What’s wrong with the Meaningful Use program?
Meaningful Use is changing. Would it simply role into the MIPS program with nothing changing except its name, or would there be more meaningful changes? At the moment even CMS can’t or won’t tell you going by their recent U turns on the subject. The only thing we know for certain is that the program and its regulations are alive and kicking, till further notice.
Here is a list of thing we believe are wrong with Meaningful Use and should be addressed moving forward.
An aggressive EHR technology upgrade
EHR vendors have many challenges ahead of them, because beginning in 2018, all healthcare providers will be required to use 2015 Edition certified EHR technology. With only 24 months lead time, it is doubtful that all stakeholders (Office of the National Coordinator for Health IT, testing and certification bodies, vendors and providers, etc.) will be up to speed in time.
Another consideration with this timeline is that physicians must maintain performance on meaningful use measures while undergoing an upgrade. Challenging? You bet. Impossible? Quite possibly.
Stage 3’s API requirement a relief for patients but a real pain for docs
Stage 3 requires providers enable certified API’s so that patients can have free access to their medical records without any limitation. While this is great for patients, who will be able to access this data using any application that meets security requirements and technical specifications, it means that providers will need to scale their infrastructure accordingly, not an easy undertaking. On top of this, docs must also find the time to educate their patients about how to gain access through the API while sharing and maintaining a list of all apps using the API.
eCQM reporting requirements
Beginning in 2018, CMS will no longer accept electronic clinical quality measure information via attestation in order to align quality reporting requirements across numerous programs. Although CMS has allowed electronic submissions in the past, most physicians have opted out due to various challenges such as difficulty mapping and limited allocation of resources. We will have to wait and see whether or not CMS will identify CQMs that are amenable to physicians’ specialty and practice as well as allow multiple versions of electronic specifications.
The transition to merit-based incentive payment system
Eventually the meaningful use program will become a component of the Merit-based Incentive Payment System (MIPS). It’s important for physicians to pay attention to MIPS because meaningful use contributes ¼ of their total MIPS performance score. It is this MIPS score that will determine the payment adjustment for Medicare EPs. So, although the Medicare incentive payments will go away starting in 2016, physicians will still be able to gain “incentives” through higher reimbursements based on their MIPS score.
Many in the community are already speculating that MU3’s thresholds are simply not achievable in today’s marketplace. For instance:
- CMS is calling for more than 25% of patients to “actively engage” with their electronic records.
- Physicians must send a secure message to more than 35% of their patients using their EHRs secure messaging function. It is acceptable if they also respond to a secure message that is sent by a patient.
- For more than 15% of patients seen, patient-generated data from a nonclinical setting must be uploaded and incorporated into the EHR system.
- Physicians must use their EHRs to create a summary of care and share it with other providers for more than 50% of transitions of care and referrals.
- In more than 80% of these transitions of care, the physician is required to perform a “clinical information reconciliation” that includes not only medications and allergies, but also problem lists.
Recommendations for fixing the system
Many in the industry feel Meaningful Use Stage 3 is no better than its predecessors. John Halamka, CIO of Beth Israel Deaconess Medical Center in Boston, has been outspoken in his belief that many of MU3s thresholds are out of reach. “If Meaningful Use was converted from a stimulus/penalty program to a pay-for-performance program without penalty, then these thresholds would be more appropriate,” Halamka said.
He also points out that the certification rule released by the Office of the National Coordinator for Health IT is “too broad in scope,” criticizing an attempt to cover all health information technology. He worries that this increase in scope could create market confusion, vendor burden, and a general lack of focus that could inevitably impede real progress.
Jeff Smith, vice president of public policy at the College of Healthcare Information Management Executives, believes the 2018 deadline may inhibit widespread compliance by physicians. “There are a percentage of providers who have not engaged with the program yet, or who have only started to engage with the program, who are probably looking at what’s being required in three years with a fair amount of disbelief,” Smith said.
At the end of the day, there doesn’t seem to be all that much of a difference between MU1, 2 and 3. While it may seem CMS has only decided to require eight objectives, physicians will still be required to be successful with 18 measures, which has caused many providers to feel a sense of dread and hopelessness.
Linda Fishman, senior vice president of public policy analysis and development at the American Hospital Association, shares these sentiments, “It is difficult to understand the rush to raise the bar yet again, when only 35 percent of hospitals and a small fraction of physicians have met the Stage 2 requirements.”
Agreeing that there is something wrong with the program is the first welcome step taken by the CMS. Now as we move towards evolving the Meaningful Use program we hope that CMS would be taking the above into account.