The government has finally released its long-awaited “Notice of Final Rulemaking,” which defines “meaningful use” under the Stimulus legislation and spells out the associated regulations. In 556 pages, the document lays out what physicians must do—in addition to implementing a qualified EHR—to meet the meaningful use requirements and earn the EHR incentives. The bottom line: Purchasing a “government EHR” is a money trap for high-performance physicians—particularly specialists.
The new meaningful use requirements are virtually the same as those recommended by the HIT Policy Committee back in July, which means that the requirements remain onerous and unreasonable in terms of the burdens placed on physicians hoping to earn the incentives. There are 25 meaningful-use objectives and related measures, and every one of them must be met every year for a practice to qualify for the incentive money.
Economics clearly do not support participation in the incentive program. A physician must incur the following costs in return for a potential $44,000 earned over five years:
| Capital cost to purchase point-and-click EHR: | $54,000 | * | |||
|---|---|---|---|---|---|
| Annual maintenance & training ($10,000/year): | $50,000 | * | |||
| Cost of reporting for 5 years (9 hrs/year of physician time): | $22,000 | ** | |||
| Cost of additional staff needed to input required data: | $75,000 | *** | |||
| Total: | $201,000 | ||||
| Notes: | |||||
| * ** *** |
Government’s estimate presented in the proposed rule. Estimate for average specialist; see Physician Productivity Calculator. Assumes one nurse shared by three physicians @ $45,000/year. Staffing is based on Phase I of meaningful use requirements and will increase with the more stringent requirements of Phases 2 and 3. |
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This $201,000 five-year loss doesn’t even factor in the exorbitant costs of the lost physician productivity associated with the implementation of a traditional EMR. Nor does it account for the risk of a failed adoption attempt or the inability to achieve meaningful use to the satisfaction of the government.
My concerns are not unique—it is clear that skepticism and doubt abounds among industry stakeholders:
- The length of the document alone should give physicians pause. As A. Cavale, M.D., says in one of the first government blog posts related to the proposed rule:
“If the ONC really wants practicing physicians to read and understand any such criteria, it has to be cognizant of the size of such documents. It would be nearly impossible for a clinician in private practice to dedicate that type of time to read a 556-page document, understand it and implement it.”
- William Jessee, M.D., CEO and president of the MGMA (Medical Group Management Association), wrote in a letter to CMS:
“Overly burdensome requirements and needlessly complex administration will only discourage physician participation in the program and the implementation of EHRs.”
- HIMSS, the EMR-vendor association, issued a warning:
There is still “much work to do within healthcare regarding simple adoption [of electronic health-record systems] well before we can achieve meaningful use of the IT. . . . This foundational work—while required—will likely result in provider uncertainty about which IT products to adopt, costs through adoption of ever-maturing IT over time, higher costs associated with a need to support multiple standards, and somewhat delayed improvements in patient outcomes and costs.”
- HISTalk (venerable healthcare IT blog, 1/4/10) summarized the level of concern:
“Doctors were already avoiding EMRs because of cost and negative workflow impact. Providers are questioning whether they can qualify for the incentives and whether they trust the government to pay them. . . . If you’re a provider trying to decide whether the government money has too many strings attached, this might convince you that it does. And if you asked me how the odds of high EMR utilization changed with the release of these proposed requirements, I’d say they got worse.”
What physicians should focus on instead of the government incentives is implementing a proven product like the hybrid EMR, which helps them operate a highly productive practice where patient care and efficiency are key.
Related posts:
We have an excellent EMR in our subspeciality ophthalmology and ENT practice, which consists of 50+ providers. I thought that eventually EMR would increase efficiency and the extra time required to input data would go away. However, after 3 years of putting up with the inefficiency in my clinic created by EMR; I finally conceded. I now schedule 6 less patients a day and had to hire an additional skilled technician at 37,500 per year.
Note the negative return on investment
SRS would be my current choice of EMR- a hybrid.
Great post, but you forgot a major additional cost. The costs you quote are accurate if the rollout and purchase work without a hitch.
If you implement an EMR product, only to find out that it is the wrong product or doesn’t do what it has promised, you are out at least double your initial purchase cost, probably more!
I am developing a custom EMR workflow product for my client (and blogging about it on my site), and the last thing on his mind is the laughable amount of compensation from Uncle Sam.
These #’s are terribly inflated and seem pulled out of thin air. I am curious how you attained them or what research you did find them. I work with physicians who have implemented EMR systems in their practices everyday and they all agreed that not only are your #’s way off, your reporting is irresponsible at best. I would suggest going back to the drawing board and making another attempt.
Well done. What’s your take for hospitals?
I guess I’m too much of an optimist and want to see widespread EHRs and HIE.
In response to Steven Finch:
Actually, I would argue that if I erred, it was on the low side, since the numbers quoted do not include the cost of lost physician productivity. However, let me address your allegations. Most of the numbers come from the government’s own published estimates or from industry (MGMA) data.
1)The capital cost ($54,000) is stated in the CMS Proposed Rule on Meaningful Use, in the table on page 361, and includes all the acquisition and implementation costs.
2) $10K/year for annual maintenance comes from the same table, and includes ongoing training and upgrades that will be necessary as vendors change their products to keep up with the increasingly stringent requirements for “meaningful use.”
3) In the same table, the government estimates that it will take physicians 9 hours/year to report and document their “meaningful use” for the government. Using MGMA estimates of average physician revenue, this comes to approximately $500 per exam hour for primary-care physicians, and considerably higher for specialists.
4) The cost of additional staff time is an estimate—I believe a conservative one—based on the anticipated need for one staff member for every three physicians to input the information a physician would typically not input, at a cost of approximately $15K/year/physician. Even if you took this number out of the calculation entirely, the costs far outweigh the potential incentives.
Your article is a bit misleading. The stimulus money is $44K per physician while your other costs would be spread over the number of physicians. Our purchase price, maintenance and hardware costs were no where near your estimates if they were per physician.