Too steep to climb
Proposed meaningful-use regs ask too much, too soon of providers
As a chief information officer who has long believed in the value and critical need for integrating computers into the delivery of healthcare, I couldn’t be more excited about the developments of the past year.
The federal government sees the digitization of healthcare delivery as an essential foundation for bringing about reform in the nation’s healthcare system. As part of efforts to revitalize the economy, federal legislators have backed additional funding to help providers implement electronic health records in a meaningful way.
Much of the past year has focused on determining exactly what “meaningful use” means when it comes to electronic health records. Dozens of committee members have been helping to define the specifics of what constitutes the meaningful use of these records. The definition, embodied in regulations released Dec. 30, 2009, sets a high bar for providers to clear.
How many healthcare providers will be left behind with this meaningful-use definition? Apparently, if the proposed definition holds, the answer will probably be “the majority.”
The federal government has set forth a laudable vision of “a transformation of our health system to improve healthcare quality, efficiency, equity and safety through the use of health information technology.” This vision is a worthy one, and the current administration points to the potential savings just waiting to be gathered from the widespread deployment of healthcare IT.
There’s just one problem. Successfully implementing technology involves more than just installing technology. The current discussion on meaningful use of healthcare IT hints at this, but it still proposes somewhat of a “black box” reality. It’s the start of a digital transformation, but certainly it doesn’t represent the entire process that needs to occur.
The meaningful-use definitions linked to incentives and penalties for providers include numerous details—if you would like some light reading, peruse the 556-page filing in the Federal Register— but somehow it still feels like sausagemaking.
Certainly “health outcome priorities” and “care goals” are listed along with associated objectives and measures. However, the challenge for IT professionals specifically—and the nation’s healthcare providers in general— lies in getting from A to Z in bringing technology to bear on transforming the system.
I know of no one in healthcare who denies the potential value of these components in the definition of “meaningful use.” What is more difficult to agree on is how to realize them— how to truly arrive at the ultimate destination.
Certainly, only a minority of hospitals, physicians and other care providers will be able to meet meaningful-use targets on the timetables for incentives proposed by the CMS. Even the CMS apparently recognizes this, because they have lowered their projections for the eventual total of stimulus payments—the original estimate of $34 billion may dwindle to as little as $14 billion, according to the CMS.
Setting a high bar for what constitutes meaningful use has the effect of limiting stimulus dollars that will be distributed and could actually drop future costs for federal programs by broadening penalties to the majority of providers who are unable to implement EHRs by 2015. The net result could include more hospitals losing money and the potential for a decline in the number of physicians, even as fewer from future generations are entering the medical profession.
So how do we put this effort back on track to meet the stated goals? If we move politics and hyperbole out of the way, it actually is pretty straightforward: ■ Make all providers eligible for payments, including hospital-based physicians. ■ Ensure full alignment of Medicare and Medicaid criteria for meaningful use. ■ Allow the “90-day qualification period” for meaningful use in the first year of a provider’s efforts, regardless of the calendar year involved. ■ Reduce or eliminate the Medicaid threshold for qualification for incentives. ■ Revisit the staging of quality goals and have fewer goals with lower thresholds upfront, and then, as providers benefit from stimulus payments and become versed in the use of healthcare IT, boost those thresholds over time. ■ Move requirements to implement computerized physician order entry, or CPOE, to Stage 3, which would begin in fiscal 2015. CPOE is a technology that requires too many other IT “feeder systems” to be effectively deployed at the front end, as it is currently scheduled to be.
The bottom line is that we need to get money into the hands of providers faster. This is the investment side of the equation. Without the money to accomplish these goals, many hospitals and physicians just can’t fund the effort.
So what options would the CMS have if it pays all the planned incentives out before the end-state is achieved? They can always slap onerous penalties on later after healthcare providers have at least tried to reach the mark. It’s a better approach than setting up a system that makes it likely that very few providers will ever succeed in maximizing stimulus reimbursement.
The basic question is: What are we really trying to accomplish? If the answer is that we are trying to effect “a transformation of our health system,” then we need to create a path to that destination, not a series of obstructions. <<
Tim Stettheimer is chairman of the board
of the College of Healthcare Information Management Executives and is a regional chief information officer for Ascension Health,