Meaningful Use (MU) mania has been afflicting the healthcare industry for some time now — serving, some would argue, as a source of both focused progress and unintentional distraction.
Healthcare providers seem to be overwhelmed trying to decipher MU requirements, while electronic health record (EHR) vendors appear equally busy trying to help their clients meet their MU needs. As a result, some might say that real innovation has stopped, or at least slowed down.
As you may or may not know, the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator (ONC) recently proposed giving hospitals, doctors and vendors more time to upgrade their EHR systems to the national standards released in September 2012. While this proposal gives some parties the time they need to overcome difficulties, it also means patients will have to wait longer for better access to health information and better care. It is true, however, that the delay would give all providers additional time to implement Stage 2 effectively. It also presents an opportunity to reflect upon and develop all the critical criteria and standards pending in Stage 3 for better outcomes.
The Medicare and Medicaid EHR Incentive Programs offer financial payments to healthcare providers who can demonstrate they are making “meaningful use” of certified EHR technology by meeting certain objectives ranging from recording patient information as structured data to exchanging summary care records with other providers.
The reality, of course, is that MU is intended to be a shot in the arm of healthcare IT as it pushes for innovation in interoperability, adherence to data standards, and clinical data exchange.1 The intent is sufficiently ambitious and well meaning. MU itself is divided into three stages:
Meaningful Use payments are starting to flow; encouraged by the rewards of their efforts in Stage 1, many providers are focusing intently on meeting Stage 2 requirements. According to the latest CMS data, the agency has made $22.9 billion2 in MU incentive payments to hospitals and professionals. Of this total, $14.3 billion has gone to eligible hospitals and almost $8.6 billion to other health care professionals.
Most radiologists are defined as “eligible professionals” (EPs) under the incentive programs, and in fact the ACR estimates that 90 percent of radiologists are eligible for the incentive payments.
To participate in the program, radiologists must have access to and be using certified EHR technology (CEHRT). CEHRT consists of 2014 Edition certified products used either singly or in combination. Consequently, it is not sufficient for radiologists to show they are ‘meaningfully using’ EHR technology—certification of products is important. To verify certification, radiologists must use the shopping cart-like functionality on the 2014 Edition section of the ONC’s Certified Health IT Product List (CHPL) website3 to generate an “EHR certification ID.”
Awareness of the EHR reporting period is also critical. For radiologists whose first year of participation is 2014, the EHR reporting period can be any consecutive 90-day period within the calendar year to obtain the incentive payments. However, first-year participants must begin by July 1 and complete their attestation by Oct. 1 to avoid penalties in 2015. For prior-year participants, the EHR reporting period in 2014 can be any quarter of the year.
This carrot-and-stick approach is soon poised to start flexing its muscle with the approach of penalties—payment reductions for noncompliance that begin in 2015. To avoid these, eligible radiologists must either begin participating on time as described above, or obtain one of the temporary “significant hardship exception” options. CMS can grant such exceptions on an annual basis for up to five years.4 Exceptions that require manual applications, however, must be submitted by July 1 of the year before the penalty year. If you have not done this already, you may have missed the boat.
CMS data2 show that more than 371,000 eligible hospitals and other professionals have received incentive payments thus far. According to one report,5 this represents more than 90 percent of the 5,011 estimated eligible hospitals; and nearly 70 percent of the estimated 527,200 eligible professionals. This suggests a slowing down in the number of new participants joining the MU program. Experts say CMS could have difficulty getting the remaining eligible providers, including some 9 percent of hospitals and 30 percent of eligible professionals, to join.
Indeed, the American Medical Association warns that the current MU approach in “not working.”6 In a May 8 letter, AMA Executive Vice President and CEO James Madara warned CMS Administrator Marilyn Tavenner and National Coordinator for Health IT Karen DeSalvo of dire consequences unless the EHR incentive program is substantially modified. Unless major modifications are adopted to add flexibility to the program, Dr. Madara said, more physicians will drop out, patients will face disruptions and inefficiencies, thousands of physicians will incur financial penalties, and outcomes-based delivery models will be jeopardized. As Madara put it, “Expecting every physician to meet the same set of requirements despite varying specialties and patient populations is an ill-defined approach that is not working.”
Even as folks grapple with MU stages 1 and 2, requirements are already being drawn up for MU Stage 3, which is likely to follow the same format as its predecessors, with a divide between core (mandatory) and menu (optional) requirements, continuations of stage 1 and stage 2 requirements, and the addition of some new ones. Stage 3 could also see a major push to include access to imaging results and images directly through the certified EHR technology as a core requirement. Stage 3 ideally should encourage healthcare providers to give patients at least the option to have their images and related information (such as radiation dose) transmitted to other EHR systems. Image-enabling the health information exchange should be a priority driven by clinical needs, technology readiness and regulatory incentives – with the aim again to reduce inappropriate utilization while controlling radiation dose exposure and decreasing waste and associated costs.
Clearly, where you stand in your MU journey is often a factor of what is most important to you. While MU offers many benefits, many radiologists would not disagree that it is also important not to be caught up in the frenzy and chaos of MU implementation without balancing internal needs, priorities, and resources. Overall, MU sets the stage for better-coordinated patient care. Embracing digital EHRs should be a strategy regardless of MU.
Interoperability can only allow for a more patient-centric approach to care – one that promises better quality and improved outcomes.