With the debate on whether to pause the EHR Incentive Program beginning to heat up, I wanted to dissect the various issues involved as this concept actually has distinct components. I have written about the idea of “pausing Meaningful Use” and the focus now being given to the topic by the Senate Finance Committee. Many associations, academies, and organizations have also joined a chorus calling for delay in certain aspects of the program.
- Allow providers at Stage 1 to meet the requirements using either the 2011 certified Edition EHR, or the 2014 certified Edition EHR.
- Establish a 90-day reporting period for the first year of each new stage of Meaningful Use for all providers, similar to what was done for Stage 1.
- Offer greater flexibility to providers in meeting Stage 2 to ameliorate the “all or nothing” problem, and recognize that the level of change in Stage 2 will take time to accomplish.
- Extend each stage of Meaningful Use to no less than three years for all providers.
The College of Healthcare Information Management Executives (CHIME) called for a one-year pushback of the Stage 2 Meaningful Use deadline and defended the efficacy of the federal incentive program. In a May 6, 2013, letter addressed to six Senators who have recently voiced concerns over the current state of health IT, CHIME CEO Russell P. Branzell and CHIME Board Chair George T. Hickman wrote that a one-year extension of Stage 2 would “maximize the opportunity of program success.”
The American Academy of Family Physicians (AAFP) has also appealed to CMS to delay the Meaningful Use Stage 2 timeline by one year. AAFP Board Chair Glen Stream, MD, wrote in a letter sent Aug. 7, 2013, that while the AAFP supports family physicians’ adoption of EHRs and the patient-centered medical home model of care, they’re concerned about both the regulatory expectations of Meaningful Use Stage 2 and the timeframe for physician compliance.
“2014 brings a perfect storm of regulatory compliance issues for family physicians that, we fear, may derail health information technology adoption and substantially interfere with our shared progress toward achieving better care for patients, better health for communities and lower costs through improvements to the health care system,” said Stream.
Healthcare Information and Management Systems Society (HIMSS) then sent a letter Aug. 15, 2013, calling for some changes to the timeline for Stage 2 Meaningful Use. In the letter, HIMSS emphasized the need to stay the course for this next phase of the EHR Incentive Programs, while also asking for changes to the Stage 2 attestation period.
“Achieving optimal results from Meaningful Use Stage 2 can positively impact the effectiveness of national healthcare transformation,” wrote HIMSS. “Many are, indeed, ready for the next Stage. For these reasons, HIMSS supports maintaining the current Stage 2 Meaningful Use launch schedule.”
HIMSS recommended that Year 1 of the Meaningful Use Stage 2 attestation period extend through April 2015 and June 2015 for EHs and EPs, respectively. This would allow 18 months in which EHs and EPs can attest to quarterly Meaningful Use requirements.
Then, on Aug. 21, 2013, the Medical Group Management Association (MGMA) sent a letter urging HHS to implement an indefinite moratorium on penalties imposed on physicians who have completed Stage 1 of the Meaningful Use program. In the letter, Susan Turney, president and CEO of MGMA, said that there are only 75 products and 21 EHR systems that currently meet Stage 2 criteria, compared with more than 2,200 products and nearly 1,400 EHRs that qualify for Stage 1 criteria.
The MGMA asked for an extension of the reporting period for Stage 1 incentives for providers whose EHRs have not been re-certified by January 2015 to allow additional flexibility in some Stage 2 reporting requirements.
So what is likely to happen?
While I think it is very important that healthcare organizations and providers do not count on any delay or changes, but prepare for plans to proceed under the current regulatory framework, I think it is very likely that CMS and ONC will respond to the general outcry with some limited and reasonable changes. The departure of Farzad Mostashari and a new National Coordinator being named might be good timing for a few changes.
First, they could extend the penalty phase from six months to a year to give providers a chance to upgrade to 2014 Edition Certified EHR technology. The Certified Health IT Product List (CHPL), which provides the authoritative and comprehensive listing of Complete Electronic Health Records (EHRs) and EHR Modules that have been tested and certified under the ONC HIT Certification Program to the 2014 Edition, show only a handful of inpatient systems have achieved Complete EHR certification to the 2014 Edition.
What will organizations do in 2014 if their vendor is unable to gain certification to the 2014 Edition?
There are likely to be vendors that were previously Complete EHR certified, but in 2014 will only be capable of obtaining modular certification. This would require purchasing additional certified modules.
There is a great deal of misunderstanding in the marketplace around Stage 1 and Stage 2 in terms of certification. There is no Stage 1 or Stage 2 certification. There is only 2011 Edition Certified EHR Technology (CEHRT) and 2014 Edition certifications. Anyone attesting in 2014 must be using 2014 CEHRT no matter what stage of the program they are in – the current certifications to the 2011 Edition expire this year. So everyone in the program must upgrade over the next year. This is why there is only a 90-day reporting period for 2014 no matter what stage of the program to which you are attesting.
Another area that CMS and the ONC could tweak for 2014 is the arrangement of core set and menu set objectives. Moving some core set objectives to the menu set, while keeping a strong focus on interoperability and patient engagement, could allow providers some much needed flexibility. I am not sure that this is an option they would even consider, but I think it would be a way of meeting providers where they are and also looking out for the little guy.
Finally, I think the idea of lengthening the attestation period to 18 months has merit. HIMSS has a good suggestion that Year 1 of the Meaningful Use Stage 2 attestation period extend through April 2015 and June 2015 for EHs and EPs, respectively. I think it would also be good for Stage 1 attestations to be similarly extended, with the penalties obviously pushed out at least that far. This would allow the necessary upgrades to take place at a more measured pace and ensure that things are done safely.
One thing I hope does not happen is that any standards and certification criteria get watered down. EHR vendors have had record sales and profits and it would actually be good for the number of certified products to be culled. However, healthcare providers are going to need time to allow the market to react and adopt certified systems and modules. I think providing even greater flexibility in 2014 can help make Meaningful Use truly meaningful.
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