Legal or not, EMR donations still chancy


It's always nice to be out from under the white-hot scrutiny of the IRS, so it's great that the agency has joined HHS in making physician EMR donations safe for non-profit hospitals--but are such donations smart strategy? Maybe, maybe not. 

To establish a collaborative EMR implementation between a hospital and its hundreds (or thousands) of affiliated practices, I believe the following would be minimum requirements:

  • The hospital has a close relationship with core admitters (perhaps in a small market where competition isn't as brutal).
  • Key affiliated practices are IT-friendly, yet haven't adopted and committed to an EMR of their own.
  • The hospital has enough IT staffers to offer free support to physicians as the donated EMR falls into place.
  • Both the medical practices and hospitals are prepared to absorb major changes in their work flow, and resolve conflicts patiently over a year or more.
  • The hospital finds a vendor which is particularly skilled at managing implementation across differing technical environments, including varied operating systems and access devices (including multiple handheld/wireless devices).
  • Physicians are comfortable with all of these changes, and aren't prone to shifting admissions elsewhere to avoid engaging with new technologies.

Even in this more-or-less ideal situation, some critical issues remain. For example, I still wonder whether physicians will actually use externally-donated EMRs for the bulk of their work, even if they're delivered with a bouquet of flowers. I also wonder whether a hospital can and should build a key part of their long-term IT strategy around what physicians outside of their organizations will agree to adopt. After all, tailoring your development strategy to meet the needs of practices you neither own nor manage is a significant risk.

What I'm getting at here, I guess, is that the IRS may have removed an important obstacle to handing out an EMR system--but they haven't made rollouts, integration or achieving strong user adoption any easier. That problem, for better or worse, is still in your hands. - Anne