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03/20/2012 6:59 PM
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We are three independent doctors who have a practice "overhead sharing arrangement" but otherwise have no legal ties etc. We need to keep everything else seperate as we have different malpractice carriers etc and are told to never have any piece of paper with all of our names on it, so no one thinks we are a " legal entity or group". I went on AC first and just put my name as " the practice name". Now another of the doctors is ready to sign up but AC says she either has to set up a seperate AC program on the server or we have to have her under my acct which causes a problem when she wants to send a letter etc and it has my name on the letter head. If we put both our names as stated above it implies partners etc. Any suggestions on a work around? I guess we could just call the practice " DOCTORS OFFICE" or " DR A and DR B legally independent practices", but those aren't very attractive names.
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This question comes up about every two to three months, and it simply can't be done. Each AC EMR must have one Tax I.D. number.
Plus, you get into huge HIPAA and confidentiality issues as all of your patients' charts will be in the same EMR. With paper charts it isn't so much a problem putting them in the same rack, but there are issues when all of the patient names are in the Patient List, etc. If you do a search on COPD, you will also see all of her patients with COPD. I don't even know how it would affect MU. I do know that if someone else not in my practice changed the preferences so that there were med interactions at the highest level, that would be an issue. Automatic refills would be a problem especially if you were to refill one of her patient's medications. Wouldn't the violate the problem of having your name on the same piece of paper or electronic display?
For the price, you are simply much better off with both of you have separate EMRs, with their own patients, very clean, with your own letterhead, etc.
Bert Pediatrics Brewer, Maine
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Starbug,
I agree with Bert, we are a group of 8 docs with a limited liability partnership. We all utilize lytec 11 for our practice management, but now 5 of us are utilizing AC, one e-clinical and two soon go with AC--but you will all have to purchase AC separately and each one use his own tax ID--very clean as Bert says and works great!!!! jimmie
jimmie internal medicine gab.com/jimmievanagon
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We will have three seperate docs. I'm a computer idiot so help me out. Does this mean each computer would have 3 seperately labeled AC one for each doctor. Front office would have all three opened to work with patients and I would only need my version open unless I'm seeing one of their patients. Any other unforseen inconveniences? Is this just as simple to install and run as when they put me on the computer or does it get more confusing the more practitioners you add?
Thanks
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Starbug, I don't think I am following you. You can have one AC program on each computer and on the front desk and use 50 doctors and see whosever patients you wish. But, what I thought you said was that you are three doctors only in the same office, because you are sharing overhead. You are not bound together as a practice or connected in any way. If that is the case, then there is no difference between the way you would set it up if you are in one office as if you were ten miles apart. Each doctor (if they are not in the same practice) would have to practice by themselves using a separate Amazing Charts. Yes, it could be done. You could have three computers in each room or use virtual machines, two on each computer so you could run three ACs on each. (You can't run two AC programs on one computer at the same time). They can't even be installed. I would only need my version open unless I'm seeing one of their patients. Now this is where it gets interesting. On one hand I am led to believe you are three completely different practices. But, then you say you will be seeing "their" patients. In order for us to give a good answer, I think we need a clearer picture. If everyone is in the same building with the same name office and the same Tax ID, then you can use one AC. If not, then you will need three different ACs. Where I think the confusion is, I think you are asking can we all use the same Amazing Charts. It would still be three licenses either way. You can if everyone is in the same group. You can't put three practices into one database. If you download AC, and fill out your practice demographics, it is going to ask you for name of practice, Tax ID, etc. I don't see how you can get around that. But, given the complexity of the situation, before you give up based on Jimmie and I's advice, I would call AC and see what they say.
Bert Pediatrics Brewer, Maine
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Beg to differ with some of the responses above.
I have an expense sharing agreement with another doctor. We share staff, office space, and some expenses but the practices are otherwise independent with separate Tax IDs etc.
We both use the same installation of AC. Each of us have our own tax ID number in AC and we can generate separate reports for things like meaningful use. The staff at AC suggested this arrangement and it was very simple to add my "office associate" as a new user to AC when she joined me a few months ago. AC sorts things like prescription refills by provider which is assigned under the demographic tab.
The one downside is the Letterhead in AC. It now says "Internal Medicine" at the top instead of either of our names. That's a little lame but not intolerable.
I think the HIPPA concern is a non-issue. Our current setup is no different than two doctors who share office space being able to go over and grab another paper chart off the shelf and read it. Or picking up a chart in the hospital for a patient who is not your own. You just don't do it.
Mike
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We have 2 different practices here, both using totally separate AC servers. There are 2 different server computers. Each client computer *can* access both databases if we run another virtual OS, but we choose not to do that - it's too much of a hassle. Since 1 doctor is part time, we just have 2 client computers for his practice - one for his staff and one for the doctor. These 2 client computers only access his database and the other client computers we have access only the other practice.
I can't imaging having to do this for 3 full time doctors. Seems like a lot of extra work.
Serene Office Manager General Pediatrics Houston, Texas
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I think the HIPPA concern is a non-issue. Our current setup is no different than two doctors who share office space being able to go over and grab another paper chart off the shelf and read it. Or picking up a chart in the hospital for a patient who is not your own. You just don't do it. There is a HUGE difference. Having two different practices in one database is different. You don't have all of your charts mixed in with that other person's chart. You could never do a search on a medication or other thing unless you squinted your eyes not to look at her patients. When you do backups, you now have both of "your paper charts" all combined into one. You also have all of the names listed in your Patient List. Should you really know all of the patients that go to her practice? I just don't see how it can be HIPAA compliant. We don't have all of the doctor in the other side of the building's paper charts in our rack. That is much different than walking over to their side and grabbing a chart.
Bert Pediatrics Brewer, Maine
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Actually AC does allow you to search medications for just one provider - any report can be run for an individual provider.
I see lists of patients who are not my own every day when I log on to the hospital computer or look up a radiology report in DR - this is not a HIPPA violation. If I open their chart and start digging around, that would be a HIPPA violation. This is true whether two doctors are partners, office mates, or complete strangers.
Finally, I am not sure what you mean by the charts being "mixed together". If we ever separate our office practices, I suppose we will each take a copy of the database and delete the patients that don't belong to us.
Mike
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Mike,
You bring up interesting counterpoints and some seem they may be valid. I wonder if a patient signs a release when they go into a hospital that their demographics (name) will be on a computer that other caregivers may see. Do you tell your patients that Drs. B and C. can see that that they are in your practice. It depends somewhat what your practice is.
Apologize on the search. I guess if you are signed in under your name, you only see those patients? My nurse today brought up the very same patients under her sign-in as I did. Help me out here?
The charts are "mixed together." If, you have a John Aardvark, and she has a Jim Aarrdvark, both charts will be mixed in the same databases. And, there was an entire thread on how someone was going to take a database and take patients out.
Other interesting notes that they should think of. Maybe I am not thinking it through.
1. Entire threads have been devoted to can we delete a note on the wrong person. Answer no. But, at least it is on my patient. What if you chart on the other doctor's patient? You can use an addendum, but that patient who isn't in your practice has a note that was based on a patient from a different practice.
2. Can you do Prescription renewals and Prescription status? I suppose you could choose not to use it. Again, I am just asking.
Bert Pediatrics Brewer, Maine
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I would do virtual machines with each going to a different database.
If you are using Win 7 Pro, one doc would be on the virtual XP machine and the other is on the Win 7 machine. They would have to switch out and it could become an issue if the staff is not careful.
Probably easy with 2, but 3 docs could get confusing. You would need another virtual machine on each station.
Wendell Pediatrician in Chicago
The patient's expectation is that you have all the answers, sometimes they just don't like the answer you have for them
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Agreed. And, "switching" would be as simple as minimizing to the taskbar.
Bert Pediatrics Brewer, Maine
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I'll be honest here. XP Mode is nice. But Windows Virtual PC leaves a lot to be desired. You should get VMWare Player and migrate your XP Mode over. VMWare Player does allow distribution of VMWare Player, just got to fill out a form or you can ignore it. http://www.vmware.com/products/player/player-reseller-registration.html
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I use VMWare, 'cause I like to spend money. Also, with VMs the restores are great. But, I always forget to do a snapshow before a major update or install.
Bert Pediatrics Brewer, Maine
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True. I have VMWare workstation as well. Very good at handling multiple VMs. Snapshots are a life saver when you're making images for deployment. I just finished my generic image yesterday. Barely fits on an 8GB USB Flash Drive/dual layer DVD.
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Mike,
You bring up interesting counterpoints and some seem they may be valid. I wonder if a patient signs a release when they go into a hospital that their demographics (name) will be on a computer that other caregivers may see. Do you tell your patients that Drs. B and C. can see that that they are in your practice. It depends somewhat what your practice is.
Apologize on the search. I guess if you are signed in under your name, you only see those patients? My nurse today brought up the very same patients under her sign-in as I did. Help me out here?
The charts are "mixed together." If, you have a John Aardvark, and she has a Jim Aarrdvark, both charts will be mixed in the same databases. And, there was an entire thread on how someone was going to take a database and take patients out.
Other interesting notes that they should think of. Maybe I am not thinking it through.
1. Entire threads have been devoted to can we delete a note on the wrong person. Answer no. But, at least it is on my patient. What if you chart on the other doctor's patient? You can use an addendum, but that patient who isn't in your practice has a note that was based on a patient from a different practice.
2. Can you do Prescription renewals and Prescription status? I suppose you could choose not to use it. Again, I am just asking. When you create a search/report for patients of a specific doctor in AC you need to add a search criteria for preferred physician (it is in the demographics section of AC). Not to get too philosophical but the meaning if "mixed together" needs to be looked at. I am not sure how sharing a database means charts are mixed together. If the charts can be accessed as individual charts and when you access them you only see one at a time, it doesn't seem like they are mixed together in any meaningful sense. The reality of sharing an office with another doc (or practicing medicine in any setting) is that there are lots of opportunities for HIPAA violations - I don't think using the same installation of AC has changed this in the least compared to how it was when my office associate and I both used paper charts. If the standard of practice was that we had to stamp out all POTENTIAL OPPORTUNITIES to violate HIPAA we would all be paralyzed. Documenting in the wrong patient's chart is a problem regardless of who does the documenting. I wish AC would allow us to fix this problem. Prescription renewals has a "Show mine only" button in the upper right corner so I only have to see my own patient's prescription renewals. The issue of separation of practices some day might be a hassle. Worst case scenario we each take a copy of the database and just inactivate each other's patients I suppose. Not sure if it would be possible to actually purge all of her patients from the Database - I would have to ask AC for help on this if it ever happened.
Mike
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You continue to make valid points, which is good for everyone to see. You have done this a while so that is helpful.
But, you will never convince me that having another doctor's patients in one AC is safe. I think adding information on your patient mistakenly is worse than adding it to yours; maybe a small difference. But, to me, mixing everything together in an electronic database is akin to sharing a fax machine or a chart rack. You certainly wouldn't want to put everyone's patient chart in the same rack, would you?
And, who is Mike? And, I am not referring to you, lol.
Bert Pediatrics Brewer, Maine
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So, just trying to learn. So bear with me.
Under ePrescibing it seems to default to All. You have to quickly tick Mine Only.
Under prescription status, how do you differentiate them?
Would you mind showing me where to indicate which doctor in demographics is that would filter searches?
Bert Pediatrics Brewer, Maine
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Happy to bear with you.
Under e prescribing, once you tick mine only, it always defaults to mine only view.
Under prescription status (a tab our staff uses but I have never clicked on before) it shows all of the patients on one screen and I do see that my office associate prescribed meds for patients. The HIPAA police might not like this but since I hadn't looked at this screen until now, I was probably OK. Since you pointed me at it Bert I may have to name you as an accomplice:)
There is a preferred provider box with a dropdown tab on the demographics page (right below preferred pharmacy box)
Mike
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Ahh, I got fooled on the once ticked, always ticked because of the All, but that is for another filter. Point to Mike.  On the HIPAA police (which I have never seen), I will swear to secrecy. On the preferred provider, I tried it, but it didn't work, but it may be because I didn't prescribe the med (my example) under that provider. I will defer to your experience and give Point Mike. I think we (you mainly) have provided quite a bit of information in our two day debate. lol Final score: Mike 25 Bert 1. I may just have to delete this thread. 
Bert Pediatrics Brewer, Maine
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So how many docs does Mike have on AC and one of the other posts " Jimmy" describes a practice of 8 doctors with different tax IDs all happily using AC any idea how they do it? I sent a note to Jimmy but dont know how often he goes on line.
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I don't know, but given he has posted on:
20, 19, 16, 14, 13, 12, 11, 9, 8, 7, 6, and 5th
I imagine he'll see it.
If you read Mike's initial post, it appears there are two doctors sharing AC.
Bert Pediatrics Brewer, Maine
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you were so right Bert--starbug I sent you a message--jimmie
jimmie internal medicine gab.com/jimmievanagon
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I usually am until Mike took me to the cleaners, lol.
Bert Pediatrics Brewer, Maine
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I appreciate all your help and I suspect your idea is what we will do. We will likely have three sepreate practitioners each independent on one AC. Any MU issues as far as getting paid? i.e program not seperating us out or medicare not paying us unless we all have the same TIN? We share the same front office staff so one person is answering the phone for all three doctors so setting up three seperate computers for each doc wouldn't work and I agree despite Bert's technical concerns I can't believe HIPAA would really care unless you actually leaked or lost info and then it doesn't make a difference whether it was your patient or there's. It sounds like the 8 doc LLC using it actually is 8 totally seperate offices so seperate programs makes sense. We see each others patients on their day off so I may see 1-5 of the other docs patients a day. Anybody else doing this set up other than Mike?
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Starbug,
Good luck with your plan. Just wanted to make clear I was just using HIPAA as a euphemism (right word, lol). I am, as you, about as scare of HIPAA as Monsters, Inc., although some are pretty scary. I was more worried with your patients picking up on it.
Hey, you blew my concerns away, remember? LOL
Bert Pediatrics Brewer, Maine
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Any MU issues as far as getting paid? i.e program not seperating us out or medicare not paying us unless we all have the same TIN? I collected MU last year before adding office associate to A/C so I don't know the answer for sure as to whether there could be a problem with this. However, the Meaningful Use Wizard does generate separate reports by provider, so extracting the data each doctor needs is not a problem.
Mike
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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
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Adam,
From my understanding, AC has no issue with practices sharing AC. The ONLY stipulation is that the name of the practice is the same. Each provider would still need a licese just like in a normal one Tax ID practice.
The issue, if I am reading this correctly is space. The practice may have six exam rooms, and they don't want to have three computers and monitors in each room. Some of us have given solutions such as VM, etc., but I can certainly see where they are coming from.
Bert Pediatrics Brewer, Maine
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