Comment: Prioritize billing logic when implementing an EMR, not clinical workflow alone

# The central point

Claire Morgan's comment restates Jonathan Bush's argument: treat the electronic medical record (EMR) as a billing tool as well as a clinical record. Many practices set up clinical workflows first and add revenue cycle management (RCM) later. That sequence commonly produces higher denial rates and missed incentive payments.

# Why billing-first matters

Claims succeed when clinical documentation maps to billing logic and payer rules. If those rules are bolted on after clinicians adopt an EMR, documentation gaps and incorrect coding show up only once claims are submitted. By that point the practice faces denials, rework, delayed payments, and lost bonus money tied to programs such as Meaningful Use.

# Practical implications for practices

• Configure EMR templates and workflows to capture the specific data elements payers require for coding and incentive programs. Include documentation prompts that align with billing rules.
• Make revenue cycle workflows part of the EMR rollout plan rather than an add-on project after go-live. That avoids retrofitting clinical documentation to billing retrospectively.
• Treat revenue capture and sustainability as operational priorities alongside quality. If documentation does not support reimbursement, the practice risks financial instability despite clinical gains.

# How athenahealth's approach is used as an example

# Consequences of ignoring billing during EMR implementation

Failing to align EMR documentation with billing requirements leads to common operational problems:

• Rising claim denial rates that increase accounts receivable days and staff workload.
• Missed incentive payments tied to attestation because clinical records lack the elements required for demonstration.
• Additional downstream project costs to retrofit templates, retrain clinicians, and rework historical documentation.

# Action checklist for a billing-first EMR rollout

• During vendor selection and configuration, demand clarity on how the EMR supports billing rules and incentive program attestation.
• Map clinical templates to CPT/ICD/quality measure requirements before clinicians start using the system.

# Bottom line

If a practice wants the financial benefits tied to EMR adoption, it must plan the EMR around revenue cycle needs as much as clinical usability. Embedding billing logic into the clinical workflow at implementation reduces denials and increases the likelihood that incentive payments will be realized.