ツ)_/¯

No worries. Additionally, many private practice EMR systems I know people are using are not actually "interoperable" in terms of communication with other systems. I believe different rules apply in situations such as prescribing and whatnot, but for us small fries, no NBD.

 

[Sanman]

Registered agent question for you PP people. Did you act as your own registered agent, hire a registered agent company, or use a local attorney?

 

[AcronymAllergy]

Registered agent question for you PP people. Did you act as your own registered agent, hire a registered agent company, or usa a local attorney?

I currently use a company, but may do it for myself at some point. I don't really think the fee tends to be worth it, unless your state has some strange reqs for the registered agent.

 

[WisNeuro]

I am my own agent

 

[Sanman]

I currently use a company, but may do it for myself at some point. I don't really think the fee tends to be worth it, unless your state has some strange reqs for the registered agent.

Mostly thinking about it as a way to hide my personal address on NPI vs a virtual office.

 

[Therapist4Chnge]

I did it for privacy reasons at first, but then got lazy and haven’t updated it. $120/yr is the lazy tax I pay. I even set a reminder to change it, but got busy and just renewed another year.

 

[AcronymAllergy]

I did it for privacy reasons at first, but then got lazy and haven’t updated it. $120/yr is the lazy tax I pay. I even set a reminder to change it, but got busy and just renewed another year.

I also pay the lazy tax.

 

[PsyDr]

Mostly thinking about it as a way to hide my personal address on NPI vs a virtual office.

If that is all you are doing, go to a UPS store that offers PO Boxes with a physical address. $40/yr

 

[Sanman]

If that is all you are doing, go to a UPS store that offers PO Boxes with a physical address. $40/yr

I looked into that. Registered agent is not much more and I can be a bit lazier. Which is why I was weighing the options.

 

[ccpsych16]

I’ve been looking into this and seeing what other local/small businesses do. Many have a lawyer as registered agent, especially the ones that operate out of homes like I plan to (e.g., remote businesses or mobile ones with no physical address). Not sure what else those businesses use the lawyer for, but seems to be an included part of the package to have a healthcare lawyer review consent forms, financial disclosures, etc.