The next 18 months will be a pivotal time period for providers' pursuit of meaningful use incentive money. The payments are already starting to taper off, and the actions taken now by hospitals and health systems could be an important factor in whether they receive the last of their incentive payments or start seeing payment adjustments come 2015.
In a Web session, "Meaningful Use: At the Crossroads between Stage 1 and Stage 2," Bruce Eckert, national practice director at Beacon Partners, said everything changed when the Centers for Medicare and Medicaid Services released its final stage 2 rules in August 2012. Not only do these regulations lay out the requirements for providers moving on to stage 2 in 2014, they also update the stage 1 meaningful use requirements. This update could bring a number of new challenges to participants, regardless of the stage they are in now.
There's very little 2014-certified EHR technology on the marketplace. To attest in 2013 we must first get it from our vendors, so that's going to be a significant challenge.
national practice director, Beacon Partners
For one thing, the updated rules state that all participants -- in both stages 1 and 2 -- must start using EHR systems that are certified using 2014 certification standards at the beginning of 2014. Complicating matters, said Eckert, only about 1% of EHR systems that were certified under the 2009 standards have received the updated certification. With only six months left in the year, providers may have to scramble to update their implementations. "There's very little 2014-certified EHR technology on the marketplace," he said. "To attest in 2013, we must first get it from our vendors, so that's going to be a significant challenge and it's important for us to keep an eye on our vendors."
Similarly, providers must start tracking the 2014 clinical quality measures at the beginning of 2014, even if they are still at stage 1, Eckert said. He discussed some other areas providers should focus on during this pivotal time period.
- Attest as soon as possible. Eckert pointed out that 2015 payment adjustments will be made based on whether providers met the meaningful use requirements in 2013.
- Past performance is no guarantee of future success. Even if a hospital or physician successfully attested to meeting the requirements of stage 1 in 2011 or 2012, it is possible to fail to meet meaningful use requirements in 2013. Providers must continue to ensure that previously implemented EHR systems still meet all meaningful use objectives.
- Stage 2 changes some documentation requirements. For example, there was a change to the denominator for computerized physician order entry (CPOE) requirements. Before stage 2, the denominator for CPOE requirements was "patients," but under the new rules this will change to "orders." The new denominator will be easier for providers to measure, but CPOE requirements could be more difficult to meet, as they set the bar higher, Eckert said.
- Develop a game plan. A number of other regulatory deadlines will come up during the next 18 months, including the transition to ICD-10 codes and various provisions of the Affordable Care Act. Providers who don't have a thorough plan in place now may lose of track of what needs to be done ahead of these deadlines, and implementations will suffer.
- Providers shouldn't think they can simply avoid implementing EHRs and absorb payment adjustments. A growing number of people Eckert talks to are thinking of ducking the headaches of meaningful use attestation and living with the consequences, he said. But when the loss of incentive payments is combined with reimbursement penalties, the six-year hit could top out at more than $4 million, he said, something few hospitals can afford at a time when reimbursement rates are dropping across the board.