CMS proposed rule change, a little too late

June 14, 2014 in Medical Technology

As the person responsible for the management of the hosted electronic health record and practice management system for 200 private and employed providers affiliated with a health system in Massachusetts, I couldn’t believe it when I saw new CMS proposed rule modifying the EHR Incentive Program.

I understand that it was meant to provide relief to physicians having trouble upgrading to a 2014 certified EHR or getting the system setup to meet the measures, however the proposed rule itself and the timing of the rule is extremely disheartening for me.  

At this point, we are stuck between our EHR system and the EHR Incentive Program.  As an organization that does a lot of strategic planning and takes deadlines seriously, this announcement is a little late to provide us any relief. We are too far down the path for Meaningful Use Stage 2 to turn back to Stage 1.  There is a lot of work to go forward, but there is almost as much to go back.  By the time the proposed rule gets through the commenting period and finalized, it will really be too late.

We signed up to be an early adopter for the MU Stage 2 and ICD-10 EHR release.   I wanted to be sure we were upgrading as early as possible, to ensure the system would be ready for the providers.   The goal was for the physicians to have the opportunity to start MU Stage 2 on July 1, so they wouldn’t have to worry about Meaningful Use when the ICD-10 deadline hit on 10/1/2014 (silly me!).   

We decided not to renew a contract with a consulting firm that ended in January of 2014.  This company calculated our core and menu measures and provided each physician with a monthly MU dashboard.  Instead, we chose to go with a new web based reporting tool that utilized the data calculated by the certified EHR vendor.   That choice was complicated because our EHR vendor changed their Meaningful Use reporting methodology, including the way they pull the clinical quality measure data.   The new methodology is only compatible with the 2014 certified version of the EHR system.  In addition, the 2014 certified EHR release has been delayed significantly.  We worked through all the delays and now our upgrade is scheduled for the end of May (yes, less than 2 weeks away!).  We are already training end-users and providers on the new release, we are ready to go.

Even if we wanted to cancel the upgrade and stay on the 2011 certified version it would be complicated.   There would be a significant effort to figure out how we could even obtain the clinical quality measure and core/menu data for the providers to use in their attestation. Also our 2011 Certified EHR is built with the original Stage 1 measures, so we would have additional effort to build out either the 2013 or 2014 Stage 2 measures, not to mention that we have been working on this upgrade for months and months and stopping now would completely demoralize the team. 

I started to think about a proposed rule that would actually help us and here is what I came up with:

 “A provider, who is scheduled to begin Meaningful Use Stage 2 in 2014, must meet 90 days of Stage 2 Meaningful Use during a calendar quarter, sometime between January 1, 2014 and December 31, 2015.  There will be no penalty in 2016 if a provider starts their first 90 day reporting period in 2015.  The physician will receive the next incentive payment as scheduled when they complete their stage 2 attestation.  Clinical Quality Measure data will only need to be reported for a 90 day EHR reporting period, which can occur during any calendar quarter between January 1, 2014 and December 31, 2015.”

After having witnessed both the Meaningful Use date and the ICD-10 date get changed a few times, I have zero confidence that any physician will ever be held accountable for either of these items.  The dates will continue to be changed.   While I will hang my hat and continue to be proud of our achievement that over 90% of our physicians achieved Stage 1 in 2011 or 2012 and earned incentive dollars, I continue to shake my head at the timing of these things that are supposed to provide relief, because in this case it will not help.  So, we continue the march forward to the finish line and our goal of ensuring the system is ready for our physicians to meet 90 days of Stage 2 starting on October 1, 2014, expecting an announcement at any moment of yet another new program meant to reduce the cost of healthcare! 

File under:  Fool me once, shame on you, fool me twice shame on me!

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