A 'mean­ing­ful' dead­line nears

De­ci­sion to go for EHR in­cen­tive pay­ments not a sim­ple one for providers

Modern Healthcare - - Front Page - Joseph Conn

Hos­pi­tal lead­ers with ad­vanced health in­for­ma­tion tech­nol­ogy sys­tems will be ap­proach­ing a de­ci­sion dead­line in the com­ing weeks: whether to reach now for the golden ring of fed­eral IT in­cen­tive pay­ments un­der the Amer­i­can Re­cov­ery and Rein­vest­ment Act, or wait one more year.

At stake are first-round pay­ments in what even­tu­ally could be a multi­bil­lion-dol­lar Medi­care elec­tronic health-record in­cen­tive pro­gram.

But what sounds like a no-brainer at first pass—to go for the money now—is a de­ci­sion that’s a lot more weighty and com­plex, with both risks and re­wards even for those well-equipped or­ga­ni­za­tions that have suf­fi­cient IT ca­pa­bil­i­ties in place to qual­ify now for pay­ments un­der Medi­care’s mean­ing­fu­luse cri­te­ria.

The first year of Stage 1 of the Medi­care EHR in­cen­tive pro­gram ends Sept. 30 for hos­pi­tals and at year’s end for physi­cians and other “el­i­gi­ble pro­fes­sion­als.” Or­ga­ni­za­tions will have up to 60 days af­ter those dead­lines to sub­mit needed data and at­test to the CMS that they had been mean­ing­ful users of their cer­ti­fied EHRs for at least 90 con­sec­u­tive days dur­ing the past year.

Sev­eral fac­tors might en­tice providers to jump now: the time value of money re­ceived now ver­sus a year from now; the risk that po­lit­i­cal change will lead to de­pleted fund­ing for the pro­gram; or­ga­ni­za­tional bud­gets that fig­ured in first-year money; and the year’s worth of brag­ging and mar­ket­ing rights as lead­ers in the use of health IT.

The risks, how­ever, could give providers pause about at­test­ing to mean­ing­ful use in 2011. If they do, they com­mit to be­ing mean­ing­ful users for a full 365 days in the sec­ond year of Stage 1. An ex­tra year gives them more time to make every­thing bul­let­proof.

Per­haps the big­gest po­ten­tial draw­back is that Stage 2 rules and cri­te­ria are a work in progress and may not be in fi­nal form un­til sum­mer 2012. Providers who start the clock now could lock them­selves into meet­ing first-year Stage 2 re­quire­ments be­gin­ning Oct. 1, 2012. That’s even though there is no guar­an­tee EHR ven­dors will have their sys­tems tested and cer­ti­fied as Stage 2-com­pli­ant in time for providers to im­ple­ment the up­grades and train their staffs to use them in time to meet that tight dead­line.

In June, the fed­er­ally char­tered Health IT Pol­icy Com­mit­tee, aware of this time crunch, rec­om­mended to the Of­fice of the National Co­or­di­na­tor for Health In­for­ma­tion Tech­nol­ogy and through it to the CMS that providers who start now and seek mean­ing­ful-use sta­tus in 2011 be given an ex­tra, or third, year us­ing Stage 1 cri­te­ria. The CMS, which has the fi­nal say, has yet to an­nounce whether they’ll ac­cept the rec­om­men­da­tion.

In Fe­bru­ary, the Ad­vi­sory Board Co., a man­age­ment and IT con­sult­ing firm, is­sued a three-page guid­ance urg­ing its clients to wait un­til fis­cal 2012 be­fore start­ing their climb up the mean­ing­ful-use stair­case.

The con­sul­tants said the money will be the same—roughly $7.2 mil­lion for a “typ­i­cal” 200-bed hos­pi­tal with 20,000 dis­charges and a 40%/20% Medi­care/Med­i­caid pa­tient mix—whether they go now or wait un­til next year.

Protima Ad­vani, the Ad­vi­sory Board’s strate­gic re­search di­rec­tor, says her ad­vice re­mains the same to­day.

“I am stick­ing with my guns for a cou­ple of rea­sons,” she said.

The CMS was “very vo­cal” dur­ing a re­cent we­bi­nar that the timetable in the cur­rent rule re­mains un­changed. “If you were to hold to the let­ter of the law, you must ac­cept you’re go­ing to have to be there (at Stage 2) by Oc­to­ber 2012.”

Even for those lead­ers of hos­pi­tals that are able to at­test they’ve been mean­ing­ful users, Ad­vani said, “Run your data, but if you don’t see some­thing solid be­fore Nov. 30, by all means don’t push your ‘sub­mit’ but­ton.” Providers have 60 days af­ter the end of the first “pay­ment year” on Sept. 30 to sub­mit re­quired data and their at­tes­ta­tions to the CMS, she said.

Ad­vani rec­om­mends, in­stead, that providers ap­ply for Med­i­caid in­cen­tives, since Med­i­caid ini­tially re­quires only that providers “adopt, im­ple­ment or up­grade (to)” a cer­ti­fied EHR, but not demon­strate mean­ing­ful use.

Through Aug. 31, there are 2,054 hos­pi­tals reg­is­tered with the CMS to re­ceive in­cen­tive pay­ments ei­ther un­der the Medi­care por­tion of the pro­gram, or un­der both Medi­care and Med­i­caid, which means they would still need to at­test to hav­ing met Medi­care mean­ing­ful-use cri­te­ria to re­ceive a Medi­care in­cen­tive pay­ment. But only 114 of these reg­is­tered hos­pi­tals—fewer than 6% of those reg­is­tered—have at­tested to be­ing mean­ing­ful users so far this year. They’ve split about $ 226 mil­lion in Medi­care EHR in­cen­tive pay­ments.

Sim­i­larly, for the same pe­riod, 71,378

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