Starbug,
there probably won't be MU issues b/c each "elligible provider (or EP)" is allowed to receive the money. So whether 9 offices each has 1 doc and 9 separate EMR's or if there is 3 offices each with 3 docs sharing 1 EMR, it's 9 EP's however you slice it. So the same total payout to Medicare. You might have difficulty sustaining audit with them, but could probably get through it okay. It's worth studying the guts of the MU rules however. You certainly don't want to get in a pissing contest with Medicare, they have a tendency to win there disputes.

HOWEVER CAUTION: I've read about this issue in the journal Medical Economics. A subscriber wrote to the legal staff about this exact issue. They were advised of the following:
1) separate tax entities sharing the same office can give the appearance they are one office, and thus open themselves to legal risk as "covering physicians" if a law suit involved not just a physician but also "the office." Since there is one receptionist for multiple different practices it gives appearance of it being one unified office.
2) different practices sharing one EMR also raised the exact same issue about not really being separate entities, and thus opens up other providers to legal risk how are not actually in the same practice as the one being sued.

So I'm quite certain you guys must have had your attorney look at this as well as your malpractice carrier, but I just wanted to advise there may be increased risk depending upon your state rules.

Just a question (please don't misinterpret, I'm not making any judgements by asking this): is AC so expensive that each different practice can't have their own user license and their own instance of AC running? Or is the infrastructure you are sharing (server, computer network) that is the issue for cost savings?


Adam Lauer, DO (solo FP)
Twin City Family Medicine
Brewer, ME