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Greenway Health has agreed to pay $57.25 million to the federal government to settle allegations that the company misrepresented the capabilities of its records software. This is a tale that should give all healthcare companies a reason to pause.

The Greenway case highlights the use of non-standard or local vocabulary in the software. Healthcare Information Management sits on the background of a controlled vocabulary.

In a statement from Assistant Attorney General Jody Hunt:

“Electronic health records are critically important to the healthcare decision process, and both patients and providers rely on these technologies to safely and accurately record and transmit vital health information.


This resolution demonstrates our continued commitment to pursue EHR vendors who misrepresent the capabilities of their products, and our determination to promote public health while holding accountable those who seek to abuse the government’s trust.”

The DOJ’s case is based on the premise that Greenway falsely obtained 2014 Edition certification for its Prime Suite software as a result of concealing from its certifying entity that the product did not fully comply with requirements.

“Among other things, Greenway’s product did not incorporate the standardized clinical terminology necessary to ensure the reciprocal flow of information concerning patients and the accuracy of electronic prescriptions. Greenway accomplished its deception by modifying its test-run software to deceive the company hired to certify Prime Suite into believing that it could use the requisite clinical vocabulary.”

This is complicated by the allegation that Greenway Health was aware that an earlier version of the product—which was certified to 2011 Edition criteria—did not correctly calculate the percentage of office visits for which its users distributed clinical summaries.

As a result, DOJ alleges that certain Prime Suite users falsely attested that they were eligible for EHR incentive payments from the government.

“Greenway refrained from rectifying this error in order to ensure that its users would receive incentive payments. As a result, numerous users of this earlier version of Prime Suite falsely attested that they were eligible for EHR incentive payments when, in fact, they had not met all necessary use requirements.


Finally, the government also alleged that Greenway violated the Anti-Kickback Statute by paying money and incentives to its client providers to recommend Prime Suite to prospective new customers.”

When a company chooses to use non-standard terms for ‘Ease of Adoption by User’ rather than the established standards, it risks a misunderstanding that can have horrifying consequences. Additionally, its critical that firms that develop software internally, rather than using standardized and vended products take a critical look at how testing can obscure a wrong answer.

Automated testing, an Agile approach and careful understanding of the legal impacts of clinical terminology are now watchwords for us all.