Medicare penalties for failure to demonstrate meaningful use are a little more than 30 months away (January 2015). Considering the time required to select an EHR, implement it, and then demonstrate MU for at least 90 days, time may be getting short for providers who have not already begun the process. A recent Health Affairs article seems to support this sense of urgency.
The article, Most Physicians Were Eligible for Federal Incentives in 2011, but Few Had EHR Systems That Met Meaningful-Use Criteria, by Hsiao C, Decker SL, Hing E, and Sisk JE, reports on 2011 National Ambulatory Medical Care Survey data. The abstract contains this interesting statement concerning providers’ preparedness for meeting meaningful use:
In our analysis of a 2011 nationally representative survey of office-based physicians, we found that 91 percent of physicians were eligible for Medicare or Medicaid meaningful-use incentives. About half of all physicians intended to apply. However, only 11 percent both intended to apply for the incentives and had electronic health record systems with the capabilities to support even two-thirds of the stage 1 core objectives required for meaningful use. Although the federal Medicare incentives will be available through 2016, and Medicaid incentives through 2021, widespread gaps in readiness throughout the states illustrate the challenges physicians face in meeting the federal schedule for the incentive programs.
If my understanding of the methods described by the authors is accurate, readiness was assessed only among physicians who already had EHRs in place. Assuming this is the correct interpretation, it means that nearly 90% of office-based clinicians who have EHRs installed, and who wish to participate in the incentive programs, will have to replace or upgrade their systems in order to receive incentives or avoid Medicare penalties. What are the implications of this intention-readiness gap? Does it represent a strategic opportunity for the ONC to promote its meaningful use-based vision of EHR adoption?
Eligible professionals (EPs) who wish to apply for incentives or avoid penalties must do the following: upgrade or buy a new EHR, redesign workflows, and then, in the case of Medicare EPs, demonstrate MU. This is a daunting path for any clinician. Medicaid EPs might have a somewhat easier go of it because they may receive the full initial incentive payment without demonstrating MU and they are not facing penalties in 2015. However, Medicare EPs must pay out-of-pocket for upgrades/new systems and then demonstrate MU for at least 90 days before receiving a payment.
Given that all EPs under discussion already have electronic systems in place, it seems that they should be rewarded for being ahead of the curve, and not punished for the lack MU features in their systems. Keeping in mind that one can catch more flies with honey than with vinegar, it might be a good strategy for the ONC to grant special status to this group of providers.
One approach might be to grant Medicare providers who had EHRs in place as of January 2009, a full, first-year incentive payment without requiring them to meet MU until their second year in the program. Since they have already demonstrated a willingness to adopt HIT, allow them to stay at the vanguard of EHR adoption by providing funds that can be used for upgrades or replacements prior to showing MU. Medicaid allows for this approach, why not extend it to these early-adopter Medicare EPs? Providers who installed EHRs before ARRA are the poster children for EHR adoption. Why put them on the hot seat with looming Medicare penalties?
The ONC can treat these providers in a business-as-usual fashion and prove, once more, the truth of the old saying about pioneers and arrows. Conversely, the intention-readiness gap problem can be turned into an MU program opportunity with a little out-of-the-box thinking. In doing so, the ONC could create a win-win for all involved.