In its infancy, the HITECH EHR Incentive program, better known as "Meaningful Use," had the best intentions to improve the overall quality of patient care by attempting to eliminate the isolated paper record infrastructure in place at medical practices. Now that a majority of the medical community has gone to EHRs, the next problem is to get the diverse catalog of certified applications connected to continue the advancement of actionable data that can promote improved clinical outcomes. Yet, here we are, over 4 years later, and the momentum of the program seems to be waning rather quickly. In a story published in November, 2014 on Fierce EMR, it was stated that under 12,000 eligible professionals (EP) have successfully attested for Meaningful Use stage 2 (MUS2). Without getting into all the stats and numbers on where that ranks with the previous years of the program, let's just say that it appears that most EPs are going to take advantage of the flexibility rule published by CMS in October, and thus, not report on MUS2 for their 2014 reporting period. EPs have until the end of this month to get that participation numbers back where it should be regardless of the stage.
By offering EPs a safety net, next to no EPs had to meet MUS2 in 2014, and thus the credibility of the program took a serious blow. Not only did it reward the unprepared, but it effectively killed the momentum of the program. I understand why the flexibility rule was drafted and passed, and I understand the challenges of implementing upgraded technologies and workflows for compliance to MUS2, but I really do not expect practices to be anymore prepared to meet the objectives in a few weeks when a full year's worth of reporting is required. Groups like CHIME have already got the ball rolling on fighting the full year reporting period this year by calling for a 90 day reporting period, but who knows if that will get the same treatment as 2014's rule changes.
The bottom line, and unfortunate lesson, in all of this is that CMS just may cave when there is enough pressure and resistance to the advanced stages of Meaningful Use. Just like the year long delay in ICD-10, the medical community can use its collective power to protest with well written complaints and delay much needed advancements until another year has gone by and nothing has changed. It is my opinion that a minority perspective should be considered in the medical industry: Only participate in MUS2, IF IT MAKES SENSE!
Options need to be weighed at every medical practice to determine if taking the steps necessary to meet MUS2 are worth it in terms of finance and relevance. If an EP successfully attested starting in 2011, the incentive for a full year's compliant reporting in 2015 is only $1960 (don't forget to factor in the 2% payment reduction thanks to sequestration). In addition to the incentives becoming increasingly smaller, practices will also have to factor in the 1% reductions in Medicare reimbursements that will also come from non-compliance to MUS2 and eventually stage 3. The maximum annual adjustment, or penalty, for not meeting meaningful use is 1% which is capped at an overall maximum reduction of 5%. Practices need to do the math now and see if the costs for compliance are greater than the penalties.
Once EPs make the right call to participate or not, there should be no question that the focus should be meeting the rules currently in place. If the EHR incentive program makes any further changes to its rules or compliance standards, it should be in redefining who is an EP. CMS should not expect specialists to jump through hoops to maintain their current Medicare reimbursements, they should work to impose specialty driven compliance measures that are completely relevant to the EP. It is not relevant for Orthopaedic doctors to exempt out of immunization registry objectives every year. I'm not offering any alternatives. That is for much more qualified and clinical minds to decide. My focus is, and has always been, on preparing my clients for the rules that are in place. If and when CMS decides to change the rules again in 2015, I will scramble with the rest of the medical community to find clarity in already muddied waters. By finding a new meaning and a new focus, perhaps CMS can save the program and continue to guide the medical industry on the path to true interoperability and better patient care.